August 2010 3-1 Draft NUREG-1941 

1 3.0 Site Layout and Plant Description 

2 The site of proposed Levy Nuclear Plant (LNP) Units 1 and 2 is located in rural Levy County, 

3 Florida. Progress Energy Florida, Inc. (PEF) applied to the U.S. Nuclear Regulatory Commission 

4 (NRC or the Commission) for combined construction permits and operating licenses (COLs) for 

5 the two new units. On June 2, 2008, PEF submitted a Site Certification Application to the Florida 

6 Department of Environmental Protection (FDEP) (PEF 2008). The U.S. Army Corps of 

7 Engineers (USACE) received a copy of this application on June 30, 2008. In its March 16, 2009, 

8 Public Notice (USACE 2009), the USACE stated that the Environmental Resource Permit 

9 application contained in the Site Certification Application, along with its supporting documents, 

10 make up the Department of the Army permit application to affect waters of the United States. 

11 Conditions of Certification for LNP Units 1 and 2, associated facilities, and transmission lines 

12 were issued on August 26, 2009 and subsequently modified on January 12, 2010 and 

13 February 23, 2010 (FDEP 2010a). The site is approximately 44 mi southwest of Gainesville and 

14 approximately 30 mi west of Ocala, Florida. It is 7.9 mi from the Gulf of Mexico and 9.6 mi from 

15 the Crystal River Energy Complex (CREC), an energy facility also owned by PEF (2009a). 

16 This chapter describes the key plant characteristics that are used to assess the environmental 

17 impacts of the proposed actions. The information is drawn primarily from PEF’s Environmental 

18 Report (ER) (PEF 2009a), its Final Safety Analysis Report (FSAR) (PEF 2009b), the USACE’s 

19 Public Notice (USACE 2009), and supplemental documentation from PEF, as referenced. 

20 Whereas Chapter 2 of this environmental impact statement (EIS) describes the existing 

21 environment of the LNP site and its vicinity, this chapter describes the physical layout of the 

22 proposed plant. This chapter also describes the physical activities involved in building and 

23 operating the plant and associated transmission lines. The environmental impacts of building 

24 and operating the plant are discussed in Chapters 4 and 5, respectively. This chapter is divided 

25 into five sections. Section 3.1 describes the external appearance and layout of the proposed 

26 plant. Section 3.2 describes the major plant structures, systems, and components (SSC) and 

27 distinguishes those that interface with the environment from those that do not interface with the 

28 environment or that interface with the environment temporarily. Section 3.3 describes the 

29 activities involved in building or installing each of the major plant SSC. Section 3.4 describes 

30 the operational activities of the plant SSCs that interface with the environment. References 

31 cited are listed in Section 3.5. 

32 3.1 External Appearance and Plant Layout 

33 The 3105-ac site (PEF 2009a) identified as the location of the proposed LNP has been used as 

34 a commercial forest plantation (pine tree production and harvesting operations) for over a 

35 century. The two proposed reactors and associated support buildings would occupy land near 

36 the center of the site. The site, including the planned footprint for proposed LNP Units 1 and 2, 

37 is shown in Figure 3-1. 
Site Layout and Plant Description 

Draft NUREG-1941 3-2 August 2010 

1 

2 Figure 3-1. Proposed LNP Site Footprint (modified from PEF 2009a) 
Site Layout and Plant Description 

August 2010 3-3 Draft NUREG-1941 

1 The containment vessel, shield building, and auxiliary building make up the “nuclear island,” 

2 which is one of five principal structures of the standard Westinghouse Electric Company, LLC 

3 (Westinghouse) AP1000 nuclear power reactor design (Westinghouse 2008) proposed for LNP 

4 Units 1 and 2. The other four principal structures of an AP1000 unit are the turbine, diesel 

5 generator, radwaste facility, and annex buildings (PEF 2009a). 

6 The proposed location of LNP Units 1 and 2 would have a design site grade of 50 ft North 

7 American Vertical Datum 1988 (NAVD88) (PEF 2009a). Each reactor containment structure for 

8 the AP1000 is approximately 225 ft high and 130 ft in diameter. Each reactor unit is supported 

9 by a multicell mechanical draft cooling tower that is approximately 1000 ft long and 56 ft high 

10 (PEF 2009a). A conceptual drawing with proposed LNP Units 1 and 2 superimposed on the site 

11 is shown in Figure 3-2. 

12 3.2 Proposed Plant Structures, Systems, and Components 

13 This section describes each of the major plant structures: the reactor power system, structures 

14 that would have a significant interface with the environment during operation, and the balance of 

15 plant structures. All of these structures are relevant in the discussion of the impacts of building 

16 the proposed Units 1 and 2 in Chapter 4. Only the structures that interface with the environment 

17 are important to the operational impacts discussed in Chapter 5. 

18 3.2.1 Reactor Power Conversion Systems 

19 PEF has proposed building and operating two Westinghouse AP1000 reactor steam electric 

20 generating systems at the LNP site. On January 27, 2006, the NRC issued the final design 

21 certification rule for the AP1000 in the Federal Register (71 FR 4464) based on Revision 15 of 

22 the AP1000 Design Control Document (DCD) (Westinghouse 2005). Each applicant or licensee 

23 intending to construct and operate a plant based on the AP1000 design may do so by 

24 referencing its design certification rule, as set forth in Appendix D to Title 10 of the Code of 

25 Federal Regulations (CFR) Part 52. 

26 Westinghouse is requesting to amend the AP1000 DCD. As mentioned in Section 1.1.4, the 

27 reactor design referenced in the application is Revision 17 of the certified design (Westinghouse 

28 2008). The amended application is currently undergoing review. The status of the amended 

29 DCD review is available at www.nrc.gov. Each AP1000 reactor is connected to two steam 

30 generators that transfer heat from the reactor core, converting feed water to steam that drives 

31 high-pressure and low-pressure turbines, thereby creating electricity. Steam that has passed 

32 through the turbines is condensed back to water that is heated and pumped back to the steam 

33 generators, repeating the cycle. The AP1000 design has a thermal power rating of 3415 MW(t), 

34 with a design gross-electrical output of approximately 1200 MW(e). The expected net electrical 

35 output for each unit would be greater than 1000 MW(e) (PEF 2009a). Figure 3-3 is an 

36 illustration of the reactor power-conversion system. 
Draft NUREG-1941 3-4 August 2010 

Site Layout and Plant Description 

1 

Figure 3-2. Conceptual Drawing with the Proposed Units 1 and 2 Superimposed on the Proposed Site (PEF 2009a) 2 
August 2010 3-5 Draft NUREG-1941 

Site Layout and Plant Description 1 Figure 3-3. Simplified Flow Diagram of the Reactor Power Conversion System (PEF 2009a) 2 
Site Layout and Plant Description 

Draft NUREG-1941 3-6 August 2010 

1 3.2.2 Structures, Systems, and Components with a Major Environmental 

2 Interface 

3 The review team (composed of NRC staff, its contractor staff, and USACE staff) divided the 

4 plant structures, systems, and components into two primary groups: those that interface with 

5 the environment and those that are internal to the reactor and associated facilities but without 

6 direct interaction with the environment. Examples of interfaces with the environment are 

7 withdrawal of water from the environment at the intake structures, release of water to the 

8 environment at the discharge structure, and release of excess heat to the atmosphere from the 

9 cooling towers. The interaction of structures, systems, or components with environmental 

10 interfaces are considered in the review team’s assessment of the environmental impacts of 

11 facility construction and preconstruction, and facility operation in Chapters 4 and 5, respectively. 

12 The power-production processes that would occur within the plant itself and that do not affect 

13 the environment are not relevant to a National Environmental Policy Act of 1969, as amended 

14 (NEPA) (42 U.S.C. 4321, et seq.) review and are not discussed further in this EIS. However, 

15 such internal processes are considered by the NRC staff in the Westinghouse AP1000 design 

16 certification documentation and in other NRC safety reviews of the PEF COL application. This 

17 section describes the structures, systems, and components that have a significant plant18 environment interface. 

19 The remaining structures, systems, and components are discussed in Section 3.2.3, inasmuch 

20 as they may be relevant in the review team’s consideration of environmental impacts discussed 

21 in Chapters 4 and 5. 

22 3.2.2.1 Landscape and Stormwater Drainage 

23 Landscaping and the stormwater-drainage system affect both the recharge to the subsurface 

24 groundwater and the rate and location that precipitation drains into adjacent creeks and 

25 streams. Impervious areas reduce recharge to aquifers beneath the site. Pervious areas, for 

26 example, graveled laydown areas, managed to reduce runoff and maintained free of vegetation, 

27 would experience considerably higher recharge rates than adjacent vegetated areas. The 

28 stormwater-management system includes site grading, drainage ditches, swales, and retention 

29 and filtration ponds. This system provides both a safety function to keep locally intense 

30 precipitation from flooding safety-related structures, and an environmental function of managing 

31 site runoff to minimize erosion and impacts on nearby water resources. Three retention and 

32 infiltration ponds would be created on the LNP site (PEF 2009a). These ponds are shown in 

33 relation to major structures, parking lots, and laydown areas in Figure 3-4. 

34 3.2.2.2 Cooling System 

35 The cooling system and its principal components would represent one of the largest interfaces 

36 between proposed Units 1 and 2 and the environment. Makeup water would be provided to the 
Site Layout and Plant Description 

August 2010 3-7 Draft NUREG-1941 

1 

2 Figure 3-4. LNP Units 1 and 2 Detailed Site Layout (modified from PEF 2009a) 
Site Layout and Plant Description 

Draft NUREG-1941 3-8 August 2010 

1 plant from the Cross Florida Barge Canal (CFBC) through a cooling-water-intake structure 

2 (CWIS) located on the north side of the canal and south of the LNP site. A portion of the 

3 makeup water would be returned to the environment via the discharge structure at the CREC 

4 site. The remaining portion of the water would be released into the atmosphere via evaporative 

5 cooling through mechanical draft cooling towers. The intake and discharge structures and 

6 mechanical draft cooling towers are components that have a major plant-environment interface. 

7 This section describes these components based on the information provided by PEF in its ER 

8 (PEF 2009a) and FSAR (PEF 2009b). 

9 Cooling-Water Intake Structure 

10 Proposed LNP Units 1 and 2 would obtain makeup water for the circulating-water system (CWS) 

11 from the CFBC. A CWIS would be constructed on the north bank of the canal approximately 

12 0.5 mi west of Inglis Lock (Figure 3-1). The length of the water-facing side of the intake 

13 structure would be approximately 111 ft. The intake structure would extend approximately 86 ft 

14 inland from the water’s edge (PEF 2009a). A structure containing the intake pumps and pipe 

15 manifold would extend approximately 25 ft farther inland (PEF 2009c). Figure 3-5 and 

16 Figure 3-6, respectively, show the approximate dimensions and location of the intake structure. 

17 The bottom of the intake structure would be approximately 10 ft below the water surface in the 

18 canal (PEF 2009d). The intake structure would house six raw-water pumps (three per AP1000 

19 unit), each in an individual pump bay with vertical trash bars for coarse-debris removal and a 

20 traveling screen for fine-debris removal. The traveling screens would have mesh openings of 

21 3/8 in. (PEF 2009a). The intake structure would also house pumps for washing the traveling 

22 screens, but PEF has not proposed a fish return system. 

23 Discharge Structure 

24 No new discharge structure is proposed for LNP Units 1 and 2. Cooling-water discharges from 

25 LNP Units 1 and 2 would be transported via pipeline from the LNP site to the CREC site 

26 (Figure 3-7). The LNP discharge would be combined with CREC discharges and released into 

27 the existing CREC discharge canal to be ultimately released into the Gulf of Mexico (PEF 

28 2009d). Pipelines are described in Section 3.2.3. 

29 Cooling Towers 

30 The LNP Units 1 and 2 CWS would use mechanical draft cooling towers to dissipate waste heat 

31 from the plant. Each reactor unit would be served by a multicell cooling tower and each tower 

32 would be approximately 1000 ft long and approximately 56 ft high (PEF 2009a). Each CWS 

33 cooling tower would be located west of its respective unit (Figure 3-4). The service-water 

34 system would use a two-cell mechanical draft cooling tower with a divided basin (PEF 2009a) to 

35 cool the nonsafety-related component cooling-water system heat exchangers in the turbine 

36 building. The SWS cooling tower would be located adjacent to the turbine building. 
August 2010 3-9 Draft NUREG-1941 

Site Layout and Plant Description 1 Figure 3-5. Section View of the Cooling-Water-Intake Structure (PEF 2009a) 2 
Draft NUREG-1941 3-10 August 2010 

Site Layout and Plant Description 

1 

Figure 3-6. Proposed Cooling-Water-Intake Structure and Barge Unloading Facility Layout (PEF 2008c) 2 
August 2010 3-11 Draft NUREG-1941 

Site Layout and Plant Description 1 Figure 3-7. Discharge Pipeline Route and CREC Discharge Canal (PEF2009a) 2 
Site Layout and Plant Description 

Draft NUREG-1941 3-12 August 2010 

1 3.2.2.3 Other Permanent Structures, Systems, or Components with an Environmental 

2 Interface 

3 Buildings and roads are the additional permanent plant-environment interfacing structures that 

4 would be built on the LNP site. 

5 Diesel-Generator Building 

6 Diesel generators would be installed on the site to provide a backup source of power when the 

7 normal power source is disrupted. Combustion emissions would be released to the atmosphere 

8 from the generators only during emergency operations and periodic testing. Two standby diesel 

9 generators and two auxiliary diesel generators would be located in the diesel-generator building 

10 (PEF 2009a). 

11 Roads 

12 The workforce and some material would enter and exit the site via roads. Access to the LNP 

13 site would be provided by two access roads approaching the site from U.S. Highway 19 

14 (US-19). Solid waste and radioactive waste are expected to leave the site via roadways. Large 

15 components and material shipments would be brought onsite via a new heavy-haul road that 

16 would enter the site from the south and connect to US-40. A barge slip access road would 

17 connect the barge slip to the heavy-haul road (Figure 3-1). The barge slip access road would 

18 also allow access to the intake structure. The heavy-haul road would be 3.3 mi long and the 

19 barge slip access road would be 0.6 mi long (PEF 2009a). 

20 Diaphragm Wall and Grout Injection 

21 Building LNP Units 1 and 2 would require excavation below the current water table elevation. 

22 Therefore, temporary dewatering would be necessary. The current conceptual foundation 

23 design calls for substantial dewatering of each nuclear island area to depths of approximately 

24 100 ft below existing grade (PEF 2009b). Diaphragm walls would be installed below land 

25 surface surrounding the area to be excavated to minimize the lateral flow of groundwater into 

26 the excavation. Grout would also be injected into the carbonate rock below the planned 

27 excavation depth to minimize upward groundwater flow into the excavation. 

28 Groundwater Wells 

29 Groundwater wells would be installed to supply water for building activities and to supply water 

30 to the raw-water system. During plant operations, water would be withdrawn to supply makeup 

31 water to the service-water system, and provide raw water to the potable-water supply, the 

32 demineralized-water system, for fire protection, and for media filter backwash (PEF 2009b). 

33 Four groundwater wells would be located south of the LNP site and north of the CFBC 

34 (Figure 3-1). 
Site Layout and Plant Description 

August 2010 3-13 Draft NUREG-1941 

1 Barge-Unloading Facility 

2 Large components for the proposed reactors would be brought to the site on barges. A barge 

3 facility would be needed to allow components to be unloaded onto transporters and moved to 

4 the site. The barge-unloading facility would be located on the northern bank of the CFBC west 

5 of the CWIS (Figure 3-1) (PEF 2009a). 

6 Radwaste Facility 

7 Liquid, gaseous, and solid radioactive waste-management systems would collect the radioactive 

8 materials produced as byproducts of operating the proposed units. These systems would 

9 process radioactive liquid, gaseous, and solid effluents to maintain releases within regulatory 

10 limits as described in Section 3.4.3. 

11 Sanitary Waste-Treatment Plant 

12 The proposed sanitary waste-treatment plant would consist of two package sewage-treatment 

13 plant units. 

14 Power Transmission System 

15 The LNP site is a greenfield site and not presently connected to the regional power grid 

16 (Section 2.2.2). Integrating the additional electrical output of the proposed units would require 

17 that several new transmission-line corridors be acquired and transmission lines be built. PEF is 

18 in the process of acquiring rights-of-way for transmission-line corridors that would provide the 

19 connection between the LNP site and the area power grid. 

20 The LNP site would be connected into the PEF transmission system, which supplies large load 

21 centers in the Central Florida region, including Orlando and St. Petersburg (PEF 2009a). The 

22 two power-generating units would be tied into the PEF 500-kV transmission system via a 

23 500-kV switchyard and four 500-kV transmission lines. These lines would connect the LNP site 

24 to the Citrus substation and the Central Florida South substation, with two 500-kV transmission 

25 lines connecting each. PEF is currently in the process of acquiring and planning rights-of-way 

26 for transmission-line corridors exiting the LNP site. The proposed corridor would fall within 

27 wider planning corridors ranging from 1000 to 2640 ft wide to allow for flexible planning. 

28 Figure 2-5 shows the proposed transmission-line corridors and substations. The addition of two 

29 69-kV lines would also be required to support building and administrative operations. In total, 

30 about 180 mi of new transmission-line corridor would be needed to connect the LNP site to the 

31 electrical grid system (PEF 2008). Table 2-1 lists the affected land uses and linear runs of each 

32 potential corridor. 

33 The operation of LNP Units 1 and 2 would require that two additional substations be added to 

34 the Florida electrical grid (PEF 2009a). The first, an expansion at the Citrus substation, would 
Site Layout and Plant Description 

Draft NUREG-1941 3-14 August 2010 

1 be approximately 70 ac in size and would be designed to support 500-kV and 230-kV 

2 transmission lines. It would be located in Citrus County near the existing Crystal River East 

3 substation. The second, the proposed Central Florida South substation, would be 

4 approximately 60 ac in size and support both 500-kV and 230-kV lines. It would be located due 

5 south of the existing Central Florida substation. 

6 Four 230-kV transmission lines would also be needed beyond the Central Florida South and the 

7 Citrus substations (PEF 2009a). The first of these routes would be a transmission-line corridor 

8 accommodating two 230-kV lines that connect the Crystal River East substation to the proposed 

9 Citrus substation. Another 230-kV transmission line would originate at the CREC 500-kV 

10 switchyard and terminate at the existing Brookridge substation in Hernando County. The third 

11 line would begin at the Brookridge substation and run to the Brooksville West substation, both of 

12 which are in Hernando County. A fourth transmission line would be built from Polk to 

13 Hillsborough to Pinellas, originating at the Kathleen substation in Polk County, running south to 

14 the Griffin substation in Hillsborough County, and running west to terminate at the existing Lake 

15 Tarpon substation in Pinellas County. This transmission line would be collocated with the 

16 Kathleen-Griffin 230-kV line and the Higgins-Griffin 115-kV line, an existing transmission-line 

17 corridor. 

18 3.2.2.4 Other Temporary Plant-Environment Interfacing Structures 

19 Some temporary plant-environment interfacing structures would need to be removed before 

20 proposed Units 1 and 2 operation commences; for example, a concrete batch plant. The 

21 impacts from the operation and installation of these structures are discussed in Chapter 4. 

22 Dewatering Systems 

23 Dewatering systems (dewatering wells or sump pumps) are used to lower the water table in 

24 excavations that would otherwise be inundated by the influx of groundwater. Water within the 

25 structure created by the diaphragm walls and grouted limestone would then be removed by 

26 using shallow wells and sump pumps (PEF 2009b). 

27 Cranes and Crane Footings 

28 Crane footings would be fabricated and cranes would be erected on the site to build the plant. 

29 Concrete Batch Plant 

30 A concrete batch plant would be located onsite to supply concrete for structures (Figure 3-4). 

31 The facility would house the equipment needed for delivery, materials handling and storage, and 

32 preparation of concrete. 
Site Layout and Plant Description 

August 2010 3-15 Draft NUREG-1941 

1 3.2.3 Structures with a Minor Environmental Interface 

2 The structures described in the following sections would have minimal plant-environment 

3 interfaces during plant operation. The impacts of these structures on the environment were 

4 determined by the review team to be of such minor significance that the structures are not 

5 discussed in Chapter 5. 

6 3.2.3.1 Nuclear Island, Turbine Building, and Annex Building

7 The AP1000 nuclear island consists of a containment building, shield building, and an auxiliary 

8 building. The foundation for the nuclear island is an integral basemat that supports these 

9 buildings. The nuclear island structures are designed to withstand the effects of natural 

10 phenomena such as hurricanes, floods, tornadoes, tsunamis, and earthquakes without loss of 

11 capability to perform safety functions (PEF 2009a). The turbine building houses the main 

12 turbine generator and associated systems. The annex building provides personnel and 

13 equipment support areas, and access to the nuclear island. 

14 3.2.3.2 Pipelines

15 Water would be sent from the intake structure on the CFBC approximately 4 mi to the onsite 

16 cooling-tower basins through two 54-in.-diameter intake pipelines for each nuclear unit (four in 

17 total) (PEF 2009d). The intake pipeline corridor is shown in Figure 3-1 and in Figure 3-4. 

18 Two additional 54-in.-diameter pipelines would carry discharged cooling water from both units 

19 approximately 13 mi to the CREC discharge canal (Figure 3-7). The pipelines would cross over 

20 the Inglis Lock bypass channel and under the CFBC (PEF 2009d). Additional pipelines would 

21 be required to move water from groundwater wells to operating facilities and between the 

22 cooling towers and the plant systems requiring cooling. 

23 3.2.3.3 Miscellaneous Buildings 

24 A variety of small buildings would exist throughout the site to support worker, fabrication, 

25 building, and operational needs (e.g., shop buildings, support offices, warehouses, and guard 

26 houses). Some buildings may be temporary and would be removed after the plant begins 

27 operation. 

28 3.2.3.4 Parking 

29 Parking areas would be created to support the construction workforce and some parking would 

30 be retained for the operating workforce once plant installation is completed (Figure 3-4). 
Site Layout and Plant Description 

Draft NUREG-1941 3-16 August 2010 

1 3.2.3.5 Laydown Areas 

2 Multiple laydown areas would be established to support fabrication and erection activities while 

3 building the plant and may be maintained as laydown areas for future maintenance and 

4 refurbishment of the plant (Figure 3-4). Laydown areas are graded relatively level and covered 

5 with crushed stone or gravel. Normally only limited vegetation is allowed in laydown areas. 

6 3.2.3.6 Switchyard 

7 The location of the proposed switchyard is shown in Figure 3-4. The switchyard would be 

8 maintained free of vegetation. 

9 3.3 Construction and Preconstruction Activities 

10 The NRC’s authority is limited to construction activities that have a “reasonable nexus to 

11 radiological health and safety or common defense and security” (72 FR 57416) and the NRC 

12 has defined “construction” within the context of its regulatory authority. Examples of 

13 construction (defined at 10 CFR 50.10(a)) activities for safety-related structures, systems, or 

14 components include driving of piles; subsurface preparation; placement of backfill, concrete, or 

15 permanent retaining walls within an excavation; installation of foundations; or in-place assembly, 

16 erection, fabrication, or testing. 

17 Other activities related to building the plant that do not require NRC approval (but may require a 

18 Department of Army permit from the USACE) may occur before, during, or after NRC-authorized 

19 construction activities. These activities are termed “preconstruction” in 10 CFR 51.45(c) and 

20 may be regulated by other local, State, Tribal, or Federal agencies. Preconstruction includes 

21 activities such as site preparation (e.g., clearing, grading, erosion control, and other 

22 environmental mitigation measures); erection of fences; excavation; erection of support 

23 buildings or facilities; building service facilities (e.g., roads, parking lots, transmission lines, 

24 sanitary waste-treatment system, intake and discharge structures); dredging; and procurement 

25 or fabrication of components occurring at other than the final in-place location at the site. 

26 Activities not included in construction are identified in 10 CFR 51.10(a)(2). Additional 

27 information about the delineation of construction and preconstruction activities is presented in 

28 Chapter 4. 

29 This section describes the structures and activities associated with building proposed Units 1 

30 and 2. This section characterizes the major activities for the principal structures to provide the 

31 requisite background for the assessment of environmental impacts. However, it does not 

32 represent a discussion of every potential activity or a detailed engineering plan. Table 3-1 

33 provides general definitions and examples of activities that would be performed when building 

34 the proposed units. 
Site Layout and Plant Description 

August 2010 3-17 Draft NUREG-1941 

1 Table 3-1. Descriptions and Examples of Activities Associated with Building Units 1 and 2 

Activity Description Examples 

Clearing Removing vegetation or existing structures from 

the land surface. 

Cutting planted pines from an area to be 

used for construction laydown. 

Grubbing Removing roots and stumps by digging Removing stumps and roots of pines logged 

from construction laydown area. 

Grading Reforming the elevation of the land surface to 

facilitate operation of the plant and drainage of 

precipitation. 

Leveling the site of the reactors and cooling 

towers. 

Hauling Transporting of material and workforce along 

established roadways. 

Driving on construction access road by 

construction workers; transporting material 

from the barge slip to the site on the barge 

slip access road. 

Paving Laying impervious surfaces, such as asphalt 

and concrete, to provide roadways, walkways, 

parking areas and site drainage. 

Paving a parking area. 

Well drilling Drilling and completion of wells. Drilling water-supply wells. 

Shallow excavation Digging a hole or trench to a depth reachable 

with a backhoe. Shallow excavation may not 

require dewatering. 

Placing pipelines; setting foundations for 

small buildings. 

Deep excavation Digging an open hole in the ground. Deep 

excavation requires equipment with greater 

vertical reach than a backhoe. Deep excavation 

generally requires dewatering systems to keep 

the hole from flooding. 

Excavating to support fabrication of the 

basemat for the reactor. 

Excavation 

dewatering 

Pumping water from wells or pumping water 

directly to keep excavations from flooding with 

groundwater or surface runoff. 

Pumping water from excavation of base for 

reactor building. 

Grouting Installing low-permeability material in the 

subsurface around deep excavation to minimize 

movement of groundwater. 

Installing a diaphragm wall around the 

excavation for the reactor building. 

Dredging Removing substrates and sediment in navigable 

waters including wetlands. 

Creating the barge slip. 

Filling of wetland or 

water body 

Discharging dredge and/or fill material into 

waters of the United States including wetlands. 

Placing fill material into a wetland to bring it 

to grade with adjacent land surface. 

Dredge placement Placing fill material in areas not designated as 

wetlands. These materials can come from 

dredging wetlands. 

Placing sediments removed from the barge 

slip in a USACE-approved placement area. 
Site Layout and Plant Description 

Draft NUREG-1941 3-18 August 2010 

1 Table 3-1. (contd) 

Activity Description Examples 

Spoils placement Placing construction (earthwork) or dredged 

material in an upland location. 

Placing sediment excavated from the intake 

area in upland disposal area. 

Filling of aquatic 

resources 

Discharge of dredge and/or fill material into 

waters of the United States, including wetlands. 

Placing a culvert for a roadway. 

Erection Assembling all modules into their final positions 

including all connection between modules. 

Using a crane to assemble reactor modules.

Fabrication Creating an engineered material from the 

assembly of a variety of standardized parts. 

Fabrication can include conforming native soils 

to some engineered specification (e.g., 

compacting soil to meet some engineered fill 

specification). 

Preparing and pouring concrete; laying 

rebar for basemat. 

Vegetation 

management 

Thinning, planting, trimming, and clearing 

vegetation. 

Maintaining the switchyard free of 

vegetation. 

Source: PEF 2009a 

2 3.3.1 Major Activity Areas 

3 PEF has stated that activities required to build the proposed units would occur primarily within 

4 the boundaries of the LNP site and at offsite locations along the CFBC (PEF 2009a), except for 

5 the new transmission lines and substations described in Sections 2.2.2 and 3.2.2.3. Access 

6 roads for Units 1 and 2 would enter the property from the northwest and the south (barge slip 

7 access road). The intake structure would be on the CFBC, south of Units 1 and 2. The 

8 following sections briefly describe the construction and preconstruction activities associated with 

9 the structures described in Sections 3.2.2 and 3.2.3. 

10 3.3.1.1 Landscape and Stormwater Drainage 

11 Preparation for building and operating the proposed LNP Units 1 and 2 would require land to be 

12 cleared and graded for the main reactor buildings and support facilities and additional space for 

13 material and equipment laydown areas. The elevation of the land surface in some areas of the 

14 site would be raised to meet the requirements of the AP1000 DCD (Westinghouse 2008). The 

15 details of the alterations are discussed in the following sections. 

16 After the site is graded, a stormwater-drainage system would be created around the facilities to 

17 direct stormwater away from the operational areas. Drainage ditches and pipes would route 

18 surface water to three water-retention and/or infiltration ponds. The locations of these ponds 

19 are shown in Figure 3-4. 
Site Layout and Plant Description 

August 2010 3-19 Draft NUREG-1941 

1 3.3.1.2 Circulating-Water Intake Structure

2 Building the intake structure would require excavation to more than 10 ft below the water level, 

3 and dredging of a portion of the CFBC. Figure 3-6 shows a proposed temporary cofferdam in 

4 place enclosing an area approximately twice as wide as the proposed intake structure and 

5 extending out into the CFBC. The cofferdam is surrounded by a turbidity curtain. Riprap will be 

6 installed on the canal bank upstream and downstream of the intake structure. 

7 3.3.1.3 Circulating-Water Discharge Structure 

8 No new building is expected for the discharge structure outside of the existing CREC discharge 

9 canal. 

10 3.3.1.4 Diesel Generators 

11 Building the diesel-generator facility would involve limited fabrication and erection. 

12 3.3.1.5 Roads 

13 Building of the heavy-haul road and the barge slip access road would require land to be cleared 

14 and graded along the proposed route shown in Figure 3-1 (PEF 2009a). Temporary and 

15 permanent access roads to support site building and operations activities would require land to 

16 be cleared and graded along the routes shown in Figure 3-4 (PEF 2009a). 

17 3.3.1.6 Grouting and Dewatering 

18 The grouting program would consist of vertical diaphragm walls around the proposed 

19 powerblock area to minimize lateral groundwater inflow and pressure grouting of the Avon Park 

20 Formation below the planned excavation depth. These two engineered barriers would form a 

21 “bathtub” that can then be dewatered and excavated. 

22 Shallow excavation for foundations for other buildings and trenching for pipelines may also 

23 require dewatering. 

24 Water from the excavations would be pumped to temporary ponds constructed to allow the 

25 water to percolate into the subsurface. PEF indicates that sedimentation traps or filtration would 

26 be included in the design of the dewatering system to ensure that negligible erosion or siltation 

27 occurs during the dewatering operation (PEF 2009a). 

28 Dewatering wells would be drilled into the Upper Floridan aquifer using standard drilling 

29 practices. 
Site Layout and Plant Description 

Draft NUREG-1941 3-20 August 2010 

1 3.3.1.7 Water-Supply Wells 

2 PEF plans to construct four 16-in.-diameter water-supply wells south of the plant. The wells 

3 would be constructed to a maximum depth of 500 ft and cased to at least 150 ft. The pump 

4 capacity for each well would be 1000 gpm. Wells would be drilled using standard drilling 

5 practices (PEF 2009e). 

6 The four onsite water-supply wells would be used to obtain water for site-preparation and 

7 building activities. During building, the total maximum usage is projected to be 550,000 gpd and 

8 the projected average estimated maximum groundwater usage is 275,000 gpd. These 

9 estimates include the following: 

10 • 300,000 gpd for soil compaction 

11 • 100,000 gpd for dust and erosion control 

12 • 100,000 gpd for concrete mixing 

13 • 50,000 gpd for other miscellaneous uses (PEF 2009a). 

14 3.3.1.8 Barge Facility 

15 Excavation for the barge slip would require dredging of 1.1 ac below mean high water and 

excavation of 1.0 ac above mean high water. PEF estimates that 83,044 yd3 16 of material would 

be excavated to create the barge slip (PEF 2009a). Of this amount, 23,260 yd3 17 would be 

18 dredged material. 

19 Dredge spoil stockpile areas would be graded and compacted by traffic. The stockpile areas 

20 would be surrounded by silt fencing or vegetated buffer strips. Dredge spoils would be 

21 characterized and stockpiled for future use or properly disposed of according to regulatory 

22 requirements, if necessary. Spoil areas would have water sprayed on exposed soil to minimize 

23 wind erosion during dry periods. Vegetation would be grown on stockpiles to minimize erosion 

24 (PEF 2009a). 

25 3.3.1.9 Sanitary Waste-Treatment Plant 

26 Building the sanitary waste-treatment plant would involve limited fabrication and erection. 

27 3.3.1.10 Power Transmission System 

28 Building the transmission system would require the removal of trees and shrubs along portions 

29 of the transmission-line corridor and involve the erection and fabrication of switchyard and 

30 transmission lines (PEF 2009a). 
Site Layout and Plant Description 

August 2010 3-21 Draft NUREG-1941 

1 Transmission structures would be built on various types of engineered foundations. These 

2 foundations would likely be either direct buried with a concrete backfill or reinforced concrete 

3 drilled piers. Guys and anchors at angle and corner structures would also be used to support 

4 the loads at corners. PEF estimates that it would require approximately 91 mi of transmission 

5 lines to connect the LNP site to the first substations. Standard structure heights would range 

6 from 110 to 195 ft, with span lengths of 1000 to 1500 ft between structures. Ground clearance 

7 for the transmission lines would be 35 ft at 284°F (conductor temperature). Phase spacing 

8 would be approximately 34 ft, with each structure typically carrying a single circuit line of three 

9 phases of triple-bundled, steel-reinforced aluminum conductors of 1590 thousand circular mils 

10 with two shield wires (PEF 2009a). Figures 9 A3.2-1 through 9 A3.2-14 in the Site Certification 

11 Application to the State of Florida provide representative arrangements of alternative tower 

12 designs within proposed corridors; Figures 9 A3.2-15 and 9 A3.2-16 provide illustrations of 

13 potential ground-disturbing activities, including the building of access roads and transmission 

14 tower footings (PEF 2008). 

15 The 500-kV transmission lines and their support structures would be designed to handle a range 

16 of extreme weather conditions experienced in the area (PEF 2009a). PEF designed its 

17 transmission system to meet several load cases. These load cases include 2007 National 

18 Electric Safety Code (NESC) Light Load District standards for combined ice and wind load of 

19 0-in. radial ice and 60-mph winds. In addition, the transmission system has been designed to 

20 meet the 2007 NESC Extreme Wind Loading of 130-mph winds, and PEF’s High Wind Loading 

21 threshold of 145 mph (PEF 2009a).

22 3.3.1.11 Cranes and Crane Footings 

23 Fabricating footings, building retaining walls, and erecting cranes would be necessary to build 

24 the larger plant structures. 

25 3.3.1.12 Concrete Batch Plant 

26 The temporary concrete batch plant would involve limited erection on a cleared, graded area. 

27 3.3.1.13 Powerblock and Cooling Towers 

28 The powerblock consist of the reactor building, the radioactive waste building, the turbine 

29 building, service buildings, and associated structures. Deep excavation and extensive fill 

30 placement and large-scale fabrication and erection activities would be involved in building the 

31 powerblock facilities. An onsite concrete batch plant would fabricate concrete for numerous 

32 pours. Various components would be hauled to the site via barge and road. Many of these 

33 structures would be erected using components delivered as large modules and installed via 

34 crane. 
Site Layout and Plant Description 

Draft NUREG-1941 3-22 August 2010 

1 3.3.1.14 Pipelines 

2 The pipelines connecting the intake structure to the cooling-tower basins would run north from 

3 the intake structure along the heavy-haul road. The blowdown lines would run south from the 

4 cooling-tower basins to the CFBC in the same corridor as the intake pipelines. The pipeline 

5 would run west on the north side of the Inglis Lock bypass channel and cross the bypass 

6 channel and CFBC just north of the CREC. The pipeline would then follow an existing 

7 transmission-line corridor into the CREC and to the existing CREC discharge canal as shown in 

8 Figure 3-7. 

9 The intake and discharge pipelines would generally be buried to a minimum depth of 5 ft. 

10 Building the pipelines would require the clearing of land along the pipeline corridor and shallow 

11 excavation (trenching) to allow installation of the pipeline. The discharge pipelines would cross 

12 over the Inglis Lock bypass channel on a 33-ft-wide utility bridge. The pipelines would pass 

13 under the CFBC (PEF 2009d). 

14 A trench would be excavated in the bottom of the canal to allow the pipeline to be placed below 

15 the existing canal bottom. The canal bottom contour would be restored once the pipeline is 

16 installed. No long-term changes to the channel configuration of the CFBC would occur and, 

17 once installation is completed, navigation through the canal should not be affected (PEF 2009a). 

18 3.3.1.15 Miscellaneous Buildings 

19 Shallow excavation for foundations would be required prior to fabrication and erection of 

20 miscellaneous buildings. 

21 3.3.1.16 Parking 

22 Parking areas would be graded and paved. 

23 3.3.1.17 Laydown Areas 

24 Laydown areas would be graded relatively level and covered with crushed stone or gravel. 

25 Normally only limited vegetation is allowed in laydown areas. These laydown areas would affect 

26 approximately 120 ac (PEF 2009a). 

27 3.3.1.18 Switchyard 

28 Building the proposed 500-kV switchyard would require clearing and grading 48.2 ac of land 

29 (PEF 2009a). The switchyard and other areas around the main plant building would be graded 

30 and filled to raise the elevation of the land surface to 47 ft NAVD88 (PEF 2009a). 
Site Layout and Plant Description 

August 2010 3-23 Draft NUREG-1941 

1 3.3.2 Summary of Resource Commitments Due to Building Activities 

2 Table 3-2 lists the significant resource commitments for construction and preconstruction. The 

3 values in the table combined with the affected environment described in Chapter 2 provide the 

4 basis for the impacts assessed in Chapter 4. These values were stated in the ER (PEF 2009a), 

5 and the review team determined that the values are not unreasonable. 

6 Table 3-2. Summary of Resource Commitments Associated with Construction and 

7 Preconstruction of Proposed Units 1 and 2 

Resource Area Value Description Reference

All Resource Areas 60 months 

(5 years) per unit, 

72 months 

(6 years) total 

Duration of construction and 

preconstruction activities (18 months for 

preparation, 42 months for building per 

unit, expected to be staggered 1 yr 

between units) 

(PEF 2009a) 

Socioeconomics, 

Transportation, Air Quality 

3300 workers Peak workforce occurring in the third 

quarter of the third year of building 

(PEF 2009a) 

Land Use, Terrestrial 

Ecology, Historic and 

Cultural Resources (Site 

and Vicinity) 

777 ac Disturbed area footprint: 

627 ac permanently disturbed; 

150 ac temporarily disturbed 

(PEF 2009f)

Land Use, Terrestrial 

Ecology, Historic and 

Cultural Resources 

180 mia

1000 to 2640 ft 

Length of new transmission-line corridors 

Width of new transmission-line corridors 

(PEF 2008) 

Hydrology – Groundwater 275,000 gpd 

550,000 gpd 

Average groundwater withdrawal rate 

Maximum groundwater withdrawal rate 

(PEF 2009a) 

 75 ftb Excavation depth to which dewatering 

would be required (below land surface at 

50 ft NAVD88) 

(PEF 2009a) 

Hydrology – Surface 

Water, Aquatic Ecology, 

Terrestrial Ecology, Land 

Use 

83,044 yd3

23,260 yd3

Volume of material excavated or dredged 

to create the barge-unloading facility 

Volume of dredged material requiring 

disposal 

(PEF 2009a) 

Terrestrial Ecology, 

Socioeconomics, 

Nonradiological Health 

104 dB 

74 dB 

Peak noise level 50 ft from activity 

Noise level 1500 ft from activity 

(PEF 2009a) 

(a) Rounded from 83 mi of 500 kV corridor and 95 mi of 230 kV corridor (see Section 2.2.2) 

(b) Dewatering depth is 100 ft 
Site Layout and Plant Description 

Draft NUREG-1941 3-24 August 2010 

1 3.4 Operational Activities 

2 The operational activities considered in the review team’s environmental review are those 

3 associated with structures that interface with the environment, as described in Section 3.2.2. 

4 Examples of operational activities are withdrawing water for the cooling system, discharging 

5 blowdown water and sanitary effluent, and discharging waste heat to the atmosphere. Safety 

6 activities within the plant are discussed by the applicant in the FSAR portion of its application 

7 (PEF 2009b). The results of NRC’s safety review will be documented in its Safety Evaluation 

8 Report. 

9 The following sections describe the operational activities, including operational modes 

10 (Section 3.4.1), plant-environment interfaces during operations (Section 3.4.2), the radioactive 

11 and nonradioactive waste-management systems (Sections 3.4.3 and 3.4.4), and a summary of 

12 the resource commitments likely to be experienced during operations (Section 3.4.5). 

13 3.4.1 Description of Operational Modes 

14 The operational modes for proposed Units 1 and 2 considered in the assessment of operational 

15 impacts on the environment (Chapter 5) are normal operating conditions and emergency 

16 shutdown conditions. These are the nominal conditions under which maximum water 

17 withdrawal, heat dissipation, and effluent discharges occur. Cooldown, refueling, and accidents 

18 are alternate modes to normal plant operation during which water intake, cooling-tower 

19 evaporation, water discharge, and radioactive releases may change from nominal conditions. 

20 3.4.2 Plant-Environment Interfaces During Operation 

21 This section describes the operational activities related to structures with an interface to the 

22 environment. 

23 3.4.2.1 Circulating-Water System – Intakes, Discharges, and Cooling Towers 

24 Waste heat is a byproduct of normal power generation at a nuclear power plant. The proposed 

25 LNP Units 1 and 2 would use closed-cycle wet-cooling systems to transfer heat from their main 

26 condenser to the multicell mechanical draft cooling towers. During normal plant operation, the 

CWS for each unit would dissipate up to 7.628 × 109 27 Btu/hr of waste heat to the atmosphere 

and 1.23 × 108 28 Btu/hr of waste heat via liquid discharges (PEF 2009a). 

29 Excess heat in the cooling water would be transferred to the atmosphere by evaporative and 

30 conductive cooling in the cooling tower. In addition to evaporative losses, a small percentage of 

31 water would also be lost in the form of droplets (drift) from the cooling tower. The water that 

32 does not evaporate or drift from the tower would be routed back to the cooling-tower basin. 
Site Layout and Plant Description 

August 2010 3-25 Draft NUREG-1941 

1 Evaporation of water from the cooling towers increases the concentration of dissolved solids in 

2 the cooling-water system. To limit the concentration of dissolved solids, a portion of the 

3 circulating water would be continuously removed and replaced with makeup water from the 

4 CFBC. The water that is removed is called blowdown water. The blowdown water from each 

5 cooling tower would travel through the blowdown pipeline to be discharged to the CREC 

6 discharge canal and the Gulf of Mexico. PEF plans to operate the cooling-water system cooling 

7 tower to maintain a total dissolved solids concentration in the blowdown water between 1.5 to 

8 2 times the influent concentration (commonly referred to as cycles of concentration) 

9 (PEF 2009a). 

10 Key elements of the cooling-water system are shown in the water-balance diagram for an 

11 AP1000 shown in Figure 3-8. 

12 PEF provided the following bounding water fluxes for the combined cooling-water system for 

13 both units: 

14 • The maximum makeup-water flow rate would be 84,780 gpm. 

15 • The maximum consumptive water-use rate (evaporation and drift) would be 28,260 gpm. 

16 • The maximum blowdown rate would be 61,065 gpm (PEF 2009e). 

17 Intake Structure 

18 The canal intake structure contains three pumps for each AP1000 unit. Two of these pumps 

19 would withdraw water from the CFBC whenever the cooling-water system requires makeup 

20 water (PEF 2009a). The third pump would be maintained in standby mode and would start if 

21 one of the operating pumps ceases to function or is shut down for maintenance. Water entering 

22 the intake structure would pass through vertical trash bars and traveling screens to remove 

23 debris before reaching the pumps. The traveling screens would have mesh openings of 3/8 in. 

24 (PEF 2009a). The discharge from these pumps would be strained by an automatic strainer 

25 before discharging to the cooling-tower basins. Strainers would be backwashed to remove 

26 debris and send it back to the CFBC. 

27 Normal operations for two AP1000 units would require withdrawal of 84,780 gpm from the 

28 CFBC to supply makeup water to the cooling-tower basins (PEF 2009a). Because these units 

29 would normally run at 100-percent power, this would also be the maximum withdrawal rate 

30 needed for plant operations. Consistent with EPA Phase 1 regulations for intake design, PEF 

31 has stated that the proposed intake structure would have a design through-screen velocity of 

32 less than 0.5 fps (PEF 2009a). 
Draft NUREG-1941 3-26 August 2010 

Site Layout and Plant Description 

1 

Figure 3-8. LNP Units 1 and 2 Water-Balance Diagram (PEF 2009a) 2 
Site Layout and Plant Description 

August 2010 3-27 Draft NUREG-1941 

1 Discharge Structure 

2 Most of the maximum discharge to the CREC discussed above would come from the cooling3 water system for the two units proposed for the LNP site. Normal operation of two AP1000 units 

4 would result in 57,923 gpm being discharged from the cooling system to the discharge line as 

5 blowdown water (PEF 2009a, e). Maximum discharge from the cooling system to the discharge 

6 line as blowdown would be 61,065 gpm. The difference between normal and maximum 

7 blowdown rates is primarily a result of intermittent discharge of stormwater to the cooling tower 

8 basins during periods when infiltration through the stormwater infiltration ponds is inadequate to 

9 dispose of stormwater runoff (PEF 2009a, e). All discharges would be sent to the CREC 

10 discharge canal, where they would be mixed with the discharges from the CREC and 

11 discharged to the Gulf of Mexico. 

12 Cooling Tower 

13 The cooling-water system cooling towers provide a mechanism for removing waste heat from 

14 the main condensers. Water would be circulated from the cooling-tower basin through the 

15 condensers by three pumps that would provide a flow rate of 177,000 gpm each. Because this 

16 flow does not interface directly with the environment, it is not shown on Figure 3.8. Once the 

17 water passes through the condensers it would return to the cooling towers where it would be 

18 cooled by evaporative and conductive cooling. Heat removed by these processes would pass 

19 to the atmosphere, and the cooled water would return to the cooling-tower basin. A portion of 

20 the water in the cooling-tower basins would be drawn off to eliminate contaminants that build up 

21 as a result of the evaporation process and would be discharged as blowdown. Less than two 

22 percent of the waste heat would be removed from the cooling system with the blowdown water. 

23 The blowdown temperature is expected to be 89.1°F at the cooling-tower design wet-bulb 

24 temperature of 83°F (PEF 2009a). 

25 3.4.2.2 Service-Water System 

26 The service-water system would supply cooling water to remove heat from the nonsafety-related 

27 component cooling-water system heat exchangers in the turbine building (PEF 2009a). Cooling 

28 for the service-water system would occur through a closed-cycle system using heat exchangers 

29 and a two-cell mechanical draft cooling tower with a divided basin. The basins would be 

30 supplied with makeup water from the raw-water system, which draws the makeup water from 

31 groundwater wells. 

32 Within the service-water system tower, excess heat in the cooling water would be transferred to 

33 the atmosphere via evaporative and conductive cooling. The evaporation process increases the 

34 concentration of dissolved solids in the cooling water. To limit the concentration of dissolved 

35 solids, a portion of the water would be continuously discharged from the system as blowdown 
Site Layout and Plant Description 

Draft NUREG-1941 3-28 August 2010 

1 water, which would be routed to the cooling-water system retention basins. PEF provided the 

2 following bounding water flows for the service-water system for both units: 

3 • The maximum makeup-water flow rate would be 1662 gpm. 

4 • The maximum consumptive water-use rate (evaporation and drift) would be 1248 gpm. 

5 • The maximum blowdown rate would be 410 gpm (PEF 2009e). 

6 3.4.2.3 Water-Treatment Systems 

7 Water taken into the various systems at the proposed LNP would require treatment to meet the 

8 requirements of the end use. Water-treatment systems would be in place for 

9 • circulating water 

10 • service water 

11 • potable water 

12 • demineralized water. 

13 Water chemistry for the circulating-water system would be maintained by the turbine island 

14 chemical-feed system. This system would inject chemicals into the circulating water 

15 downstream of the circulating-water system pumps to maintain a noncorrosive, nonscale16 forming condition and limit the formation of biological film within the system that could reduce 

17 the heat-transfer rate in the condenser and the heat exchangers of the circulating-water system 

18 (PEF 2009a). The chemicals used are generally classified as biocides, algaecides, pH 

19 adjusters, corrosion inhibitors, scale inhibitors, and silt dispersants. The pH adjuster, corrosion 

20 inhibitor, scale inhibitor, and dispersant chemicals would be metered into the system 

21 continuously or as required to maintain proper concentrations. The biocide application 

22 frequency would vary with seasons. The algaecide would be applied, as necessary, to control 

23 algae formation on the cooling tower. The chemicals used in the circulating-water system and 

24 the concentrations in the blowdown water are discussed in Section 3.4.4.2 under nonradioactive 

25 waste streams. 

26 The service-water system chemistry would be controlled by the turbine island chemical-feed 

27 system. The system would inject chemicals into service-water pump discharge piping located in 

28 the turbine building to maintain a noncorrosive, nonscale-forming condition and limit the 

29 formation of biological film. Here again, the chemicals used are generally classified as biocides, 

30 algaecides, pH adjustors, corrosion inhibitors, scale inhibitors, and silt dispersants. The pH 

31 adjustor, corrosion inhibitor, scale inhibitor, and dispersant chemicals would be metered into the 

32 system continuously or as required to maintain the proper concentrations. Sodium hypochlorite 

33 would be used as the biocide and would control the microorganisms that cause fouling. The 

34 biocide application frequency would vary with seasons. Algae formation on the cooling tower 
Site Layout and Plant Description 

August 2010 3-29 Draft NUREG-1941 

1 would be controlled by application of an algaecide when necessary. The chemicals that could 

2 be used and their concentrations in the service-water system are discussed in more detail in 

3 Section 3.4.4.2 under nonradioactive waste streams (PEF 2009a). 

4 The potable-water system would be designed to furnish water for domestic use and human 

5 consumption. It would be treated to comply with the following standards: 

6 • bacteriological and chemical quality requirements as referenced in the “National Primary 

7 Drinking Water Standards,” 40 CFR Part 141 

8 • the distribution of water by the system in compliance with 29 CFR Part 1910, Occupational 

9 Safety and Health Standards. 

10 The demineralized water-treatment system takes water from the raw-water system and 

11 processes it to remove ionic impurities. The station is expected to use reverse osmosis to 

12 demineralize water (PEF 2009a). 

13 3.4.2.4 Landscape and Drainage 

14 The landscape and drainage would determine the path that precipitation takes on the land 

15 surface. In addition, the land cover, soil moisture content, and soil type would determine the 

16 rate of recharge to the subsurface. The three ponds to be constructed for stormwater retention 

17 and infiltration are designed to drain through groundwater infiltration within 5 days. Any excess 

18 stormwater runoff that is sent to the ponds would be pumped to the cooling-tower blowdown 

19 basin and, if necessary, discharged with blowdown. The ponds are designed to retain a 

20 25-year, 24-hour rainfall event. Larger storm events (100-year rainfall) would be drained out of 

21 the ponds through broad-crested weir emergency spillways provided in each of the ponds. 

22 Excess water from these maximum rainfall events would move from the spillways through long 

23 spreader swales to send runoff to the surrounding wetland as sheet flow to prevent erosion. 

24 The ponds would be constructed to maintain a minimum freeboard of 2 ft above the spillway 

25 elevation (PEF 2009a). 

26 3.4.2.5 Water-Supply Wells 

27 The four onsite water-supply wells would be used to supply general plant operations including 

28 makeup water for the service-water system, potable-water supply, raw water to the 

29 demineralizer, fire protection, and media filter backwash (PEF 2009a). PEF has estimated that 

30 plant operations would require an annual average total withdrawal of 1.58 Mgd of groundwater, 

31 and a potential maximum daily withdrawal of 5.8 Mgd (PEF 2009d). 

32 3.4.2.6 Diesel Generators 

33 Diesel generators would be installed on the site to provide a backup source of power to selected 

34 nonsafety electrical loads. Two 4000-kW standby diesel generators and two 35-kW auxiliary 
Site Layout and Plant Description 

Draft NUREG-1941 3-30 August 2010 

1 generators would be installed to support each unit at the LNP site (PEF 2009a). Emissions from 

2 these generators include particulates, sulfur oxides, carbon monoxide, hydrocarbons, nitrogen 

3 oxides, and carbon dioxide (PEF 2009a). Combustion emissions from the generators would be 

4 released to the atmosphere only during emergency operations and periodic testing. The diesel 

5 generators would be located in a diesel-generator building (PEF 2009a). 

6 3.4.2.7 Transmission-Line Maintenance 

7 Maintenance performed on the transmission lines for proposed LNP Units 1 and 2 would include 

8 a combination of aerial reconnaissance with helicopters and ground crews with trucks to 

9 conduct inspections of the corridors. The four 500-kV power transmission lines would pass 

10 through several types of undeveloped lands, ranging from upland areas to wetlands. Corridors 

11 passing through agricultural lands typically create only minimal disturbances because the land 

12 in the corridor can often remain productive. When corridors pass through wetland areas, 

13 restricted clearing and maintenance techniques would be used to reduce the total area of land 

14 disturbed. Annual inspection and maintenance activities within the corridors would be primarily 

15 preventive measures by mechanical, chemical, and manual methods. This includes clearing 

16 vegetative growth and removing dead trees along the edges of the corridor (PEF 2009a). 

17 In its Site Certification Application (PEF 2008), PEF summarized other maintenance activities, 

18 including the following: 

19 • mowing, pruning, and herbicide treatments 

20 • encouraging the growth of low-growing woody and herbaceous vegetation that will not exceed 

21 12 ft in height at maturity 

22 • taking care not to cause unnecessary damage to vegetation in environmentally sensitive 

23 areas 

24 • during line maintenance, alternatively girdling or selectively treating with herbicides any 

25 vegetation that may be cut during clearing of the corridor 

26 • allowing girdled or treated vegetation to remain standing to provide habitat and food sources 

27 for wildlife 

28 • basing the exact manner in which maintenance would be performed on the location, type of 

29 terrain, and surrounding environment 

30 • addressing each area of a corridor based on site-specific vegetation and habitat 

31 • working with public land managers to develop a management plan for the corridor where the 

32 500-kV transmission-line corridor from the proposed LNP site to the proposed Central Florida 

33 South substation crosses public land. 
Site Layout and Plant Description 

August 2010 3-31 Draft NUREG-1941 

1 To perform transmission-line maintenance, PEF uses various types of equipment, including 

2 helicopters, bucket trucks, cranes, semi-trucks, and support vehicles. Typical line-maintenance 

3 operations may include insulator replacements, conductor repairs, shield wire repairs, 

4 grounding, and other activities associated with structures, conductors, and foundations. Once 

5 onsite, the PEF crews would establish a safe working area and perform the required repair. 

6 Maintenance in environmentally sensitive areas, where access and fill pads do not exist, may 

7 require temporary matting to minimize damage to these areas during repairs (PEF 2008). 

8 3.4.3 Radioactive Waste-Management Systems 

9 Liquid, gaseous, and solid radioactive waste-management systems would be used to collect 

10 and treat the radioactive materials produced as byproducts of operating proposed LNP Units 1 

11 and 2. These systems would process radioactive liquid and gaseous effluents to maintain 

12 releases within regulatory limits and to levels as low as reasonably achievable (ALARA) before 

13 releasing them to the environment. Waste-processing systems would be designed to meet the 

14 design objectives of 10 CFR Part 50, Appendix I (“Numerical Guides for Design Objectives and 

15 Limiting Conditions for Operation to Meet the Criterion ‘As Low as is Reasonably Achievable’ for 

16 Radioactive Material in Light-Water-Cooled Nuclear Power Reactor Effluents”). Radioactive 

17 material in the reactor coolant would be the primary source of gaseous, liquid, and solid 

18 radioactive wastes in the AP1000 reactors. Radioactive fission products build up within the fuel 

19 as a consequence of the fission process. These fission products would be contained in the 

20 sealed fuel rods, but small quantities could escape the fuel rods into the reactor coolant. 

21 Neutron activation of the primary coolant system would also add radionuclides to the coolant. 

22 Prior to fuel load, PEF would develop an Offsite Dose Calculation Manual (ODCM) describing 

23 the methods and parameters used for calculating offsite radiological doses from liquid and 

24 gaseous effluents. The ODCM would also describe the methodology for calculating gaseous 

25 and liquid monitoring alarm/trip set points for release of effluents from LNP, and would specify 

26 the operational limits for releasing liquid and gaseous effluents to ensure compliance with NRC 

27 regulations. 

28 The systems used to process liquid, gaseous, and solid wastes are described in the following 

29 sections. A more detailed description of these systems for the proposed LNP Units can be 

30 found in Chapter 11 of the AP1000 Design Control Document (Westinghouse 2008). Solid 

31 radioactive wastes produced from operating LNP Units 1 and 2 would be both dry and wet 

32 solids. 

33 3.4.3.1 Liquid Radioactive Waste-Management 

34 The liquid radioactive waste-management system is designed to control, collect, segregate, 

35 process, handle, store, and dispose of liquid radioactive waste generated as the result of normal 

36 operation and anticipated operational occurrences, including refueling operations. The liquid 
Site Layout and Plant Description 

Draft NUREG-1941 3-32 August 2010 

1 radioactive waste-management system is managed using several process trains consisting of 

2 tanks, pumps, ion exchangers, filters, and radiation monitors. Normal operations include 

3 processing of (1) reactor coolant system wastes, (2) floor drains and other wastes with 

4 potentially high suspended solid contents, (3) detergent wastes, and (4) chemical wastes. The 

5 discharge would be monitored and administratively controlled to confirm that it meets 

6 requirements of 10 CFR Part 20, Appendix B, Table 2 (Westinghouse 2008). 

7 The liquid radioactive waste-management system would process and dispose of liquids 

8 containing radioactive material from the steam generator blowdown-processing system (DCD 

9 Section 10.4.8); radioactive waste drain system (DCD Section 9.3.5); and liquid radioactive 

10 waste system (DCD Section 11.2) (Westinghouse 2008). The liquid waste would be discharged 

11 from the monitor tank in a batch operation, and the discharge flow rate would be restricted as 

12 necessary to maintain an acceptable concentration when diluted by the circulating-water 

13 discharge flow. These features and procedures are designed to preclude uncontrolled releases 

14 of radioactive material (PEF 2009a). Discharges from the proposed LNP would be transported 

15 in two blowdown pipelines (one for each unit) from the LNP to the CREC discharge canal and 

16 into the Gulf of Mexico. Calculated dose to the maximally exposed individual (MEI) from 

17 gaseous effluents is evaluated in Section 5.9.1. 

18 3.4.3.2 Gaseous Radioactive Waste-Management 

19 The gaseous radioactive waste-management system functions to collect, process, and 

20 discharge radioactive or hydrogen-bearing gaseous wastes. The system is a once-through, 

21 ambient-temperature, activated-carbon delay system (Westinghouse 2008). Radioactive 

22 isotopes of iodine and the noble gases xenon and krypton are created as fission products within 

23 the fuel rods during operation. Some of these gases escape to the reactor coolant system 

24 through cladding defects. Some of these gases are released to the environment through the 

25 gaseous radioactive waste-management system or plant ventilation. In addition, various 

26 gaseous activation products, such as argon-41, are formed directly in the reactor containment 

27 during operation. The gaseous radioactive waste-management system is typically active only 

28 when monitored gaseous concentrations reach a given threshold. Waste gas flows through a 

29 guard bed that removes iodine, oxidizing chemicals, and moisture. From the guard bed it flows 

30 through two delay beds containing activated carbon, which dynamically adsorbs and desorbs 

31 the gases, delaying them long enough for significant radioactive decay to occur. The gaseous 

32 system can only delay noble gases, not collect them. If noble gases monitored in the coolant 

33 reach a threshold value, then the reactor coolant is diverted to the liquid radioactive waste34 management system where the noble gases can be collected using the degasifier. 

35 Radioactive gaseous effluents from the system described above are discharged through the 

36 plant vent, which is on the side of the containment building about 183 ft above grade level 

37 (Westinghouse 2008). Releases of radioactive gaseous effluents would also occur due to 

38 venting of the containment, auxiliary building, turbine building, condenser air removal system, 
Site Layout and Plant Description 

August 2010 3-33 Draft NUREG-1941 

1 and gaseous radioactive waste system discharges. These releases would be ongoing and 

2 there would be no holdup in the gaseous waste-management system and no batching of 

3 releases, as would be the case for the liquid effluents. At the proposed LNP, PEF would control 

4 and monitor releases of gaseous effluents from the plant so that the regulatory limits specified in 

5 10 CFR Part 20 and 10 CFR Part 50, Appendix I, would not be exceeded (see PEF’s ER 

6 Section 3.5.2, Tables 3.5-4 and 3.5-5) (PEF 2009a). Calculated dose to the MEI from gaseous 

7 effluents is evaluated in Section 5.9.1. 

8 3.4.3.3 Solid Radioactive Waste-Management 

9 The solid radioactive waste-management system functions to treat, temporarily store, package, 

10 and dispose of dry or wet solids. Solid radioactive wastes include spent ion-exchange resins, 

11 deep-bed filtration media, spent filter cartridges, dry active wastes, and mixed wastes. The 

12 system has a 60-year design objective and is designed to handle both normal and anticipated 

13 operational occurrences. The packaged wastes would be temporarily stored in the auxiliary and 

14 radwaste buildings prior to being shipped to a licensed disposal facility. The AP1000 solid 

15 radioactive waste-management system releases no gaseous or liquid effluent directly to the 

16 environment. This system discharges effluent through the liquid and gaseous waste17 management systems. 

18 The maximum total volume of shipped (wet and dry) solid radioactive waste would be 

11,434 ft3 19 /yr from LNP Units 1 and 2 (PEF 2009a) with an expected total activity of radioactive 

material shipped from both units of 3.52 × 103 20 Ci/yr (PEF 2009a). 

21 3.4.4 Nonradioactive Waste-Management Systems 

22 The following sections describe the nonradioactive waste-management systems proposed for 

23 the LNP site, including systems for solid waste, liquid waste, gaseous waste, hazardous waste, 

24 and mixed waste. 

25 3.4.4.1 Solid-Waste Management 

26 The expected nonradioactive solid-waste streams during operational activities include water27 treatment wastes, laboratory wastes, trash, effluents from the sanitary sewage-treatment 

28 system, and CWIS debris. 

29 Solid waste generated during operation would be segregated and recycled to the extent 

30 practicable, with the balance disposed of in an offsite permitted landfill (PEF 2009a). PEF 

31 would institute a waste-minimization program during operation to promote pollution prevention, 

32 recycling, and reuse. Typical solid nonradioactive and nonhazardous waste generated during 

33 operation may include office paper, aluminum cans, laboratory waste, glass, and metals. Waste 

34 materials would be collected from several onsite locations and deposited in dumpsters located 
Site Layout and Plant Description 

Draft NUREG-1941 3-34 August 2010 

1 throughout the site. Recyclable materials would be collected and recycled by a commercial 

2 recycler. The remaining solid wastes would be collected by a licensed waste hauler and 

3 disposed of in a municipal landfill. None of these solid wastes would be burned or disposed of 

4 onsite. PEF estimates that during operation, the LNP would generate an average of 1617 tons 

5 of solid waste annually (PEF 2008). 

6 The intake structure along the CFBC would have trash racks, traveling screens, and self7 cleaning strainers. Debris collected from the trash racks and screens would be disposed of in 

8 local landfills. Water used to wash the screens or to backwash the strainers would be taken 

9 from and returned to the canal (PEF 2009a). 

10 Aquifer well water for the raw-water system would pass through a self-cleaning strainer and a 

11 media filter to remove particulates. Water used to backwash the strainer and media filter would 

12 be directed to the settling basin and subsequently discharged to the cooling-water system 

13 blowdown pipe leading to the CREC discharge canal (PEF 2009a). 

14 The reverse osmosis filters in the reverse osmosis system for demineralized water-treatment 

15 would need to be replaced periodically. The spent filters would be disposed of in accordance 

16 with applicable industrial solid waste regulations (PEF 2009a). 

17 3.4.4.2 Liquid-Waste Management 

18 The expected nonradioactive liquid waste streams include cooling-water blowdown, auxiliary19 boiler blowdown, water-treatment wastes, discharge from floor and equipment drains, effluents 

20 from the sanitary sewage-treatment system, and stormwater runoff. 

21 The AP1000 plant design consolidates most of the nonradioactive liquid effluent streams into a 

22 single combined discharge. All of these effluent streams would combine into a single stream 

23 and discharge via the CREC discharge canal into the Gulf of Mexico (PEF 2009a). 

24 Chemicals that would likely be added to the plant cooling-water system, service-water system, 

25 demineralized water-treatment system, and blowdown system water streams include a biocide 

26 (sodium hypochlorite), an algaecide (N-alkyl dimethyl benzyl ammonium chloride or similar 

27 quaternary amine, pH adjusters (sulfuric acid, ammonium hydroxide), a corrosion inhibitor 

28 (ortho-polyphosphate), a silt dispersant (polyacrylate), an antiscalant (phosphonate), a 

29 coagulant (polyaluminum chloride), and an oxygen scavenger (hydrazine). Chemicals used to 

30 treat the cooling water would be mostly consumed or broken down prior to discharge (PEF 

31 2009a). 

32 Stormwater runoff from paved areas, roof drains, and the main plant area would flow over land 

33 to drainage channels leading to stormwater-retention ponds where the collected stormwater 

34 would percolate into the soil. Fire and supply test water would also be directed to the ponds. 
Site Layout and Plant Description 

August 2010 3-35 Draft NUREG-1941 

1 Any excess stormwater from large precipitation events would be pumped from the ponds to the 

2 cooling-tower blowdown basin. Combined discharge from the CREC discharge canal outfall 

3 structure would be monitored for flow, pH, color, odor, clarity, floating solids, total suspended 

4 solids, foam, oil and grease, and other obvious indicators of stormwater pollution. 

5 In accordance with Florida law (Fla. Admin. Code 62-620), any discharges during operation 

6 would need to comply with all applicable provisions of National Pollutant Discharge Elimination 

7 System (NPDES) Permit No. FL0633275-001-IW1S/NP (FDEP 2010a) upon final issuance, as 

8 well as any subsequent modifications, amendments, and/or renewals. It is anticipated that the 

9 permitted discharge concentrations for the proposed LNP would be similar to those specified in 

10 the CREC’s NPDES Permit No. FL0000159 (FDEP 2010b). The expected levels of chemicals 

11 in the discharge are summarized in Table 3-3 (PEF 2008). 

12 Table 3-3. Characterization of Potential Pollutants in the LNP Discharge to the CREC 

13 Discharge Canal

System Chemical Type Treatment Expected Levels in Discharge

CWS Biocide/sodium hypochlorite Dechlorination prior 

to discharge 

 0.01 mg/L (negligible) 

CWS Algaecide/quaternary amine 

(methyl benzyl ammonium 

chloride or dimethyl benzyl 

ammonium chloride) 

Dechlorination prior 

to discharge 

 0.01 mg/L (negligible) 

CWS pH adjustment/sulfuric acid None pH in range 

CWS Corrosion 

inhibitor/orthopolyphosphate 

None Small amount of total phosphorus (TP) 

CWS Silt dispersant/polyacrylate None Flocculant, inert solids <10 m 

SWS Biocide/sodium hypochlorite Wastewater retention 

basin, dechlorination 

prior to discharge 

 0.01 mg/L (negligible) 

SWS Algaecide/quaternary amine 

(ammonium chloride) 

Wastewater retention 

basin, dechlorination 

prior to discharge 

 0.01 mg/L (negligible) 

SWS pH adjustment/sulfuric acid Wastewater retention 

basin 

pH in range 

SWS Corrosion inhibitor/orthopolyphosphate Wastewater retention 

basin 

Small amount of TP 

SWS Silt dispersant/polyacrylate Wastewater retention 

basin 

Flocculant, inert solids <10 m 

SWS Antiscalant/phosphonate Wastewater retention 

basin 

None due to infrequent use and small 

discharge volume. 

DTS pH adjustment/sulfuric acid Wastewater retention 

basin 

pH in range 

DTS Coagulant/polyaluminum 

chloride 

Offsite disposal of 

solids 

Inert particles <10 m 

 
Site Layout and Plant Description 

Draft NUREG-1941 3-36 August 2010 

1 Table 3-3. (contd) 

System Chemical Type Treatment Expected Levels in Discharge

DTS Antiscalant/polyacrylate Wastewater Retention 

Basin 

Flocculant, inert solids <10 m 

WWS Carbonaceous biochemical 

oxygen demand, 5-day 

Activated sludge <20 mg/L annual avg.; <30 mg/L monthly avg.; 

<60 mg/L daily maximum 

WWS Total suspended solids Activated sludge <30 mg/L avg. daily over 30 days; <100 mg/L 

daily maximum 

WWS Nutrients Activated sludge Typical domestic wastewater levels: nitrogen 

10 to 20 mg/L; phosphorus 5 to 10 mg/L 

WWS Sludge Activated sludge Contract removal of solids 

Storm Total suspended solids Settling in wet ponds Will meet State treatment criteria prior to reuse 

in CWS. Typical range of runoff quality is 10 to 

30 mg/L post-treatment. 

Storm Carbonaceous biochemical 

oxygen demand, 5-day 

Settling in wet ponds Will meet State treatment criteria prior to reuse 

in CWS. Typical range of runoff quality is 2 to 

10 mg/L post-treatment. 

Storm Nutrients Settling in wet ponds Will meet State treatment criteria prior to reuse 

in CWS. Typical ranges of runoff quality are 

total nitrogen (TN) 1 to 2 mg/L and TP 0.1 to 

0.3 mg/L post-treatment. 

BDS Oxygen scavenging/ 

hydrazine 

Secondary treatment Reduces to ammonia, reduced further by 

WWS. Negligible addition to WWS and 

infrequent. 

BDS pH adjustment/ammonium 

hydroxide 

Secondary treatment Reduces to ammonia, reduced further by 

WWS. Negligible addition to WWS and 

infrequent. 

Source: PEF 2008 

Storm = stormwater runoff from the power-generation area 

2 The operational discharge from proposed LNP Units 1 and 2 would be combined with the 

3 current CREC discharge in the CREC discharge canal and would equal approximately 4.9 

4 percent of the combined discharge. The cooling-water system would use closed-cycle cooling, 

5 with a chemical concentration factor between 1.5 and 2.0 (PEF 2009a). Therefore, due 

6 primarily to evaporative losses, the concentration of any naturally occurring dissolved solids in 

7 the intake seawater would be between 50 and 100 percent higher in the discharge water. 

8 Suspended solids, with the exception of material captured on the intake screens or self-cleaning 

9 strainers, would pass through the cooling-water system cooling tower or cooling-water system 

10 basin and be discharged to the CREC discharge canal. The concentration of suspended solids 

11 would be higher in the discharge water than in the intake seawater. Although the service-water 

12 system has a concentration factor between 2 and 4, it would not contribute to a significant 

13 increase in the average concentration of natural materials because the service-water system 

14 would use filtered groundwater and would contribute less than 1 percent of the combined 

15 cooling-water system and service-water system discharge flow. Some temporal variation would 

16 occur due to intermittent backwash and blowdown operations. 
Site Layout and Plant Description 

August 2010 3-37 Draft NUREG-1941 

1 During LNP operation, one of the two sewage-treatment plants would support up to 800 people 

2 per day (40,000 gpd capacity) using the extended aeration process (PEF 2009a). In the 

3 extended aeration process, activated sludge is added to the wastewater influent, which is then 

4 held in an aeration tank for an extended time. This process produces a minimal amount of 

5 sludge, which would be removed as needed and disposed of by a licensed sanitation contractor 

6 (PEF 2008). 

7 Sanitary wastewater would be treated to the levels indicated in Table 3-3 before being 

8 combined with the CWS blowdown for discharge to the CREC discharge canal. During 

9 operation, the expected maximum flow rate from the sanitary wastewater-treatment system of 

10 69 gpm represents about 0.1 percent of the total LNP discharge. In the LNP NPDES 

11 application, Florida Wastewater Application Form 2CS, PEF indicates that fecal coliform would 

12 be absent from the combined LNP discharge (PEF 2008). 

13 3.4.4.3 Gaseous-Waste Management 

14 Gaseous emissions would be produced by the combustion of diesel fuel in the diesel engines 

15 that would power the two 2000-gpm fire pumps, the four 4000-kW standby generators, and the 

16 four 35-kW auxiliary generators. Based on four operating hours per month for each engine, the 

17 estimated annual emissions from these 10 engines are 2337 lb of particulates, 119 lb of sulfur 

18 oxides, 7161 lb of carbon monoxide, 2713 lb of hydrocarbons, 33,243 lb of nitrous oxides, and 

19 1,236,250 lb of carbon dioxide (PEF 2009a). These emissions would be subject to the 

20 requirements of the Prevention of Significant Deterioration Permit, when issued. 

21 Each of these diesel engines would have an associated fuel tank. The four tanks for the 

22 4000-kW generators would each hold 85,000 gallons, the four tanks for the 35-kW generators 

23 would each hold 650 gallons, and the two tanks for the fire pumps would each hold 240 gallons. 

24 Total estimated hydrocarbon emissions from these tanks is 72 lb/yr due to volatilization of the 

25 diesel fuel (PEF 2009a). PEF also plans to construct and operate a fueling station in the motor 

26 pool area, but details are not yet available (PEF 2009c). 

27 Small amounts of volatile organic compounds (VOCs) would also be generated from the use of 

28 common building maintenance materials such as paints, adhesives, and caulk; from mechanical 

29 maintenance materials such as oils and solvents; and periodically from activities such as 

30 asphalt resealing. Many of these materials are increasingly available in water-based or low 

31 VOC formulations, minimizing the magnitude of future VOC emissions. 

32 3.4.4.4 Hazardous- and Mixed-Waste Management 

33 The LNP is expected to be classified as either a conditionally exempt small-quantity generator 

34 or as a small-quantity generator of hazardous waste under the Resource Conservation and 

35 Recovery Act of 1976, as amended (RCRA). Hazardous waste generated during building 
Site Layout and Plant Description 

Draft NUREG-1941 3-38 August 2010 

1 activities could include small quantities of paints, solvents, greases, oils, caulk, and other 

2 common construction materials. No asbestos waste would be generated. During operation, 

3 only normal cleaning products, petrochemical products, water-treatment chemicals, and small 

4 quantities of additional regulated substances, such as laboratory chemicals, would be used 

5 onsite. Petroleum wastes could include waste gasoline, diesel fuel, oils, and grease. 

6 All transportation, storage, and disposal of regulated hazardous wastes would be in accordance 

7 with applicable RCRA regulations. All hazardous wastes would be collected, transported offsite 

8 by a licensed and permitted RCRA waste hauler, and treated or disposed of offsite at a RCRA9 permitted facility. Storage of some hazardous materials and associated wastes would occur in 

10 the Hazardous Waste Storage Building (Building 136), two Chemical Storage Buildings 

11 (Buildings 119 and 120), and the Painting and Sandblast Shop (Building 105) (PEF 2009a, c). 

12 Mixed wastes contain both hazardous and low-level radioactive waste. Small amounts of mixed 

13 solid waste could be generated during maintenance, refueling, and laboratory activities. The 

14 AP1000 design includes a solid-waste-management system that is designed to collect and store 

15 mixed wastes generated during normal plant operation. The packaged waste would be stored 

16 in the auxiliary and radwaste buildings until it is shipped offsite to a licensed disposal facility. 

PEF expects the LNP to generate about 0.3 m3

/yr of mixed waste with a maximum of 0.6 m3 17 /yr. 

18 The mixed waste from the LNP would be handled and managed in accordance with the 

19 applicable Federal and State regulations (PEF 2009a). 

20 3.4.5 Summary of Resource Commitments During Operation 

21 Table 3-4 lists the significant resource commitments involved in operating Units 1 and 2. The 

22 values in this table, combined with the affected environment described in Chapter 2, provide a 

23 part of the basis for the operational impacts assessed in Chapter 5. These values were stated 

24 in the ER (PEF 2009a) and supplemental RAI responses (PEF 2009d), and the review team has 

25 determined that the values are not unreasonable. 

26 Table 3-4. Summary of Resource Commitments Associated with Operation of Proposed LNP 

27 Units 1 and 2 

Resource(s) Value Parameter Description 

Hydrology – Groundwater 1097 gpm 

(1.58 Mgd) 

4061 gpm (5.8 Mgd) 

Annual average groundwater withdrawal rate 

Maximum groundwater withdrawal rate 

Hydrology – Surface Water 84,780 gpm 

 (190 cfs, 

 122 Mgd) 

Maximum CWS makeup-water flow rate (two 

units) 

28 
Site Layout and Plant Description 

August 2010 3-39 Draft NUREG-1941 

1 Table 3-4 (contd) 

Resource(s) Value Parameter Description 

Hydrology – Surface Water, 

Terrestrial Ecology, Meteorology-Air 

Quality 

28,260 gpm 

(40.7 Mgd) 

28,255 gpm 

(40.7 Mgd) 

5.32 gpm 

CWS consumptive use (evaporation plus drift, 

two units) 

CWS evaporation rate (two units) 

CWS drift rate (two units) 

Hydrology – Surface Water 1.23 × 109 Btu/hr Waste heat from CWS via liquid discharges 

Hydrology – Surface Water, Aquatic 

Ecology, Nonradiological Waste 

Systems 

57,923 gpm 

61,065 gpm 

89.1oF 

Average CWS blowdown flow rate (two units) 

Maximum CWS blowdown flow rate (two units 

plus stormwater runoff) 

CWS blowdown temperature 

Aquatic Ecology 0.95 cm (0.375 in) 

0.15 m/s (0.5 fps) 

Size of CWS intake traveling screen openings 

Maximum through-screen velocity of CWS intake 

traveling screens 

Meteorology – Air Quality Waste heat from CWS to atmosphere 

Meteorology – Air Quality, Terrestrial 

Ecology, Radiological Health, 

Socioeconomics 

56 ft 

225 ft 

CWS mechanical draft cooling-tower height 

Height of tallest structure (shield building) 

Socioeconomics 773 workers 

1573 workers 

Normal operating workforce for two units 

Maximum workforce during refueling outages 

lasting 25 to 30 days every 18 months 

(800 temporary workers in addition to normal 

operating workforce) 

Terrestrial Ecology, Socioeconomics, 

Nonradiological Health 

90 dBA 

28 dBA 

Nearfield maximum noise level (3 ft from source) 

Maximum noise level of main plant operations at 

nearest residence (2.6 km or 1.6 mi) 

Radiological Health, Transportation, 

Need for Power 

3415 MW(t) 

1200 MW(e) 

Thermal output per unit 

Gross electrical output per unit 

Radiological Health, Transportation 93 percent Expected annual capacity factor 

Source: PEF 2009a 

2 3.5 References 

3 10 CFR Part 20. Code of Federal Regulations, Title 10, Energy, Part 20, “Standards for 

4 Protection against Radiation.” 
Site Layout and Plant Description 

Draft NUREG-1941 3-40 August 2010 

1 10 CFR Part 50. Code of Federal Regulations, Title 10, Energy, Part 50, “Domestic Licensing of 

2 Production and Utilization Facilities.” 

3 10 CFR Part 51. Code of Federal Regulations, Title 10, Energy, Part 51, “Environmental 

4 Protection Regulations for Domestic Licensing and Related Regulatory Functions.” 

5 10 CFR Part 52. Code of Federal Regulations, Title 10, Energy, Part 52, "Licenses, 

6 Certifications, and Approvals for Nuclear Power Plants." 

7 29 CFR Part 1910. Code of Federal Regulations, Title 29, Labor, Part 1910, "Occupational 

8 Safety and Health Standards." 

9 40 CFR Part 141. Code of Federal Regulations, Title 40, Protection of Environment, Part 141, 

10 “National Primary Drinking Water Regulations.” 

11 71 FR 4464. January 27, 2006. “AP1000 Design Certification.” Federal Register. U.S. Nuclear 

12 Regulatory Commission. 

13 72 FR 57416. October 9, 2007. “Limited Work Authorizations for Nuclear Power Plants.” 

14 Federal Register. U.S. Nuclear Regulatory Commission. 

15 Florida Administrative Code (Fla Admin. Code 62-620). 2009. Chapter 62, “Wastewater 

16 Facility and Activities Permitting.” Florida Administrative Code Annotated.

17 Florida Department of Environmental Protection (FDEP). 2010a. Levy Nuclear Power Plant, 

18 Units 1 & 2, Progress Energy Florida, PA08-51B, Conditions of Certification, Plant and 

19 Associated Facilities and Transmission Lines. Tallahassee, Florida. Available at 

20 http://www.dep.state.fl.us/siting/files/certification/pa08_51_2010_B.pdf. 

21 Florida Department of Environmental Protection (FDEP). 2010b. Conditions of Certification, 

22 Progress Energy Florida, Crystal River Energy Complex, Unit 3 Nuclear Power Plant, Unit 4 and 

23 Unit 5 Fossil Plant Appendix G. PA77-09N, January 15, 2010. Tallahassee, Florida. Available 

24 at: http://www.dep.state.fl.us/siting/files/certification/pa77_09_2010_N.pdf. 

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

26 Progress Energy Florida, Inc. (PEF). 2008. Levy Nuclear Plant Units 1 and 2, Site Certification 

27 Application, Volumes 1 through 9. St. Petersburg, Florida. Including Amendments and 

28 Supplemental Information. Available at http://www.dep.state.fl.us/siting/apps.htm#ppn1. 

29 Progress Energy Florida, Inc. (PEF). 2009a. Levy Nuclear Plant Units 1 and 2 COL Application, 

30 Part 3, Applicant’s Environmental Report – Combined License Stage. Revision 1, St. 

31 Petersburg, Florida. Accession No. ML092860995. 
Site Layout and Plant Description 

August 2010 3-41 Draft NUREG-1941 

1 Progress Energy Florida, Inc. (PEF). 2009b. Levy Nuclear Plant Units 1 and 2 COL 

2 Application, Part 2, Final Safety Analysis Report. Revision 1, St. Petersburg, Florida. 

3 Accession No. ML092860737. 

4 Progress Energy Florida, Inc. (PEF). 2009c. Letter from Garry Miller, PEF, to NRC, dated 

5 January 16, 2009, regarding Supplemental Information for Environmental Audit – Information 

6 Needs with Attachments. Accession No. ML090750822. 

7 Progress Energy Florida, Inc. (PEF). 2009d Letter from Garry Miller, PEF, to NRC, dated 

8 March 27, 2009, regarding Response to Request for Addtional Information Regarding the 

9 Environmental Review. Accession No. ML091320050. 

10 Progress Energy Florida, Inc. (PEF). 2009e. Letter from Garry Miller, ,PEF, to NRC, dated 

11 June 12, 2009, regarding Supplement 1 to Response to Request for Additional Information 

12 Regarding the Environmental Review. Accession No. ML091740487. 

13 Progress Energy Florida, Inc. (PEF). 2009f. Letter from Garry Miller, PEF, to NRC, dated 

14 September 3, 2009, regarding Supplement 5 to Response to Request for Additional Information 

15 Regarding the Environmental Review. Accession No. ML092570297. 

16 Resource Conservation and Recovery Act (RCRA). 42 U.S.C. 6901 et seq.

17 U.S. Army Corps of Engineers (USACE). 2009. Public Notice – Permit Application No. SAJ18 2008-490 (IP-GAH); Levy Nuclear Plant (LNP) – Progress Energy Florida, SAJ-2008-490 (IP19 GAH), Sheet Index/Explanation for Public Notice. Panama City, Florida. Accession No. 

20 ML090890419. 

21 Westinghouse Electric Company LLC (Westinghouse). 2005. AP1000 Design Control 

22 Document. APP-GW-GL-700, Revision 15, Pittsburgh, Pennsylvania. Accession No. 

23 ML053480403. 

24 Westinghouse Electric Company LLC (Westinghouse). 2008. AP1000 Design Control 

25 Document. APP-GW-GL-700, Revision 17, Pittsburgh, Pennsylvania. Accession No. 

26 ML083230868. 

August 2010 4-1 Draft NUREG-1941 

1 4.0 Construction Impacts at the Proposed Site 

2 This chapter examines the environmental issues associated with building the proposed Units 1 

3 and 2 at the Levy Nuclear Plant (LNP) site as described in the application for combined 

4 construction permits and operating licenses (COLs) submitted by Progress Energy Florida, Inc. 

5 (PEF). As part of its application, PEF submitted (1) an Environmental Report (ER) 

6 (PEF 2009a), which discusses the environmental impacts of constructing the new nuclear units 

7 and provides information used as the basis for the environmental review and (2) a Final Safety 

8 Analysis Report (FSAR) (PEF 2009b), which addresses safety aspects of construction and 

9 operation. 

10 As discussed in Section 3.3 of this environmental impact statement (EIS), the U.S. Nuclear 

11 Regulatory Commission’s (NRC’s) authority related to building new nuclear units is limited to 

12 construction activities that have a reasonable nexus to radiological health and safety and/or 

13 common defense and security” (72 FR 57416). The NRC has defined “construction” according 

14 to the bounds of its regulatory authority. Many of the activities required to build a nuclear power 

15 plant do not fall within the NRC’s regulatory authority and, therefore, are not construction as 

16 defined by the NRC. Such activities are referred to as “preconstruction” activities in Title 10 of 

17 the Code of Federal Regulations (CFR) 51.45(c). The NRC staff evaluates the direct, indirect, 

18 and cumulative impacts of the construction activities that would be authorized with the issuance 

19 of a COL. The environmental effects of preconstruction activities (e.g., clearing and grading, 

20 excavation, and erection of support buildings) are included as part of this EIS in the evaluation 

21 of cumulative impacts. 

22 The U.S. Army Corps of Engineers (USACE) is a cooperating agency on this EIS consistent 

23 with an updated Memorandum of Understanding (MOU) signed with the NRC 

24 (USACE and NRC 2008). The NRC and the USACE established this cooperative agreement 

25 because both agencies have concluded it is the most effective and efficient use of Federal 

26 resources in the environmental review of a proposed new nuclear power plant. The 

27 environmental review described in this EIS was conducted by a joint NRC and USACE review 

28 team (composed of NRC staff, its contractors’ staff, and staff from the USACE). In carrying out 

29 its regulatory responsibilities, the USACE will complete an independent evaluation of the 

30 applicant’s Department of the Army (DA) permit application to determine whether to issue or 

31 deny a DA permit for this project. This decision will be documented in the USACE’s Record of 

32 Decision (ROD), which will be issued after publication of the EIS. 

33 USACE’s ROD will reference the information in the EIS and present any additional information 

34 required by the USACE to support its permit decision. The USACE’s role as a cooperating 

35 agency in the preparation of this EIS is to ensure to the maximum extent practicable that the 

36 information presented is adequate to fulfill the requirements of USACE permitting regulations. 
Construction Impacts at the Proposed Site 

Draft NUREG-1941 4-2 August 2010 

1 The “Section 404(b)(1) Guidelines for Specification of Disposal Sites for Dredged or Fill 

2 Material” (40 CFR Part 230) contains the substantive environmental criteria used by USACE in 

3 evaluating discharges of dredged or fill material into waters of the United States. USACE’s 

4 Public Interest Review (PIR) (33 CFR 320.4) directs the USACE to consider a number of factors 

5 as part of a balanced evaluation process. USACE’s PIR will be part of its permit decision 

6 document and will not be addressed in this EIS. 

7 On June 30, 2008, the USACE received copies of the State of Florida’s Site Certification 

8 Application for the proposed project. The Site Certification Application served as the application 

9 for a DA permit pursuant to Section 404 of the Federal Water Pollution Control Act (Clean Water 

10 Act) and Section 10 of the Rivers and Harbors Act of 1899. The USACE evaluation of the 

11 application will consider both construction and preconstruction activities. 

12 While both NRC and the USACE must meet the requirements of the National Environmental 

13 Policy Act of 1969, as amended (NEPA) (42 USC 4321 et seq.), both agencies also have 

14 mission requirements that must be met in addition to the NEPA requirements. The NRC‘s 

15 regulatory authority is based on the Atomic Energy Act of 1954, as amended (42 USC 2011 

16 et seq.). The USACE regulatory authority related to the proposed action is based on Section 10 

17 of the Rivers and Harbors Act (33 USC 403 et seq.), which prohibits the obstruction or alteration 

18 of navigable waters of the United States without a permit from the USACE, and Section 404 of 

19 the Clean Water Act (33 USC 1344 et seq.), which prohibits the discharge of dredged or fill 

20 material into waters of the United States without a permit from the USACE. Therefore, the 

21 applicant may not commence preconstruction or construction activities in jurisdictional waters, 

22 including wetlands, without a USACE permit. A decision whether to issue a permit is typically 

23 made after the USACE evaluation and receipt of public feedback in the form of public comments 

24 on its draft environmental review. Because the USACE is a cooperating agency under the MOU 

25 for this EIS, the USACE’s ROD of whether to issue a permit will not be made until after public 

26 comment has been received on this NRC/USACE draft EIS and the final EIS is issued. 

27 The collaborative effort between the NRC and the USACE in presenting their discussion of the 

28 environmental effects of building the proposed project, in this chapter and elsewhere, must 

29 serve the needs of both agencies. Consistent with the MOU, the staffs of the NRC and the 

30 USACE collaborated (1) in the review of the COL application and information provided in 

31 response to requests for additional information (RAIs; developed by the NRC and the USACE) 

32 and (2) in the development of the EIS. NRC regulations (10 CFR 51.45(c)) require that the 

33 impacts of preconstruction activities be addressed by the applicant as cumulative impacts in its 

34 ER. Similarly, the NRC’s analysis of the environmental effects of preconstruction activities on 

35 each resource area would be addressed as cumulative impacts, normally presented in 

36 Chapter 7. However, because of the collaborative effort between the NRC and the USACE in 

37 the environmental review, the combined impacts of construction activities that would be 

38 authorized by the NRC with its issuance of a COL and the preconstruction activities are 
Construction Impacts at the Proposed Site 

August 2010 4-3 Draft NUREG-1941 

1 presented in this chapter. For each resource area, the NRC also provides an impact 

2 characterization solely for construction activities that meet the NRC’s definition of construction 

3 at 10 CFR 50.10(a). Thereafter, both the assessment of the impacts of 10 CFR 50.10(a) 

4 construction activities and the assessment of the combined impacts of construction and 

5 preconstruction are used in the description and assessment of cumulative impacts in 

6 Chapter 7. 

7 For most environmental resource areas (e.g., terrestrial ecology), the impacts are not the result 

8 of either solely preconstruction or construction activities. Rather, the impacts are attributable to 

9 a combination of preconstruction and construction activities. Although, the majority of the 

10 impacts would occur as a result of preconstruction activities. 

11 This chapter is divided into 13 sections. In Sections 4.1 through 4.10, the review team 

12 evaluates the potential impacts on land use, water use and quality, terrestrial and aquatic 

13 ecosystems, socioeconomics, environmental justice, historic and cultural resources, 

14 meteorology and air quality, nonradiological and radiological health effects, and nonradioactive 

15 waste. An impact category level – SMALL, MODERATE or LARGE – of potential adverse 

16 impacts has been assigned by the review team for each resource area using the definitions for 

17 these terms established in Chapter 1. In some resource areas, for example, in the 

18 socioeconomic area where the impacts of taxes are analyzed, the impacts may be considered 

19 beneficial and are stated as such. The review team’s determination of the impact category 

20 levels is based on the assumption that the mitigation measures identified in the ER or activities 

21 planned by various State and county governments, such as infrastructure upgrades (discussed 

22 throughout this chapter), are implemented. Failure to implement these upgrades might result in 

23 a change in the impact category level. Applicable measures and controls that would limit the 

24 adverse impacts of building the proposed new units, where appropriate, are presented in 

25 Section 4.11. A summary of the construction impacts and the proportional distribution of 

26 impacts based on construction and preconstruction is presented in Section 4.12. References 

27 cited in this chapter are listed in Section 4.13. The technical analyses provided in this chapter 

28 support the results, conclusions, and recommendations presented in Chapters 7, 9, and 10. 

29 The review team’s evaluation of the impacts of building proposed LNP Units 1 and 2 draws on 

30 information presented in PEF’s ER and supplemental documents and the USACE permitting 

31 documentation, as well as other government and independent sources. 

32 4.1 Land-Use Impacts 

33 This section provides information on land-use impacts associated with building Units 1 and 2 at 

34 the LNP site. Topics discussed include land-use impacts at the LNP site, in the vicinity of the 

35 site, and in the region, and land-use impacts in the transmission-line corridors. 
Construction Impacts at the Proposed Site 

Draft NUREG-1941 4-4 August 2010 

1 4.1.1 The Site, Vicinity, Region, and Offsite Areas 

2 Land-use impacts of construction and preconstruction activities are discussed for the LNP site, 

3 as well as offsite areas, within the vicinity of the site (i.e., within the 6-mi radius), and the 50-mi 

4 region. The plant site includes the following: LNP Units 1 and 2, cooling towers, and associated 

5 support buildings: 

6 • 500-kV switchyard, 

7 • site access roads, and 

8 • stormwater ponds. 

9 Offsite areas include: 

10 • transmission-line corridors (which are covered in Section 4.1.2), 

11 • the heavy-haul road and barge slip access road, 

12 • barge slip, and 

13 • the makeup- and blowdown-water pipeline corridor and associated cooling-water intake 

14 and discharge structures. 

15 The plant site facilities would be located on approximately 627 ac near the center of the site, 

16 which is approximately 20 percent of the total site area (PEF 2009c). Construction and 

17 preconstruction activities for these facilities would permanently convert the existing land use 

18 from primarily pine plantations, forested wetlands, and mixed forests to a transportation, 

19 communications, and utilities land-use category (PEF 2009a). The ground elevation of the 

20 reactors and cooling towers, which is currently located within the 100-year floodplain, would be 

21 raised 8 ft above the existing grade, so that the structures would be above the 100-year 

22 floodplain. 

23 Approximately 150 ac on the site would be disturbed for temporary facilities, such as material 

24 storage areas, laydown areas, parking areas, and a temporary buffer surrounding the 

25 construction zone. Areas temporarily disturbed while creating these facilities would revert to 

26 open grassy areas after use of such facilities is completed, which would be a permanent 

27 conversion from pine plantations, forested wetlands, and mixed forests. During the building 

28 process, approximately 30 ac would be disturbed for temporary access to the transmission-line 

29 rights-of-way, heavy-haul road, and pipeline right-of-way, which would run from the LNP site to 

30 the Cross Florida Barge Canal (CFBC). Temporary access would be provided via a 50-ft buffer 

31 on one side of the common corridor (see Section 2.5), which would be restored to the original 

32 land-use type after building at the LNP site is completed (PEF 2009c). Lands within the 

33 common corridor would be permanently converted from mixed forest land, forested wetland, 
Construction Impacts at the Proposed Site 

August 2010 4-5 Draft NUREG-1941 

1 pine plantations, and nonforested wetland to a transportation, communications, and utilities 

2 land-use category. 

3 Heavy equipment and reactor components would be barged from the Gulf of Mexico up the 

4 CFBC. A new barge slip would be built on the north bank of the CFBC at the end of the 

5 proposed barge slip access road. Approximately 1.1 ac would require dredging below mean 

6 high water and excavation of 1 ac would be required above mean high water. In total, this 

7 activity would permanently convert the existing land use for approximately 2.1 ac of mixed 

8 forests to streams and canals. 

9 The barge slip access road would extend from County Road 40 (CR-40) south to the anticipated 

10 barge slip. A heavy-haul road would be built to transport heavy equipment and materials north 

11 from CR-40 to the LNP site and allow for ground transportation of heavy equipment and 

12 materials from the proposed barge slip. The roads would affect primarily mixed forested lands, 

13 forested wetlands, and other agricultural lands. Table 4-1 and Table 4-2 list the anticipated 

14 onsite and offsite land-use impacts. Roadways would be built to Florida Department of 

15 Transportation (FDOT) standards. 

16 Table 4-1. LNP Onsite Land-Use Impacts by Major Component 

Facility Impact Land-Use Type 

Impact Area 

(ac) 

Heavy-Haul Road Permanent Other open lands (rural) 0.3 

Tree plantations 5.9 

Cypress 1.1 

Wet planted pine 1.2 

Wetland forested mixed 0.6 

Wet prairies 0.1 

Miscellaneous Fill Permanent Other open lands (rural) 3.7 

Tree plantations 39.2 

Cypress 7.2 

Wet planted pine 19.2 

Wetland forested mixed 1.8 

Freshwater marshes 0.1 

Wet prairies 0.1 

Treeless hydric savannah 41.3 

Miscellaneous Pipeline Permanent Other open lands (rural) 0.7 

Tree plantations 1.5 

Cypress 0.3 

Wet planted pine 0.3 

Wetland forested mixed 1.6 

Wet prairies 0.0 
Construction Impacts at the Proposed Site 

Draft NUREG-1941 4-6 August 2010 

1 

Table 4-1. (contd)

Facility Impact Land Use Type 

Impact Area 

(ac) 

Miscellaneous Structures Permanent Other open lands (rural) 6.2 

Tree plantations 30.2 

Mixed wetland hardwoods 0.7 

Cypress 1.7 

Wet planted pine 17.1 

Wetland forested mixed 4.9 

Freshwater marshes 0.3 

Wet prairies 0.0 

Treeless hydric savannah 13.1 

Pipeline LNP to CFBC Permanent Other open lands (rural) 1.0 

Tree plantations 7.2 

Cypress 1.9 

Wet planted pine 1.2 

Wetland forested mixed 3.7 

Wet prairies 0.3 

Treeless hydric savannah 0.4 

Pond A Permanent Tree plantations 19.6 

Wet planted pine 30.1 

Wetland forested mixed 6.3 

Freshwater marshes 3.7 

Treeless hydric savannah 10.1 

Pond B Permanent Other open lands (rural) 6.8 

Cypress 3.0 

Wet planted pine 0.0 

Wetland forested mixed 0.1 

Wet prairies 4.0 

Pond C Permanent Tree plantations 15.6 

Cypress 2.5 

Wet planted pine 6.1 

Freshwater marshes 0.2 

Shooting Range Permanent Tree plantations 0.1 

Site Access Roads Permanent Other open lands (rural) 1.5 
Construction Impacts at the Proposed Site 

August 2010 4-7 Draft NUREG-1941 

Table 4-1. (contd)

Facility Impact Land Use Type 

Impact Area 

(ac) 

Tree plantations 15.4 

Cypress 2.5 

Wet planted pine 8.1 

Wetland forested mixed 1.0 

Treeless hydric savannah 0.7 

Switchyard Permanent Tree plantations 28.4 

Cypress 5.3 

Wet planted pine 7.1 

Switchyard Connection Permanent Other open lands (rural) 1.1 

Tree plantations 11.0 

Cypress 4.2 

Wet planted pine 5.1 

Freshwater marshes 0.0 

Wet prairies 0.1 

Treeless hydric savannah 1.7 

Transmission Corridor Permanent Upland coniferous forests 0.1 

Tree plantations 100.5 

Mixed wetland hardwoods 9.5 

Cypress 24.1 

Wet planted pine 33.9 

Wetland forested mixed 8.4 

Freshwater marshes 2.0 

Wet prairies 0.3 

LNP Unit 1 Permanent Other open lands (rural) 5.5 

Wet planted pine 3.4 

Wetland forested mixed 0.7 

Freshwater marshes 2.0 

Treeless hydric savannah 3.8 

LNP Unit 2 Permanent Other open lands (rural) 4.3 

Tree plantations 2.9 

Wet planted pine 2.1 

Wetland forested mixed 0.0 

Freshwater marshes 3.7 
Construction Impacts at the Proposed Site 

Draft NUREG-1941 4-8 August 2010 

Table 4-1. (contd)

Facility Impact Land Use Type 

Impact Area 

(ac) 

Wet prairies 0.1 

Treeless hydric savannah 2.3 

50-Foot Buffer to CFBC Temporary Other open lands (rural) 9.1 

Tree plantations 56.6 

Mixed wetland hardwoods 2.7 

Cypress 13.2 

Wet planted pine 39.5 

Wetland forested mixed 7.4 

Freshwater marshes 0.6 

Wet prairies 1.5 

Treeless hydric savannah 19.1 

Subtotal Permanent 627.1 

Subtotal Temporary 149.7 

Total 776.8 

Source: PEF 2009c. 

1 Table 4-2. LNP Offsite Land-Use Impacts by Major Component 

Facility Impact Land-Use Type 

Impact 

Area (ac) 

Blowdown Pipeline Permanent Extractive 4.5 

Open land 37.8 

Shrub and brushland 0.9 

Mixed rangeland 9.4 

Upland coniferous forest 2.3 

Pine flatwoods 3.8 

Longleaf pine – xeric oak 0.7 

Hardwood conifer mixed 16.9 

Tree plantations 6.5 

Streams and waterways 1.7 

Reservoirs 2.3 

Wetland forested mixed 2.2 

Freshwater marshes 6.5 

Saltwater marshes 4.5 

Transportation 1.6 

Utilities 14.6 
Construction Impacts at the Proposed Site 

August 2010 4-9 Draft NUREG-1941 

1 Table 4-2. (contd) 

Facility Impact Land-Use Type 

Impact 

Area (ac) 

Heavy-Haul Road Permanent Other open lands (rural) 6.6 

Upland coniferous forest 1.9 

Hardwood conifer mixed 0.1 

Tree plantations 23.1 

Cypress 5.3 

Freshwater marshes 2.5 

Miscellaneous Pipeline Permanent Other open lands (rural) 1.2 

Hardwood conifer mixed 0.8 

Tree plantations 3.4 

Freshwater marshes 0.3 

Pipeline CFBC to 

Crystal River Energy Complex 

(CREC) 

Permanent Other open lands (rural) 7.2 

Upland coniferous forest 1.5 

Hardwood conifer mixed 1.1 

Tree plantations 27.0 

Cypress 6.4 

Wetland forested mixed 0.2 

Freshwater marshes 2.6 

Site Access Roads Permanent Upland coniferous forest 0.0 

Hardwood conifer mixed 0.0 

Tree plantations 3.6 

Cypress 0.8 

Freshwater marshes 0.6 

Transportation 0.1 

Utilities 0.2 

Barge Slip and Access Road Permanent Other open lands (rural) 2.0 

Coniferous plantations 3.2 

Reservoirs 0.1 

Transportation 1.3 

50-ft Buffer to CFBC Temporary Other open lands (rural) 8.4 

Upland coniferous forest 1.6 

Hardwood conifer mixed 1.8 

Tree plantations 11.8 

Cypress 3.8 

Wetland forested mixed 0.8 

Freshwater marshes 1.4 

Permanent Subtotal 219.3 

Temporary Subtotal 29.6 

Total 248.9 

Sources: PEF 2009c, CH2M HILL 2008. 
Construction Impacts at the Proposed Site 

Draft NUREG-1941 4-10 August 2010 

1 In its Site Certification Application, PEF states that most of the fill material needed would come 

2 from onsite excavation activities, but 30 to 45 percent of it may have to be obtained from offsite 

3 borrow pits (PEF 2009d). This offsite material would be trucked onto the LNP site over the 

4 heavy-haul road. To minimize related impacts on surrounding land, the heavy-haul road would 

5 be collocated with the transmission-line corridor and the makeup-water and blowdown-water 

6 pipeline corridor. PEF selected the location of the proposed heavy-haul road because it is the 

7 shortest direct route to the LNP site from the barge slip, it is slightly higher in elevation, and it 

8 contains fewer wetlands than other potential locations that were considered (PEF 2009d). 

9 Makeup-water and blowdown-water pipeline corridors and their associated structures would be 

10 built along or near the CFBC and connect the LNP to its primary source of water. The 

11 blowdown pipeline would connect LNP to the Crystal River Energy Complex (CREC). These 

12 facilities would result in permanent land-use changes from streams, waterways, reservoirs, 

13 wetlands, and marshes to transportation, communications, and utilities. Initially proposed 

14 routing of the blowdown pipeline south of the CFBC crosses several tidal creeks and would 

15 adversely impact approximately 4.5 acres of salt marsh habitat. The staff is aware that PEF has 

16 proposed to the FDEP an alternate route to avoid this important habitat. FDEP has not made a 

17 decision on the proposal. Impacts to habitat related to the discharge pipeline, irrespective of the 

18 final routing, would be primarily due to its excavation, placement, and burial associated with 

19 construction. The intake structures would be located 7 mi from the Gulf of Mexico along the 

20 CFBC’s northern bank, and 0.5 mi from the Inglis Lock. The makeup-water pump house at the 

21 intake location would affect 1.1 ac of land already used for transportation, communications, and 

22 utilities. 

23 PEF has not made a final determination regarding the source of the fill material for the LNP site. 

24 To provide additional context for the potential impacts of fill mining, the review team considered 

25 the impacts if the proposed Tarmac King Road Limestone Mine provided the source of fill. The 

26 proposed mine would be located 1 mi west of the intersection of U.S. Highway 19 (US-19) and 

27 King Road in Levy County, about 2 mi west of the LNP site. Additional information regarding 

28 the mine is provided in Chapter 7. Tarmac America LCC (Tarmac) has applied for permits to 

29 begin site development in 2011, with operations beginning in 2013. This limestone mine would 

30 be located on a 9400-ac aggregate mining site. The mined portion would include 2700 ac of 

31 wetlands and uplands. An additional 1300 ac would be used for the associated quarry, 

32 processing plant, roads, and buffers; 800 ac would be set aside for wetlands; and 4500 ac 

33 would be donated to the State of Florida for preservation. The Tarmac mine would not be 

34 developed solely for providing fill material to the LNP site. Therefore, only a portion of the 

35 impact of the mine would be considered directly attributable to the LNP project, if the Tarmac 

36 mine were the source for fill material at the LNP site. 

37 To lessen the land-use impacts, PEF has indicated that it would use mitigation measures during 

38 construction and preconstruction activities, such as erosion control, controlled access roads, 
Construction Impacts at the Proposed Site 

August 2010 4-11 Draft NUREG-1941 

1 and restricted construction zones (PEF 2009a). Stormwater runoff from LNP corridors would be 

2 controlled by a stormwater-drainage system. Three stormwater ponds would be designed and 

3 constructed to fully contain the runoff from a 25-year, 24-hour rainfall. The stormwater collected 

4 in the ponds would infiltrate to groundwater or during exceptional rainfall events be drained 

5 through emergency spillways. The retained water could be pumped to the cooling-tower 

6 blowdown basin if necessary. 

7 Land-use impacts on communities within the 50-mi region could result from the increased 

8 workforce (up to 3300 new employees) and associated increases in urbanized land uses, such 

9 as residences and commercial areas. PEF estimates that up to half of the workforce used to 

10 build the facility might decide to relocate to the LNP vicinity. It is anticipated that adequate 

11 housing (houses for rent or purchase, mobile homes, recreational vehicle/camping units, and 

12 public lodging in hotels or motels) and community services would be available to accommodate 

13 this influx of workers. The other half of the workforce would commute from other areas within 

14 the region. See Section 4.4.4.4 for discussion of the induced impacts to residential areas and 

15 community services from construction and preconstruction. 

16 During construction and preconstruction activities for LNP Units 1 and 2, traditional hunting on 

17 the LNP site would be prohibited. However, hunting and fishing locations would be available in 

18 parks and recreational areas in the region. 

19 Wetland impacts are discussed in Section 4.3.1. Coordination with the USACE to address 

20 Clean Water Act 404 requirements, including mitigation for wetland impacts, is ongoing. Prior to 

21 receipt of a USACE permit (if issued), PEF may not commence activities in jurisdictional waters, 

22 including wetlands. 

23 Onsite, at least 627 ac of land would be permanently converted to a new land use. In addition, 

24 several offsite areas would have permanent land-use impacts, such as the heavy-haul road, the 

25 blowdown pipeline corridor, the intake facility, and the corridor for the makeup-water pipeline. 

26 These permanent land-use impacts would be detectable, but would not noticeably alter the 

27 existing land uses within the vicinity and region. 

28 4.1.2 Transmission-Line Corridors 

29 10 CFR 50.10(a)(2) specifically states that building transmission lines is not considered an 

30 NRC-authorized construction activity. There would be no transmission-line corridor impacts 

31 from NRC-authorized construction activities. However, the review team is analyzing these 

32 impacts here to support the USACE’s analysis. Transmission-line siting in Florida is regulated 

33 under the Florida Power Plant Siting Act (PPSA) (29 Fla. Stat. 403), and Chapter 62-17 of the 

34 Florida Administrative Code (FAC) (Fla. Admin Code 62-17). Although the precise rights-of-way 

35 for the proposed new transmission lines have not yet been determined, the locations of 

36 conceptual transmission-line planning corridors are shown in Figure 2-5. 
Construction Impacts at the Proposed Site 

Draft NUREG-1941 4-12 August 2010 

1 Table 4-3 lists the land-use impacts for representative corridors within the wider conceptual 

2 corridors. The review team expects that somewhat less acreage than the entire planning 

3 corridor described in Section 2.2.2 would be required to site transmission line rights-of-way due 

4 to several factors. Finalized siting plans and permitting conditions that would be imposed by the 

5 various affected State and local agencies would minimize the footprint of the corridors. 

6 Engineering considerations and costs are likely to suggest designs that favor collocation with 

7 existing transmission lines in existing corridors. The review team based these expectations on 

8 its review of the State of Florida’s Conditions of Certification (FDEP 2010a), which lists each 

9 affected agency’s specific permitting conditions, and also on commitments made by PEF to use 

10 existing corridors to the extent practicable (PEF 2009a). Specific State conditions that would 

11 minimize changes in land disturbance and land use include the following: 

12 • Rights-of-way are to be collocated “to the extent feasible with or adjacent to existing 

13 public rights-of-way.” 

14 • Rights-of-way are to “avoid the taking of homes.” 

15 • Rights-of-way are to “avoid Outstanding Florida Waterbodies (OFW) to the extent 

16 feasible and practicable,” and can only locate in such areas upon demonstrating how 

17 doing so “is clearly in the public interest.” 

18 PEF proposes four new 500-kV transmission lines and four new 230-kV transmission lines to 

19 serve Units 1 and 2 at the LNP site. All transmission lines would share a common corridor that 

20 exits to the south of the LNP site, then turns east at the CREC. The proposed Citrus substation 

21 is located approximately 9 mi south of the LNP site. The transmission-line corridor would be 

22 approximately 1000 to 2640 ft wide and 59 mi long. 

23 In addition, several new transmission lines would be required beyond the first substation to 

24 integrate power from the proposed LNP into the Florida electrical grid. These lines would 

25 include four 230-kV lines and one 500-kV line. Two of the 230-kV lines would run from the 

26 proposed Citrus substation to the Crystal River East substation (both in Citrus County); one 

27 would run approximately 38 mi south from the CREC 500-kV switchyard in Citrus County to the 

28 existing Brookridge substation in Hernando County; and one would originate at the existing 

29 Kathleen substation in Polk County, run south to the existing Griffin substation in Hillsborough 

30 County, and then west, terminating at the existing Lake Tarpon substation in Pinellas County. 

31 The 230-kV transmission line would run from the Brookridge substation to the Brooksville West 

32 substation (both in Hernando County) (FDEP 2010a). Two 69-kV transmission lines would be 

33 required to support activities related to building the facility, both connecting to existing lines and 

34 entering the LNP site from the western and southern borders. These lines would require about 

35 4.6 mi of new transmission-line corridors (PEF 2008a). 

36 The review team expects that the dimensions of each transmission segment would conform to 

37 dimensions described in the Florida Department of Environmental Protection (FDEP) Conditions 

38 of Certification (FDEP 2010a) as follows: 
Construction Impacts at the Proposed Site 

August 2010 4-13 Draft NUREG-1941 

1 Table 4-3. Land-Use Impacts within Representative Transmission-Line Corridors in Acres

FLUCFCS 

Land Use/ 

Habitat 

Levy/Citrus 

Common 

Corridor Citrus 

Crystal 

River 

East Sumter

BrookridgeBrooksville 

West Kathleen 

Total 

Acreage 

Percent 

by Land 

Cover 

411 Pine Flatwoods 16.1 0 0 10.7 0 0 3.4 30.2 1.7 

412 Longleaf Pine – 

Xeric Oak 

0 152.4 1.1 25.1 6.4 1 0 186 10.4 

413 Sand Pine 0 0 0 54.2 1.3 0 0 55.5 3.1 

421 Xeric Oak 0 0 0 97.4 0.3 0 0 97.7 5.5 

424 Melaleuca 0 0 0 0 0 0 0.3 0.3 0 

427 Live Oak 0 0 0 11.3 0 0 0 11.3 0.6 

434 Hardwood – 

Conifer Mixed 

75.7 177.1 71.5 191.2 0.1 0 31.8 547.4 30.6 

441 Coniferous 

Plantations 

138.9 0 0 106.9 0.5 0 0.6 246.9 13.8 

510 Streams and 

Waterways 

1.2 0.1 0 0.2 0 0 0.6 2.1 0.1 

520 Lakes 0 0 0 0.9 0 0 0.9 1.8 0.1 

530 Reservoirs 0 0.2 0 0.1 0 0 6.3 6.6 0.4 

534 Reservoirs <10 

ac 

0 0 0 0 0 0 0.4 0.4 0 

615 Stream and Lake 

Swamps 

(Bottomland) 

0 11.6 1.3 25.7 0 0 3.4 42 2.4 

621 Cypress 185.2 2.7 1 0.4 0 0 2.4 191.7 10.7 

624 Cypress – Pine – 

Cabbage Palm 

2.6 0 0 0 0 0 0 2.6 0.1 

630 Wetland Forested 

Mixed 

23 2.4 1.3 0.1 0 0 3.8 30.6 1.7 

631 Wetland Scrub 0 0 0 0 0 0 0.1 0.1 0 

641 Freshwater 

Marshes 

0 10.3 5.9 9.6 1.1 0 32.4 59.3 3.3 

643 Wet Prairies 0.6 0 0 3.9 0 0 0.9 5.4 0.3 

653 Intermittent 

Ponds 

0 0 0 0 0 0 0 0 0 

830 Utility Right-ofWay 2.6 0.3 35 50.9 130.2 7.2 43.1 269.3 15.1 

 Total Disturbed 

Acreage 

445.9 357.1 117.1 588.6 139.9 8.2 130.4 1787.2 100 

 Percent by 

Corridor 

24.9 20 6.6 32.9 7.8 0.5 7.3 100 

Sources: PEF 2009c and FDOT 1999. 

Notes: The Levy North South Corridor is subsumed within the total for the Levy/Citrus Common Corridor. 

FLUCFCS = Florida Land Use, Cover and Forms Classification System. 
Construction Impacts at the Proposed Site 

Draft NUREG-1941 4-14 August 2010 

1 • Citrus corridor: This entirely new 500-kV corridor, also known as the LPC corridor, 

2 would accommodate rights-of-way for two 500-kV transmission lines originating at the 

3 LNP switchyard and traversing 2 mi of the LNP site and the southern property. From the 

4 southern boundary of the southern property, it would then traverse south for 

5 approximately 7 mi, terminating at the proposed Citrus substation in Citrus County, 

6 Florida. Each 500-kV line typically would require a width of 200–220 ft, but by optimizing 

7 design, less width may be needed. 

8 • Crystal River corridor: Also known as the LCR corridor, this 500-kV corridor is 

9 approximately 14 mi long. From the LNP to the existing PEF 500-/230-kV transmission 

10 line, the transmission lines would likely be collocated with three other proposed 500-kV 

11 transmission lines (the two Citrus transmission lines and the Sumter transmission line) 

12 within the Levy/Citrus common corridor. From CR 488 (West Dunnellon Road), the 

13 Crystal River corridor proceeds south to the existing PEF 500/230-kV transmission-line 

14 right-of-way, where it turns west centered on the existing PEF 500/230-kV transmission15 line right-of-way alignment to the CREC switchyard. A single, new 500-kV transmission 

16 line is proposed for the 500-kV of this corridor. The proposed collocation with other 

17 proposed and existing 500-kV transmission lines may allow a reduction in the typical 

18 right-of-way width. 

19 • Sumter corridor: From the LNP to the existing PEF 500/230-kV transmission line, the 

20 500-kV Sumter corridor (also known as the LCFS corridor) would be collocated with the 

21 three other proposed 500-kV transmission lines (the two Citrus transmission lines and 

22 the Crystal River transmission line) in the Levy/Citrus common corridor. For most of the 

23 rest of its length, the 500-kV Sumter corridor will be collocated with existing PEF 

24 transmission lines. The corridor is approximately 59 mi long, and typically 200–220 ft 

25 wide, and would terminate at the proposed Central Florida South Substation near the 

26 City of Leesburg in Lake County, Florida. The proposed collocation with other proposed 

27 and existing 500-kV transmission lines likely would allow a reduction in the typical right28 of-way width. 

29 • Brookridge corridor: Also known as the CB corridor, the 230-kV Brookridge corridor 

30 originates at the CREC switchyard in Citrus County and terminates at the existing 

31 Brookridge substation in Hernando County. The overall length of the corridor is 

32 approximately 38 mi. The corridor would be collocated with PEF’s existing transmission33 line rights-of-way for most of its length. Each 230-kV line typically would require 100 ft of 

34 corridor width, but by optimizing design and collocation, less width may be needed. 

35 • Brooksville West corridor: The 230-kV Brooksville West corridor (also termed the BBW 

36 corridor) originates at the existing Brookridge substation, traverses south, and 

37 terminates at the existing Brooksville West substation in Hernando County, Florida. The 

38 overall length of the corridor would be approximately 3 mi and be collocated with the 

39 existing PEF 500/230/115-kV transmission-line right-of-way. Each 230-kV line typically 
Construction Impacts at the Proposed Site 

August 2010 4-15 Draft NUREG-1941 

1 would require 100 ft of corridor width, but by optimizing design and collocation, less 

2 width may be needed. 

3 • Kathleen corridor: The 230-kV Kathleen corridor (also termed the PHP corridor) 

4 originates at the existing Kathleen substation in Polk County and terminates at the 

5 existing Lake Tarpon substation in Pinellas County. The overall length of the corridor is 

6 approximately 50 mi. The proposed corridor would be collocated with PEF’s existing 

7 230-kV transmission-line right-of-way from the Kathleen substation to the Griffin 

8 substation. The 230-kV transmission line would replace the existing 115-kV 

9 transmission-line from the existing Griffin substation to the existing Lake Tarpon 

10 substation. Each 230-kV line typically would require 100 ft of corridor width, but by 

11 optimizing design and collocation, less width may be needed. 

12 • Crystal River East corridor: The 230-kV Crystal River East corridor (also termed the 

13 CCRE corridor) originates at the proposed Citrus substation and traverses east and 

14 crossing US-19. Then the corridor makes a right-angle, turning south toward the 

15 existing Crystal River East substation, and ending approximately 0.25 mi south of the 

16 existing PEF 500/230-kV transmission-line right-of-way, for a total run of 0.75 mi each. 

17 Each 230-kV line typically would require 100 ft of corridor width, but by optimizing design 

18 and collocation, less width may be needed. 

19 • Levy North-South corridor: This corridor would be used to supply offsite power to the 

20 LNP site via 69-kV lines. The north portion is a small 375 ft segment linking the LNP site 

21 with an existing 69-kV transmission line just west of US-19. The south portion is 

22 approximately 4.5 mi long. A right-of-way up to 70 ft wide would be required, which 

23 would be reduced within the Levy/Citrus common corridor and wherever the right-of-way 

24 would run adjacent to an existing road right-of-way. Because it is subsumed by the 

25 Levy/Citrus common corridor, this corridor is not identified separately in Table 4-3. 

26 Based on Table 4-3, a total of about 1790 ac of land would be disturbed by placement of new 

27 transmission lines in corridors PEF is proposing (PEF 2009c). Of this total, about 18.6 percent 

28 is classified as wetlands under the Florida Land Use, Cover and Forms Classification System 

29 (FLUCFCS), with 65.8 percent of the total in forested lands, 0.6 percent crossing open water, 

30 and the remaining 15.1 percent crossing existing utility right-of-way including agricultural land. 

31 Wetland impacts are discussed in more detail in Section 4.3.1.1. 

32 In its ER (PEF 2009a), PEF reports that corridor development and transmission-line placement 

33 would include erosion control, corridor preparation, placement of foundations, assembly and 

34 erection of structures, and installation of conductors. PEF has committed to minimizing the 

35 effects on human populations, waterbodies and wetlands, archaeological and historic sites, 

36 vegetation, and wildlife to the extent practicable by complying with State and Federal regulatory 

37 requirements, including the specific conditions outlined in the Conditions of Certification (FDEP 

38 2010a) discussed previously in this section. 
Construction Impacts at the Proposed Site 

Draft NUREG-1941 4-16 August 2010 

1 PEF indicates that the entire width of the transmission-line corridor would be completely cleared 

2 except within wetland areas. In general, proposed transmission lines that would be collocated 

3 with existing transmission lines would use portions of the existing right-of-way. However, for 

4 areas where existing right-of-way widths are insufficient for placement of the proposed 

5 collocated transmission lines, additional land clearing would be necessary (PEF 2009a). 

6 Because transmission-line corridors would pass through a number of undisturbed lands, 

7 including wetlands, PEF has identified several measures it would take to mitigate the impacts on 

8 the environment. Upland areas would be cleared and covered with a chipping material. 

9 Corridors that pass through wetlands would be cleared, although vegetation and trees would be 

10 cut back to avoid clearing where possible. Trees that are cut down would have their stumps 

11 and root systems left intact where possible. After the transmission lines have been installed, the 

12 land in the corridors would be maintained in an herbaceous state. Where practicable, vegetated 

13 areas 25 ft wide forming deep foliage screens with mature heights not exceeding 12 ft would be 

14 left intact where the corridor crosses navigable waterways. In addition, the State of Florida 

15 Conditions of Certification would help minimize land-use impacts. For example, according to 

16 FDEP (2010a), to ensure that impacts are minimized, “...where practicable, the length of the 

17 span between transmission line structures shall be varied and other design changes made, 

18 which shall include but not be limited to a reduction in pad size, elimination of access roads, use 

19 of finger fill from existing rights-of-ways (ROWs) and/or modification of construction techniques 

20 shall be considered....” 

21 Based on information provided by PEF and the review team’s independent review, the review 

22 team concludes that because of the amount and breadth of land to be affected by new 

23 transmission-line corridor development, the development activities would be somewhat 

24 noticeable to the public and there would be the potential for more than minor acreages to be 

25 converted from forested land to utility corridor land use. However, these impacts, while 

26 noticeable, are not expected to be destabilizing with respect to land use and would be mitigated 

27 as already described. Because the NRC does not authorize the building of transmission lines, 

28 the incremental impact from NRC-authorized activities would be negligible. 

29 4.1.3 Summary of Land-Use Impacts 

30 The review team evaluated the construction and preconstruction activities related to building 

31 proposed LNP Units 1 and 2 and the potential land-use impacts at the site and vicinity, in the 

32 region, and in the potential transmission-line corridors. Onsite, at least 627 ac of land would be 

33 permanently converted to a new land use. In addition, 219 ac of offsite areas would have 

34 permanent land-use impacts, such as the heavy-haul road, the blowdown pipeline corridor, the 

35 intake facility, and the makeup-water pipeline corridor. Transmission-line corridors would 

36 require about 1790 ac of land disturbance. These land-use impacts would be detectable, but 

37 would not noticeably alter the existing land uses in the vicinity and region. Transmission lines 
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August 2010 4-17 Draft NUREG-1941 

1 would noticeably alter, but not destabilize, local land uses, especially for new transmission lines 

2 that are not collocated with existing transmission lines. 

3 Based on information provided by PEF and the review team’s independent evaluation, the 

4 review team concludes that the land-use impacts of construction and preconstruction activities 

5 including those from placement of the transmission lines would be MODERATE, and PEF 

6 described the following mitigation activities to reduce such impacts: clearing and covering 

7 upland areas with a chipping material, avoiding clearing in wetland areas where possible, 

8 leaving stumps and root systems intact where possible, and maintaining land in corridors in an 

9 herbaceous state. Where practicable, PEF would leave intact vegetated areas 25 ft wide 

10 forming deep foliage screens with mature heights not exceeding 12 ft where the corridor 

11 crosses navigable waterways. In addition, the FDEP Conditions of Certification would help 

12 minimize land-use impacts. No further mitigation beyond the actions stated above would be 

13 warranted. 

14 In Chapter 4.0 of the ER, PEF estimated that 95 to 100 percent of the land-use impacts would 

15 be the result of preconstruction activities, such as clearing, grading, building roads, excavation, 

16 erection of support buildings, and placement of the transmission lines (PEF 2009a). NRC’s 

17 Limited Work Authorization (LWA) rule (72 FR 57416) specifically indicates that transmission 

18 lines and other offsite activities are not included in the definition of NRC-authorized construction. 

19 Because NRC-authorized construction activities represent only a part of the analyzed activities 

20 and because NRC does not authorize transmission-line installation activities, the NRC staff 

21 concludes that the impacts of NRC-authorized construction activities would be SMALL. The 

22 NRC staff also concludes that no further mitigation measures beyond PEF’s commitments and 

23 the FDEP Conditions of Certification would be warranted. 

24 4.2 Water-Related Impacts 

25 Water-related impacts involved in building a nuclear power plant are similar to impacts that 

26 would be associated with building of any large industrial construction project. Prior to initiating 

27 building activities including any site-preparation work, PEF would be required to obtain the 

28 appropriate authorizations regulating alterations to the hydrological environment. Below is a list 

29 of the hydrological-related authorizations, permits, and certifications potentially required from 

30 Federal, State, regional, and local agencies. Additional detail regarding the items listed is 

31 contained in Appendix H. 

32 • Clean Water Act Section 401 certification. This certification is issued by the FDEP as 

33 part of Florida’s PPSA Certification and ensures that the project does not conflict with 

34 State water-quality standards. This certification is required before the NRC can issue a 

35 COL to PEF. 
Construction Impacts at the Proposed Site 

Draft NUREG-1941 4-18 August 2010 

1 • Department of the Army (DA) Permit (USACE). Authorization from the USACE would be 

2 required under Section 404 of the Clean Water Act for the discharge of fill or dredged 

3 material into waters of the United States associated with the site preparation activities 

4 and construction of the nuclear power plant and its associated components, including 

5 electrical transmission lines and substations, access roads, a barge slip at the Cross 

6 Florida Barge Canal (CFBC), cooling-tower makeup-water pipeline with an intake structure 

7 at the CFBC, and blowdown pipelines. Authorization would also be required under Section 

8 10 of the Rivers and Harbors Act of 1899 for the construction or placement of structures, 

9 dredging, and the discharge of fill or dredged materials into or over navigable waters of 

10 the United States associated with the construction of the nuclear power plant and its 

11 associated components. 

12 • Clean Water Act Section 402(p) National Pollutant Discharge Elimination System 

13 (NPDES) Discharge permit. This permit would regulate limits of pollutants in liquid 

14 discharges to surface water. The U.S. Environmental Protection Agency (EPA) has 

15 delegated the authority for administering the NPDES program in Florida to the FDEP. 

16 The NPDES permits are part of PPSA certification. A stormwater pollution prevention 

17 plan (SWPPP) would be required. 

18 • Water-use permit. Consumptive use of surface water or groundwater would require a 

19 permit from the FDEP or the water management district. 

20 • Groundwater well drilling and operating permits. Construction of water wells would 

21 require a permit from the Southwest Florida Water Management District (SWFWMD). 

22 4.2.1 Hydrological Alterations 

23 Building the proposed Units 1 and 2 at the LNP site would alter several bodies of surface water 

24 and some of the aquifers underlying the site. Surface water resources that may be affected 

25 include the wetlands located in the area where proposed Units 1 and 2 would be located and 

26 the CFBC. Building LNP Units 1 and 2 would require excavation and/or dredging for installation 

27 of a barge-unloading facility and the intake structure for the circulating-water system on the 

28 CFBC and the installation of the blowdown discharge line from Units 1 and 2 to the Crystal River 

29 Discharge Canal. 

30 Other activities would require alteration of the land surface in the vicinity of the proposed units. 

31 These alterations include clearing and grading for new and upgraded roadways. These land 

32 surface modifications would alter surface-water runoff flow patterns and the infiltration properties 

33 of the land surface. 

34 Building LNP Units 1 and 2 and their ancillary facilities would occur within the 100-year 

35 floodplain and a portion of the offsite transmission line would be located within the 100-year 

36 floodplain (PEF 2008a). The State of Florida requires that any encroachment on the 100-year 
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August 2010 4-19 Draft NUREG-1941 

1 floodplain that may result in loss of flood storage be compensated (Fla. Admin. Code 40D-4.301 

2 and 40D-4.302) such that no net encroachment occurs (SWFWMD 2009). 

3 Building in floodplains may result in two effects: (1) encroachment up to the 100-year floodplain 

4 elevation above the seasonal high-water level (SHWL) and (2) encroachment below the SHWL 

5 in natural depressions including wetlands and sloughs. The first of these effects results in loss 

6 of detention storage capacity of the floodplain and the second results in loss of retention storage 

7 capacity of the landscape. The second of these effects is also called historic basin storage 

8 (HBS). The SWFWMD’s bases of review regarding water quantity for Environmental Resource 

9 Permit (ERP) applications do not allow any net encroachment into the floodplain up to the 

10 100-year event (SWFWMD 2009). If compensating floodplain storage is required for a project, it 

11 must be provided between the SHWL and the 100-year flood level. In addition, the SWFWMD 

12 also requires replacement or mitigation of the loss of HBS because of the project 

13 (SWFWMD 2009). 

14 PEF performed a bounding analysis to conservatively estimate the loss of floodplain storage 

15 because of building and fill needed for the LNP facilities (CH2M HILL 2009a). PEF used a high16 resolution digital elevation data set for the LNP site, Federal Emergency Management Agency 

17 (FEMA) Flood Insurance Rate Maps (FIRM), and a map of LNP facilities including the blowdown 

18 pipeline and transmission-line corridor to estimate the areas, called floodplain map units, where 

19 floodplain loss would occur because of building. PEF defined the floodplain fill and the HBS as 

20 the volumes of fill above and below, respectively, the seasonal high groundwater (SHGW) 

21 elevation (CH2M HILL 2009a). PEF estimated the SHGW elevation using wetland, soil, and 

22 hydrologic information for connected floodplain map units (CH2M HILL 2009a). PEF did not 

23 consider floodplain storage loss in isolated or unconnected floodplain map units. PEF stated 

24 that increased flood levels because of filling the isolated floodplain map units would be wholly 

25 contained on the LNP site. The review team determined that this is a reasonable assumption 

26 because the area of the isolated floodplain units on the LNP site is relatively minor (less than 7 

27 percent) compared to that of the connected floodplain units. Flood storage currently provided 

28 by the isolated or non-contiguous floodplain units would run off and would be collected in the 

29 stormwater ponds after construction of the LNP facilities where it would infiltrate into the soil. 

30 PEF has performed a more detailed hydrologic and hydraulic modeling of the LNP site as part of 

31 the requirements of the Conditions of Certification for the LNP Units 1 and 2 

32 (FDEP 2010a and PEF 2010c). The analysis is currently under review by the FDEP. 

33 PEF estimated the 100-year floodplain elevation for the floodplain map units using the high34 resolution 1-ft ground elevation contours and the FEMA FIRMs. PEF estimated the normal pool 

35 elevation, defined as the elevation of standing water in wetlands for several weeks during the 

36 wet season, for the floodplain map units based on site knowledge which required site inspection 

37 to qualitatively determine historical wetland water levels. The normal pool elevation for each 

38 floodplain map unit was set 1 ft above the average bottom elevation of the unit. PEF estimated 
Construction Impacts at the Proposed Site 

Draft NUREG-1941 4-20 August 2010 

1 the floodplain fill volume to be 252.4 ac-ft and the HBS to be 73.9 ac-ft because of building of 

2 LNP facilities (CH2M HILL 2009a). 

3 PEF estimated the rise in level of the 100-year flood because of the LNP encroachment on the 

4 floodplain by distributing the lost volume on the remaining floodplain area within the LNP site 

5 boundary downstream of the facilities (CH2M HILL 2009a). The estimated rise is 0.22 ft. 

6 PEF also identified upland areas that may be available for compensating the floodplain storage 

7 and HBS loss considering habitat data, land use and cover classifications, natural areas 

8 inventory, and other resources (CH2M HILL 2009a). PEF estimated that up to 320.9 ac-ft of 

9 compensation volume above SHGW elevation could be provided on the LNP site on a 322-ac 

10 area (CH2M HILL 2009a). Because floodplain storage loss is estimated to be 252.4 ac-ft, PEF 

11 concluded that volume compensation for floodplain storage loss could be provided onsite. PEF 

12 stated that compensation for HBS could be provided by excavating below the SHGW elevation 

13 in the same areas where floodplain compensation loss is provided (CH2M HILL 2009a). The 

14 area required for compensating 73.9 ac-ft with an average excavation of 0.5 ft would be 148 ac, 

15 which is only a portion of the 322 ac available for compensation. 

16 The review team determined, based on its review of Florida regulations and PEF’s description of 

17 the floodplain storage loss compensation, that sufficient onsite area is available to meet the 

18 requirements of the FDEP and SWFWMD (Florida Administrative Code 40D-4.301 and 

19 40D-4.302 and SWFWMD 2009). 

20 Hydrologic alterations also will result from grading and building a series of stormwater-drainage 

21 ditches. These surface modifications will result in changes in the rate and distribution of surface 

22 recharge and may affect groundwater levels beneath the LNP site. Stormwater-drainage 

23 ditches will direct runoff into three stormwater-retention and infiltration ponds. Any excess 

24 rainfall will be pumped to the cooling-tower blowdown basin and, if necessary, discharged with 

25 blowdown. The retention ponds are designed for a 25-year, 24-hour rainfall event. During 

26 larger storm events, pond overflow will be released through broad-crested weir emergency 

27 spillways. 

28 The local groundwater aquifers that could be affected by the building of proposed LNP Units 1 

29 and 2 are the surficial and Upper Floridan aquifers. Surface modifications will alter the 

30 thickness of the surficial aquifer and the nature and location of recharge and discharge zones. 

31 During building, anticipated hydrologic alterations include temporary changes in the 

32 groundwater levels associated with dewatering of excavations for the proposed structures. The 

33 current conceptual foundation design calls for substantial dewatering of each nuclear island 

34 area (containing the containment vessel, shield building, and auxiliary building) to depths of 

35 approximately 100 ft below the existing grade (PEF 2009b). Under this design, subsurface 

36 grouting and diaphragm walls would be used to isolate the excavation and minimize the impacts 

37 of dewatering on surrounding groundwater levels. Grouted diaphragm walls would be installed 
Construction Impacts at the Proposed Site 

August 2010 4-21 Draft NUREG-1941 

1 to minimize lateral groundwater inflow, and grout would be injected into the carbonate rock 

2 below the planned excavation depth to minimize upward groundwater flow into the excavation. 

3 These two engineered barriers would allow the excavation to be dewatered and minimize the 

4 amount of drawdown that occurs outside the grouted excavation. Thus, the impact of nuclear 

5 island dewatering on the surrounding groundwater system is expected to be minor. 

6 Localized, short-term, building-related dewatering of the surficial aquifer outside the nuclear 

7 island excavation (e.g., dewatering of shallow trenches for pipelines and other utilities) would 

8 occur over a relatively small portion of the LNP site, primarily within the footprint of the LNP site 

9 boundaries and along the makeup-water and blowdown pipeline corridor. These are areas 

10 where existing wetlands would be drained or backfilled, and affected wetlands will be mitigated 

11 through Florida’s Regional Offsite Mitigation Area plan. Wetlands located outside these impact 

12 areas would not be significantly affected by building-related dewatering. Once final designs are 

13 submitted, these dewatering activities will require approval from FDEP and the Southwest 

14 Florida Water Management District (SWFWMD). 

15 The Upper Floridan aquifer may be affected because water for building activities would be 

16 obtained from wells screened within this aquifer. Building-related groundwater-use impacts are 

17 discussed in Section 4.2.2. Alteration of groundwater elevations resulting from building-related 

18 groundwater usage were evaluated based on the results of a local-scale groundwater flow 

19 model (see discussion in Sections 2.3.1.2 and 4.2.2). Effects of groundwater withdrawals 

20 during construction were not simulated. Instead, conclusions were drawn based on modeling of 

21 withdrawals during plant operation. These withdrawals will be much greater than withdrawals 

22 during construction. Results from the predictive simulations of withdrawals during plant 

23 operation indicate that groundwater withdrawal from the Upper Floridan aquifer at a rate of 1.5 

24 Mgd would, after 1 year of pumping, result in surficial aquifer drawdowns of as much as 1.5 ft in 

25 areas where wetlands are present (Figure 4-1). A rate of 1.5 Mgd was used for the simulations 

26 because the wellfield would be permitted to withdraw that much water (FDEP 2010a). PEF 

27 indicates that the average water withdrawal rates for building activities would be 275,000 gpd 

28 and maximum rates would be 550,000 gpd, so drawdowns in the surficial aquifer are expected 

29 to be less than those predicted in the simulations. As noted in Section 2.3.1.2, water levels in 

30 the surficial aquifer have been observed to fluctuate 5 ft in a year at the LNP site due to normal 

31 seasonal variability (see discussion of potentiometric surfaces in Section 2.3.1.2). 

32 Another potential hydrologic alteration that was considered in the evaluation was mining of fill 

33 material used during building activities at the LNP site. Whereas PEF has not made a final 

34 determination regarding the source of the fill material for the LNP site, to provide the reader with 

35 additional context of the potential impacts of fill mining, the review team considered the impacts 

36 of mining at the proposed Tarmac King Road Limestone Mine. Due to its proximity to the LNP 

37 site, this evaluation will provide maximal impact in the vicinity of the LNP site with regards to 

38 hydrological alterations. The proposed mine would be located 1 mi west of the intersection of 

39 US-19 and King Road in Levy County, about 2 mi west of the LNP site. Additional information
Draft NUREG-1941 4-22 August 2010 

Construction Impacts at the Proposed Site 

1 

Figure 4-1. Simulated Incremental Surficial Aquifer Drawdown for 1 Year of Pumping at the Annual Average Usage 2 

Rate (PEF 2010a) 3 
Construction Impacts at the Proposed Site 

August 2010 4-23 Draft NUREG-1941 

1 regarding the mine is provided in Chapter 7. Tarmac has applied for permits to begin site 

2 development in 2011, with operations beginning in 2013. This limestone mine is expected to 

3 use less than 1 Mgd of water (PEF 2009a), which is comparable to LNP operational usage. 

4 Although no evaluation of the impacts of water use at the Tarmac mine on groundwater levels 

5 and wetlands was performed, the review team determined that the effects would be of the same 

6 order of magnitude as those predicted for the LNP wellfield. As discussed in Section 5.2.2.2, a 

7 modeling evaluation indicated that average LNP operational groundwater use (1.58 Mgd) 

8 represents only a small percentage (0.8 percent) of the total water flux (208 Mgd) moving 

9 through the groundwater model domain. Assuming similar geohydrologic conditions at the 

10 Tarmac site, the review team determined that the proposed water use would also be a relatively 

11 small amount of the flux moving through the groundwater system. The Tarmac mine would not 

12 be developed solely for providing fill material to the LNP site, therefore only a portion of the 

13 impact of the mine would be considered directly attributable to the LNP project, if the Tarmac 

14 mine was used as the source of fill at the LNP site. The FDEP conditions of certification require 

15 PEF to develop an environmental monitoring plan, which includes a hydraulic testing program 

16 during drilling and installation of the proposed water-supply wells to obtain site-specific hydraulic 

17 property estimates and determine whether the wellfield can meet groundwater usage impacts 

18 without significantly affecting water levels in the surficial aquifer. The FDEP Conditions of 

19 Certification require that operational impacts of the LNP wellfield limit drawdowns in the surficial 

20 aquifer to levels that ensure no adverse impacts on wetlands. 

21 During installation of the proposed new transmission lines (discussed in Section 4.1.2), 

22 hydrologic alterations to offsite surface waterbodies could occur. No surface or groundwater 

23 would be used in the installation of these lines. Although the exact routes are not yet 

24 determined, the lines would cross numerous waterbodies and wetlands. Best management 

25 practices (BMPs) would be applied for erosion and sedimentation control. 

26 In summary, the hydrologic alterations associated with construction and preconstruction 

27 activities at and near the LNP site would include dredging for the intake structure, barge slip, 

28 and discharge pipeline; altering the surface topography; changes to runoff and infiltration 

29 characteristics (e.g., site grading, laydown yards, stormwater-collection trenches, and basins); 

30 dewatering the excavations for the nuclear island and intake structure; and groundwater 

31 withdrawal to supply water to building activities. Offsite hydrologic alterations are associated 

32 with the proposed new transmission-line corridors where they cross wetlands or surface waters. 

33 The impacts of hydrologic alterations resulting from both onsite and offsite activities would be 

34 localized and temporary, and the required permits, certifications, and the SWPPP call for the 

35 implementation of BMPs to minimize impacts. 

36 4.2.2 Water-Use Impacts 

37 The impacts of building a nuclear power plant on water use are similar to impacts that would be 

38 associated with the development of any large industrial site. This section includes identification 
Construction Impacts at the Proposed Site 

Draft NUREG-1941 4-24 August 2010 

1 of the proposed activities associated with building LNP Units 1 and 2 that could affect water use, 

2 and analysis and evaluation of proposed practices to minimize adverse impacts on water use by 

3 these activities. The impacts on the use of surface water and groundwater are discussed in this 

4 section. Water quality impacts on surface water and groundwater are discussed in Sections 

5 4.2.3.1 and 4.2.3.2, respectively. Information in this section is drawn from the ER (PEF 2009a) 

6 and supplemental information provided by PEF, as referenced. 

7 PEF does not intend to use surface-water during building of proposed LNP Units 1 and 2. 

8 Raw water for building activities (e.g., soil compaction, dust and erosion control, and concrete 

9 mixing) will be withdrawn from onsite water-supply wells completed in the Upper Floridan 

10 aquifer. As discussed in Section 5.2.2.2, LNP operational usage of groundwater from the Upper 

11 Floridan aquifer is small relative to the overall model water balance. Because groundwater 

12 usage while building the proposed units is expected to be less than half that used during plant 

13 operations and the review team concludes that impacts of operational groundwater usage would 

14 be minor, building-related groundwater-use impacts also are expected to be minor. 

15 Based on the information provided by PEF and the review team’s independent evaluation, the 

16 review team concludes that the water-use impacts of construction and preconstruction activities 

17 would be SMALL, and mitigation beyond the State of Florida’s Conditions of Certification (FDEP 

18 2010a) would not be warranted. Based on the preceding analysis and because NRC-authorized 

19 construction activities represent only a portion of the analyzed activities, the NRC staff 

20 concludes that the impacts of NRC-authorized construction activities would be SMALL. The 

21 NRC staff also concludes that mitigation beyond the FDEP conditions of certification would not 

22 be warranted. 

23 4.2.3 Water-Quality Impacts 

24 Impacts on the quality of the water resources of the LNP site are described for surface-water 

25 and groundwater features that are most directly affected by building activities. 

26 4.2.3.1 Surface-Water-Quality Impacts 

27 Surface-water quality of nearby waterbodies would most likely be affected by surface-water 

28 runoff from the site during preparation and building of the facilities. Dredging in the CFBC to 

29 facilitate building of the intake structure, barge slip, and discharge line could also affect surface30 water quality. The FDEP requires PEF to develop an erosion and sediment control plan and a 

31 SWPPP (PEF 2009a). The plans would be developed prior to initiation of site disturbance 

32 activities and would identify control measures to be used during site preparation activities to 

33 mitigate erosion and control stormwater runoff (PEF 2009a). 
Construction Impacts at the Proposed Site 

August 2010 4-25 Draft NUREG-1941 

1 Building of some LNP facilities would occur within the 100-year floodplain as described in 

2 Section 4.2.1. As stated above, the review team determined, based on its review of Florida 

3 regulations and PEF’s description of the floodplain storage loss compensation, that sufficient 

4 onsite area is available to meet the requirements of the FDEP and SWFWMD (Florida 

5 Administrative Code 40D-4.301 and 40D-4.302 and SWFWMD 2009). Therefore, the increase 

6 in the 100-year flood elevation downstream of the LNP site would not be noticeable after 

7 compensation is provided for floodplain fill and HBS losses. 

8 The plan would identify BMPs to control the impacts of stormwater runoff. As discussed in 

9 Chapter 3, PEF would install three stormwater retention and infiltration ponds. Drainage ditches 

10 would be built to control delivery of sediment from the disturbed area to onsite waterbodies. 

11 Sediment carried with stormwater from the disturbed area would settle in the retention and 

12 infiltration ponds, and the stormwater would infiltrate into the shallow aquifer. Because the 

13 delivery of sediment from the disturbed area would be minimized by the use of BMPs and 

14 controlled by the stormwater ponds, the effects on off-site water quality are expected to be 

15 minor. The building of the stormwater drainage ditches would also be temporary and sediment 

16 delivery during this activity would also be minimized by use of BMPs and would remain 

17 localized. Therefore, the effects on off-site water quality from the building of stormwater 

18 drainage ditches are expected to be minor. 

19 Dredging activities in the CFBC for the intake structure, the barge slip, and the blowdown 

20 discharge line may also result in disturbance of sediments and in a potential increase of turbidity 

21 near these locations. As discussed in Chapter 3, a temporary cofferdam and turbidity curtain 

22 would be used during excavation of the intake structure to control water-quality impacts. For the 

23 intake structure, barge slip, and blowdown discharge line installation, the hydrological 

24 alterations resulting from site development would be localized and temporary. Permits, 

25 certifications, and SWPPP require the implementation of BMPs to minimize impacts. Based on 

26 information provided by PEF and the review team’s independent evaluation, the review team 

27 concludes that the impacts of construction and preconstruction activities on surface-water 

28 quality at the site would be temporary and SMALL, and no further mitigation, other than the 

29 BMPs discussed, would be warranted. Based on the preceding analysis and because NRC30 authorized construction activities represent only a portion of the analyzed activities, the NRC 

31 staff concludes that the impacts of NRC-authorized construction activities on surface-water 

32 quality would be temporary and SMALL, and no mitigation other than BMPs would be 

33 warranted. 

34 4.2.3.2 Groundwater-Quality Impacts 

35 Dewatering of the foundation excavations would be required to build the powerblock (which 

36 includes the reactor building, the radioactive waste building, the turbine building, service 

37 buildings, and associated structures). Water from the excavations would be intermittently 

38 pumped and discharged to temporary retention basins and settling ponds, which allow 
Construction Impacts at the Proposed Site 

Draft NUREG-1941 4-26 August 2010 

1 discharge water to infiltrate back into the surficial aquifer. Measures would be implemented, 

2 such as sedimentation traps or filtration, to ensure that erosion or siltation caused by the 

3 dewatering would be negligible (PEF 2009a). The potential also exists for stormwater infiltration 

4 to transport pollutants (e.g., gasoline) to the surficial aquifer. Impacts on groundwater quality 

5 would be monitored and controlled using the Florida BMPs for stormwater management 

6 (FDEP 2010b). As such, the review team expects these impacts to be minor. 

7 PEF committed to complying “with federal, state, and local laws, ordinances, and regulations 

8 intended to prevent or minimize adverse environmental effects (for example, solid waste 

9 management, erosion and sediment control, air emissions, noise control, stormwater 

10 management, spill response and cleanup, and hazardous waste management)” (PEF 2009a). 

11 The Conditions of Certification issued by the State of Florida require that: 

12 1. If hazardous substances are used in the construction or maintenance of the Certified 

13 Project, PEF shall provide the DEP with reasonable assurances that such hazardous 

14 substances will not enter stormwater drains or waterbodies. 

15 2. Fuel and other petroleum product spills that enter stormwater drains or waterbodies, or fuel 

16 and other petroleum product spills that are in excess of 25 gallons shall be contained, 

17 cleaned up, and immediately reported to the appropriate DEP District Water Resources 

18 Office. A copy of any submittal by PEF pursuant to this paragraph, for any spills located in 

19 Pinellas County, shall be provided to Pinellas County for informational purposes. Smaller 

20 ground surface spills shall be cleaned up as soon as practical (FDEP 2010a). 

21 Building-related groundwater withdrawals from the Upper Floridan aquifer, although unlikely, 

22 have the potential to decrease water levels at the site and induce lateral saltwater intrusion from 

23 the CFBC and vertical migration of saline waters from deeper Floridan aquifer intervals. The 

24 impacts on groundwater quality during building activities are bounded by the impacts during 

25 operation of the LNP Units 1 and 2, as discussed in Section 5.2.3.2, because operational 

26 groundwater usage is greater than that during building activities. Therefore, the review team 

27 concludes that groundwater-quality impacts during building activities would be minor, and 

28 mitigation beyond the conditions of certification would not be warranted. 

29 Based on the consideration of potential impact from dewatering, spills, and salt water intrusion; 

30 information provided by PEF; and the review team’s independent evaluation, the review team 

31 concludes that the groundwater quality impacts at the site from construction and preconstruction 

32 activities would be SMALL, and no further mitigation, other than BMPs and the conditions of 

33 Florida Site Certification, would be warranted. Based on the preceding analysis and because 

34 NRC-authorized construction activities represent only a portion of the analyzed activities, the 

35 NRC staff concludes that groundwater-quality impacts of NRC-authorized construction activities 

36 would be SMALL. 
Construction Impacts at the Proposed Site 

August 2010 4-27 Draft NUREG-1941 

1 4.2.4 Water Monitoring 

2 Prior to initiating building activities, PEF would be required to develop a SWPPP (FDEP 2010a). 

3 During building activities for Units 1 and 2, the SWPPP would be in effect and may include a 

4 monitoring program. 

5 Section 6.3 of the ER (PEF 2009a) describes the hydrologic monitoring program that would be 

6 used to control potential impacts on groundwater caused by site preparation and building 

7 activities and identifies alternatives or engineering measures that could be implemented to 

8 reduce potential adverse impacts. Most pre-application monitoring wells are located within the 

9 disturbance footprint and would need to be decommissioned prior to the start of building 

10 activities. Hydrologic measurements would continue to be collected in the four pre-application 

11 monitoring wells that would not be disturbed by building activities (MW-1S, MW-2S, MW-3S, 

12 and MW-4S). In addition, a hydrologic monitoring program during building activities would be 

13 implemented to monitor dewatering impacts at the two nuclear island excavations. This 

14 program would be designed to monitor head differential between the inside and outside of the 

15 diaphragm wall, as well as the uplift pressure on the bottom of the excavation (PEF 2009b). 

16 Section 6.6 of the ER (PEF 2009a) describes the chemical monitoring program. The objective 

17 of pre-disturbance and preoperational monitoring is to characterize the chemical quality of 

18 groundwater at the site and provide a basis from which to identify the impacts resulting from 

19 building activities and plant operations. While the LNP is being built, groundwater chemistry 

20 would be monitored quarterly in the four pre-application monitoring wells mentioned above. 

21 Sampling and analysis requirements for these monitoring events would be the same as those 

22 specified for pre-application monitoring (PEF 2009a). 

23 4.3 Ecological Impacts 

24 This section describes the potential impacts on ecological resources resulting from development 

25 of proposed LNP Units 1 and 2 and associated offsite facilities, including transmission lines 

26 required to tie into the Florida electrical grid system. Impacts on terrestrial resources are 

27 presented in Section 4.3.1, and impacts on aquatic resources are addressed in Section 4.3.2. 

28 4.3.1 Terrestrial and Wetland Impacts 

29 This section evaluates impacts on terrestrial and wetland resources from site-preparation 

30 activities and build-out for the proposed LNP Units 1 and 2 and associated offsite facilities. 

31 4.3.1.1 Terrestrial Resources – Site and Vicinity 

32 Most terrestrial impacts would occur near the center of the 3105-ac LNP site where the two 

33 reactors and ancillary power production facilities would be built. Additional impacts would 
Construction Impacts at the Proposed Site 

Draft NUREG-1941 4-28 August 2010 

1 extend to the southeast corner of the site within a corridor supporting the heavy-haul road, the 

2 blowdown and makeup pipelines, and four 500-kV transmission lines. As described in Section 

3 2.4.1, terrestrial habitats throughout the site have already been substantially altered by intensive 

4 commercial forest management over many decades. For the purposes of the following analysis 

5 (excluding transmission line impacts included as part of Section 4.3.2.2), all impacts that lie 

6 within the zone of disturbance indicated on proposed site-development plans (see Figure 3-1) 

7 are treated as permanent impacts. Temporary impacts are estimated to consist of clearing 

8 vegetation in a 50-ft buffer around the perimeter of the depicted development activities. 

9 Cover Types (Habitats) 

10 Development of LNP facilities would require permanent or temporary disturbance or removal of 

11 existing vegetation from approximately 776.6 ac (25 percent) of the LNP site. Impacts would 

12 result from clearing and grubbing, grading, excavation, and the placement of fill. Permanent 

13 and temporary impacts estimated by FLUCFCS cover type are presented in Table 4-4. 

14 Table 4-4. Extent of Project Development-Related Impacts on Cover Types of the LNP Site 

Cover Type (Habitat) 

FLUCFCS 

Code(a)

Approximate 

Existing 

Area on LNP 

Site (Acres) 

Permanent Impacts Temporary Impacts 

Acres 

Percent 

of Total 

Site Acres 

Percent 

of Total 

Site 

Coniferous plantations 441 962.9 277.5 8.9 56.6 1.8 

Wet planted pine 629 812.7 135.0 4.3 39.5 1.3 

Cypress 621 402.6 53.8 1.7 13.2 0.4 

Mixed wetland hardwoods 617 317.6 10.2 0.3 2.7 0.1 

Treeless hydric savanna 646 274.4 73.5 2.4 19.1 0.6 

Wetland forested mixed 630 156.4 29.0 0.9 7.4 0.2 

Other open lands (rural) 260 106 31.0 1.0 9.1 0.3 

Freshwater marshes 641 23.5 12.0 0.4 0.6 >0.1 

Hardwood conifer mixed 434 16 0 0 0 0 

Wet prairie 643 14.3 5.1 0.2 1.5 >0.1 

Upland coniferous forest 410 11 0.1 >0.1 0.1 >0.1 

Utilities 830 4.0 0 0 0 0 

Pine flatwoods 411 3.0 0 0 0 0 

Shrub and brushland 320 0.6 0 0 0 0 

Total 3105 627.0 20.2 149.6 4.8 

Sources: PEF 2009c, e; FDOT 1999. 

(a) FLUCFCS = Florida Land Use, Cover and Forms Classification System. 
Construction Impacts at the Proposed Site 

August 2010 4-29 Draft NUREG-1941 

1 Permanent losses would account for about 627.0 ac, with impacts on habitat that has been 

2 altered by commercial forest management accounting for the greatest losses. Approximately 

3 277.5 ac of coniferous plantations (FLUCFCS 441) and 135.0 ac of wet planted pine 

4 (FLUCFCS 629) would be permanently lost; as well as 73.5 ac of treeless hydric savanna 

5 (FLUCFCS 646) and 31.0 ac of other open lands (rural) (FLUCFCS 260) (which have been 

6 recently clear-cut but not yet replanted with trees). Permanent impacts on natural cover types 

7 (those not substantially influenced by commercial forest management) would be greatest for 

8 cypress swamps (FLUCFCS 621; 53.8 ac), and wetland forested mixed (FLUCFCS 630; 29.0 

9 ac). Permanent impacts to remaining natural cover types onsite would be minimal. 

10 Temporary impacts would occur on about 149.6 ac of the site, primarily to cover types that have 

11 been altered by commercial forest management including coniferous plantations (FLUCFCS 

12 441; 56.6 ac); wet planted pine (FLUCFCS 629; 39.5 ac); treeless hydric savanna (FLUCFCS 

13 646; 19.1 ac); and other open lands (rural) (FLUCFCS 260; 9.1 ac) (Table 4-4). Temporary 

14 impacts on natural cover types onsite would be greatest for cypress (FLUCFCS 621; 13.5 ac) 

15 and wetland forested mixed cover (FLUCFCS 630; 7.4 ac). Impacts on other natural cover 

16 types would be relatively minor. Temporarily disturbed areas would be regraded to pre-existing 

17 contours after site-development activities have ceased. Uplands would be seeded in 

18 accordance with project-developed sedimentation and erosion-control plans, while wetlands 

19 would be allowed to regenerate naturally from the existing wetland seed bank (PEF 2009c, e). 

20 Refer to Section 4.3.1.7 for a description of the mitigation planning effort and the BMPs PEF 

21 proposes to use to restore temporarily disturbed lands. 

22 In Table 4-5, estimated losses were compared to the availability of similar FLUCFCS cover 

23 types within a 6-mi radius of the LNP site to assess the extent of habitat losses to the overall 

24 occurrence of biotic communities in the project vicinity. The proposed permanent and 

25 temporary impacts would affect only cover types that are common in the project vicinity. Losses 

26 for each affected cover type would be relatively minor compared to overall occurrence in the 

27 project vicinity, with no impact on a cover type exceeding 4.9 percent of its availability in the 

28 project vicinity. The largest proportional impacts would occur to mixed wetland hardwoods 

29 forest (FLUCFCS 617; 4.9 percent) and coniferous plantations (2.6 percent as represented by 

30 the combined acreage of coniferous plantations and wet planted pine). For comparative 

31 purposes with the project vicinity, the acreage of wet planted pine (FLUCFCS 629) on the LNP 

32 site was combined with coniferous plantations (FLUCFCS 441) because this subcategory of 

33 pine plantation was not distinguished in the FLUCFCS land cover mapping for the project 

34 vicinity. Impact on treeless hydric savanna (FLUCFCS 646), represented on the LNP site by 

35 recently clear-cut forest stands on low-lying wetland flats not yet replanted to conifers, is not 

36 included with this project vicinity analysis. Very little natural treeless hydric savanna (which is 

37 also referred to as mixed scrub-shrub wetland) is identified from the FLUCFCS land cover 

38 mapping for the project vicinity.
Construction Impacts at the Proposed Site 

Draft NUREG-1941 4-30 August 2010 

1 Table 4-5. Extent of Project Development-Related Impacts on Cover Types in the LNP Vicinity 

Cover Type (Habitat) 

FLUCFCS 

Code(a)

Availability 

in Vicinity 

(ac) 

Permanent 

LNP Site 

Impacts 

(ac) 

Temporary 

LNP Site 

Impacts 

(ac) 

Total 

Impact 

Relative to 

Availability 

in Vicinity 

(%) 

Other open lands (rural) 260 5251.7 31.0 9.1 0.8 

Upland coniferous forest 410 8187.9 0.1 0.1 >0.1 

Coniferous plantations(b)

 441&629 19,724.5 412.5(c) 96.1(c) 2.6 

Mixed wetland hardwoods 617 262.8 10.2 2.7 4.9 

Cypress 621 5331.5 53.8 13.2 1.3 

Wetland forested mixed 630 5245.5 29.0 7.4 0.7 

Freshwater marshes 641 2126.3 12.0 0.6 0.6 

Wet prairies 643 313.0 5.1 1.5 2.1 

Treeless hydric savanna(d) 646 92.5 73.5 19.1 n/a(d)

Other FLUCFCS cover types n/a 39,285.3 0 0 0 

Total 72,381.4 627.0 149.6 

Sources: PEF 2009f, FDOT 1999. 

(a) FLUCFCS = Florida Land Use, Cover and Forms Classification System. 

(b) All tree plantations were assumed planted to pine and classified as coniferous plantations (FLUCFCS 441). 

(c) Wet planted pine (FLUCFCS 629) identified for the LNP site was combined with coniferous plantations because 

this subcategory of tree plantations was not distinguished in the FLUCFCS land cover mapping for the project 

vicinity. 

(d) Treeless hydric savanna (FLUCFCS 646) from the LNP site is not included in this analysis because this custom 

cover type is an artifact of logging practices on the site. 

n/a = not applicable 

2 The treeless hydric savanna classified during site-specific mapping of the LNP site is an artifact 

3 of forest-management activities. 

4 Approximately 75 percent of the LNP site would remain undeveloped, providing a vegetated 

5 buffer around the centrally located LNP facilities. PEF’s proposed wetland mitigation concept 

6 calls for ceasing commercial forest management over approximately 1549 ac of undeveloped 

7 areas remaining on the LNP site and part of a property owned by PEF directly south of the LNP 

8 site, followed by rehabilitating pine plantations and other disturbed habitats through a series of 

9 vegetation management and restorative processes to reestablish plant communities more 

10 functionally similar to native upland and wetland habitats (Entrix 2010). Restorative processes 

11 would include selective tree thinning, prescribed fire, and hydrologic restoration to achieve high 

12 ecological value. A more detailed description of the wetland mitigation planning effort is 

13 provided in Section 4.3.1.7. PEF has not indicated how it would manage the other remaining 

14 undeveloped land on the LNP site or PEF property to the south. 
Construction Impacts at the Proposed Site 

August 2010 4-31 Draft NUREG-1941 

1 Wetlands 

2 Impacts on wetlands from project development activities on the LNP site would include filling, 

3 erosion, sedimentation, alterations to hydrology, and clearing of vegetation. Wetlands located 

4 within and adjacent to the limits of site-preparation activities may be subject to three general 

5 types of impacts: 1) permanent fill impacts converting wetlands to developed uplands, where all 

6 wetland functions are lost indefinitely; (2) temporary disturbance impacts where some or all 

7 wetland functions are restored after site development is completed; and (3) partial impacts from 

8 the clearing of trees along final transmission-line rights-of-way where nonforested wetland 

9 functions would be retained. Impacts on wetlands were quantified by overlaying the site plan 

10 onto the wetland delineation for the LNP site and evaluating the likely changes to wetland 

11 functions. Review by the USACE and FDEP of wetland delineations performed by PEF’s 

12 consultants is ongoing. Final approvals of the determination of the presence of jurisdictional 

13 waters, including the delineation of wetlands are expected from the USACE and FDEP by the 

14 end of 2010. 

15 Wetlands make up about 64.5 percent (2001.5 ac) of the 3105-ac LNP site (Table 4-6). 

16 Although impacts on wetlands were avoided and minimized to the extent practicable during 

17 project design, wetland impacts during project development are unavoidable. This is a 

18 consequence of the large amount and broad distribution of wetlands present on the LNP site, as 

19 well as the numerous safety, operational, and engineering constraints required to site a nuclear 

20 facility. Approximately 318.6 ac of wetlands on the LNP site would be permanently filled, 

21 representing a permanent loss of approximately 15.9 percent of the total wetlands onsite (Table 

22 4-6 and Figure 4-2). Of the wetland cover types on the site, the wet planted pine cover type 

23 (FLUCFCS 629) would sustain the greatest amount of permanent wetland impact (135 ac), 

24 followed by treeless hydric savanna (FLUCFCS 646) (73.5 ac). These wetlands have been 

25 historically degraded by commercial forest management, generally are of lower quality, and 

26 provide reduced functions relative to natural wetland cover types. However, permanent impacts 

27 on about 110 ac of higher-quality wetland systems would occur as well. Losses of native 

28 wetland cover types would include approximately 53.8 ac of cypress (FLUCFCS 621), 29.0 ac of 

29 wetland forested mixed (FLUCFCS 630), 10.2 ac of mixed wetland hardwoods (FLUCFCS 617), 

30 12.0 ac of freshwater marsh (FLUCFCS 641), and 5.1 ac of wet prairie (FLUCFCS 643). 

31 Temporary impacts would affect about 84.0 ac of wetlands on the LNP site, with wet planted 

32 pine (39.5 ac) and treeless hydric savanna (19.1 ac) accounting for more than two-thirds of the 

33 temporary wetland impacts (Table 4-6). Natural wetlands affected would include about 23.3 ac 

34 of wetland swamps (i.e., cypress, wetland forested mixed, and mixed wetland hardwoods) and 

35 minor amounts of wet prairie and freshwater marshes. Wetlands subject to temporary impacts 

36 would be regraded to pre-existing contours after site development has ceased and allowed to
Draft NUREG-1941 4-32 August 2010 

Construction Impacts at the Proposed Site 1 Table 4-6. Extent of Project Development Impacts to Wetlands on the LNP Site 2 Wetland Cover Type FLUCFCS Code(a) Existing Area (acres) Permanent Impacts Temporary Impacts Acres Percent of Total Site Wetlands Acres Percent of Total Site Wetlands Wet planted pine 629 812.7 135.0 6.7 39.5 2.0 Cypress 621 402.6 53.8 2.7 13.2 0.7 Mixed wetland hardwoods 617 317.6 10.2 0.5 2.7 0.1 Treeless hydric savanna 646 274.4 73.5 3.7 19.1 1.0 Wetland forested mixed 630 156.4 29.0 1.4 7.4 0.4 

Freshwater marshes 641 23.5 12.0 0.6 0.6 >0.1 Wet prairie 643 14.3 5.1 0.3 1.5 0.1 Total 2001.5 318.6 15.9 84.0 4.2 Sources: PEF 2009e, FDOT 1999. (a) FLUCFCS = Florida Land Use, Cover and Forms Classification System. 
Construction Impacts at the Proposed Site 

August 2010 4-33 Draft NUREG-1941 

1 

2 Figure 4-2. Extent of Project Development-Related Impacts on Delineated Wetlands of the 

3 LNP Site (PEF 2009n) 
Construction Impacts at the Proposed Site 

Draft NUREG-1941 4-34 August 2010 

1 regenerate naturally from the existing wetland seed bank (PEF 2009c, e). Refer to Section 

2 4.3.1.7 for a description of PEF’s wetland mitigation planning effort, including BMPs to restore 

3 temporarily disturbed wetlands. 

4 Temporary, localized dewatering impacts on wetlands could occur during excavation of the 

5 powerblocks for proposed LNP Units 1 and 2. Dewatering of the 75-ft deep foundation 

6 excavations would be required to build each proposed powerblock. While the foundation 

7 excavations may reach 75 feet, dewatering to support the foundation construction may go to 

8 100 feet. Measures would be taken prior to excavation to isolate and seal the dewatering areas 

9 and minimize inflow into the excavations. An impervious reinforced diaphragm wall would be 

10 installed around the perimeter of each excavation, and the underlying bedrock would be sealed 

11 by drilling and pressure grouting (PEF 2009c). Over a roughly 2 to 4-year period (depending on 

12 the extent of overlap between building the powerblocks for LNP Units 1 and 2), inflow and 

13 stormwater from within the excavations would be intermittently pumped for each nuclear island 

14 and discharged to an infiltration basin sized for the estimated flow rate (PEF 2008a, 2009c, e). 

15 These actions are expected to prevent significant drawdowns from occurring in the surficial 

16 aquifer system surrounding the excavations that supports hydrologically connected adjoining 

17 wetlands (PEF 2009c). No long-term changes to local groundwater levels are expected as a 

18 consequence of the dewatering (i.e., groundwater is expected to return to pre-disturbance levels 

19 after dewatering ceases). 

20 Temporary, localized dewatering of wetlands would also be necessary to install the blowdown 

21 and makeup pipelines and some other facilities (PEF 2009c). Dewatering of wetlands traversed 

22 by the pipeline excavations would occur in a segmented manner, with excavation, pipe 

23 installation, and backfill occurring in short duration. Pumped water would be discharged to 

24 infiltration basins situated between the excavation and adjacent wetlands to create a 

25 groundwater mound that would minimize impact on wetlands. Because of the short duration of 

26 dewatering, the shallow depth of the excavations, and the groundwater recharge achieved 

27 through groundwater mounding, no long-term impact on wetlands are expected from pipeline 

28 installation. In deeper excavations, such as for the turbine building and the circulating-water 

29 system, pumped water would be discharged to infiltration basins to recharge adjacent wetlands. 

30 PEF has committed to monitoring adjacent surface and ground water levels to ensure that 

31 dewatering impacts are minimized. If any detrimental impact on water levels affecting adjacent 

32 wetlands were detected during monitoring, mitigative measures such as drilling and grouting, 

33 sheeting, or re-design of the recharge basins would be implemented (PEF 2009c). 

34 Wetlands in the LNP vicinity are adapted to a range of seasonal and annual variability in 

35 groundwater levels, including periodic drought. Monitoring conducted by PEF documented that 

36 groundwater levels on the LNP site fluctuate by as much as 5 ft over the course of 1 year 

37 (March 2007 to March 2008), and long-term data from nearby wells suggest seasonal 

38 groundwater fluctuations of as much as 7 to 8 ft (see Section 2.3.1.2). Although dewatering 
Construction Impacts at the Proposed Site 

August 2010 4-35 Draft NUREG-1941 

1 may temporarily lower the water table supporting nearby wetlands, the effects would be short2 lived (i.e., at most 2 to 4 years, depending on the extent of overlap between building the 

3 powerblocks for LNP Units 1 and 2) and within the range of variability to which these wetlands 

4 systems have adapted. Rainfall, which is abundant during summer months (see Section 2.9.1), 

5 would help limit any temporary stress trees and other wetland flora and fauna could experience 

6 during dewatering. Consequently, no long-term adverse impacts on adjacent wetlands would 

7 be expected from dewatering during site development. PEF would be required to prepare a 

8 dewatering plan for approval by the FDEP and SWFWMD. The plan would include details of the 

9 dewatering system, discharge quantities and location, a monitoring plan, and other details 

10 needed to demonstrate that it meets the State of Florida Conditions of Certification (FDEP 

11 2010a) and complies with all applicable ERP dewatering requirements. 

12 Authorization to affect wetlands on the LNP site would require a Clean Water Act Section 404 

13 permit issued by the USACE and an ERP issued by the State of Florida. In Florida, the ERP 

14 application serves as a joint Federal/State permit application to affect wetlands. PEF submitted 

15 an ERP in June 2008 as part of the Site Certification Application, initiating the Section 404 and 

16 State permitting processes. PEF is required under the Federal and State permitting processes 

17 to avoid or minimize wetland impacts to the extent practicable and to mitigate for unavoidable 

18 wetland impacts. The Section 404 permit would also require a Clean Water Act Section 401 

19 Water Quality Certification issued by the FDEP to control the discharge of water caused by site 

20 development activities. 

21 Mitigation for unavoidable impacts on wetlands is required through both the Section 404 

22 permitting process and the ERP process. PEF has prepared a wetland mitigation plan that 

23 would compensate for the loss or impairment of functions to wetlands affected by project 

24 activities, including wetland impacts on the LNP site and those for the associated offsite facilities 

25 (Entrix 2010). By using the Florida Uniform Mitigation Assessment Methodology (UMAM) – a 

26 wetland functional analysis method used by the FDEP and the USACE to evaluate wetland 

27 functions and estimate associated mitigation requirements – PEF determined the amount of 

28 mitigation required to adequately compensate for wetland impacts. PEF’s determination would 

29 be independently verified by the USACE. Refer to Section 4.3.1.7 for a description of the 

30 wetland mitigation plan, including an account of the functional losses predicted to occur with site 

31 development and the functional gains to be incurred with implementation of the mitigation plan. 

32 Wildlife 

33 Whenever development removes or modifies large blocks of habitat, loss of wildlife is an 

34 unavoidable consequence. Although many of the wildlife habitats on the LNP site have been 

35 previously degraded by commercial forest management, the interspersion of pine plantations, 

36 wetlands, and mixed forestland on the site still provides sufficient water, food, and vegetative 

37 cover to support a variety of wildlife species. Clearing of vegetation and other site-preparation 

38 activities on the LNP site have the potential to adversely affect wildlife, either through direct 
Construction Impacts at the Proposed Site 

Draft NUREG-1941 4-36 August 2010 

1 mortality or by displacing wildlife into adjacent habitats where they must compete with other 

2 wildlife for finite resources. About 627 ac of wildlife habitat would be permanently removed, with 

3 another 149.6 ac temporarily disturbed (Table 4-4). Most of the impacts would involve lands 

4 previously altered by logging (i.e., pine plantations and other open lands), but about 116 ac 

5 (representing both permanent and temporary impacts) would involve less frequently disturbed 

6 forestlands that provide higher-quality habitat for wildlife. Wildlife species associated with these 

7 cover types and, therefore, subject to impacts are identified in Section 2.4.1. 

8 During site preparation for the LNP site, wildlife would be killed or displaced primarily as a result 

9 of heavy equipment operation during land clearing. Less mobile animals, such as reptiles, 

10 amphibians, and small mammals, are expected to incur greater direct mortality than more 

11 mobile animals, such as birds and large mammals, which would be displaced to adjacent 

12 habitats. Land clearing done during the spring/early summer nesting period for most bird 

13 species could be detrimental to nesting and reproductive success. If this work were to be 

14 carried out during non-nesting periods for most species, impacts on nesting birds could be 

15 reduced. 

16 About 75 percent (2328 ac) of the LNP site would not be physically disturbed during site 

17 development and could therefore receive displaced wildlife. Other wildlife habitats occur just 

18 outside of the perimeter of the site, including the Goethe State Forest to the north and 

19 northeast. Although these habitats could support displaced animals, increased competition for 

20 available space and resources may result in increased stress, greater susceptibility to predation, 

21 and a decline in reproductive success. Temporary wildlife population fluctuations would be 

22 expected in these habitats as competitive forces act to define new equilibrium population levels. 

23 Species that can adapt to disturbed or developed areas may readily re-colonize disturbed areas 

24 and temporarily disturbed areas after restoration. 

25 As site development is completed, remaining habitats adjacent to disturbed areas would again 

26 become available for use by wildlife that previously occupied the affected areas. Under 

27 mitigation plans proposed for the LNP site, commercial timber management would cease on 

28 approximately 1549 ac of the remaining undisturbed lands on the LNP site, wherein pine 

29 plantations and other disturbed habitats would be rehabilitated and restored to native plant 

30 communities that provide better wildlife habitat (PEF 2009e; Entrix 2010). The higher-quality 

31 habitat provided by the restored communities would allow for an increase in wildlife diversity and 

32 species population levels. Perimeter fencing that could restrict movement by medium- and 

33 large-sized animals would be limited to areas close to plant facilities, as needed to provide 

34 security or industrial safety. Fencing would not be built around the LNP property line, thereby 

35 allowing unimpeded movement by wildlife between undeveloped areas on the site and adjacent 

36 offsite habitats (PEF 2009g). Mitigation beneficial to wildlife is discussed further under Section 

37 4.3.1.7. 
Construction Impacts at the Proposed Site 

August 2010 4-37 Draft NUREG-1941 

1 Habitat fragmentation is another factor that can adversely affect wildlife resources. Habitat 

2 fragmentation occurs when development divides and isolates blocks of otherwise suitable 

3 wildlife habitat. Fragmentation can effectively reduce the amount of habitat across the 

4 landscape that is available to wildlife species requiring large blocks of contiguous suitable 

5 habitat. Wildlife occupying the remaining smaller patches may be subject to increased 

6 predation, vulnerability, and insularity (i.e., separation from other populations), and may suffer a 

7 decrease in dispersal success. The net result can be a decline in the diversity and abundance 

8 of wildlife the landscape can support. The degree to which fragmentation affects wildlife 

9 depends upon the size and isolation of the parcels being fragmented as well as the sensitivity of 

10 the species present. For example, many neotropical migratory bird species are particularly 

11 vulnerable to habitat fragmentation. They winter in tropical climates and either migrate through 

12 or nest in the subtropical or more northerly latitudes. Neotropical migrants represented on the 

13 LNP site include various vireos, flycatchers, thrushes, tanagers, and warblers (see Appendix K). 

14 The LNP site is already highly fragmented, a consequence of decades of commercial forest 

15 management that has simplified the landscape and modified wildlife habitat. Development 

16 activities would further fragment upland and wetland habitats used by wildlife. However, 

17 considering the already fragmented condition of the LNP site, the incremental impact of further 

18 fragmentation caused by site-preparation activities on wildlife and wildlife habitat is expected to 

19 be minimal. Restoration of approximately 1549 ac of undeveloped lands remaining on the LNP 

20 site and PEF-owned property directly to the south would help to mitigate the effects of 

21 fragmentation by creating a more contiguous native landscape on lands now highly altered by 

22 commercial forest management. For example, restoring native pine flatwood (FLUCFCS 411), 

23 cypress forest (FLUCFCS 621), and hardwood swamp (FLUCFCS 617 and 630) communities 

24 on the site would enhance the quality of nearby similar habitats in the Goethe State Forest. 

25 Human activities and elevated noise levels during site-development activities may also 

26 adversely affect wildlife by inducing physiological changes, nest or habitat abandonment, or 

27 behavioral modifications and by disrupting communications required for breeding or defense 

28 (Larkin 1996). It is not unusual, however, for wildlife to habituate to noise and human presence. 

29 LNP site-development activities that would generate noise include the operation of equipment 

30 such as jack hammers, pile drivers, and heavy-construction vehicles. Noise would also result 

31 from the movement of workers, materials, and equipment. Background noise levels on and 

32 near the LNP site would increase during site development, but this would primarily be limited to 

33 daytime hours (PEF 2009a). Short-term noise levels onsite could be as high as 104 dBA as 

34 measured 50 ft from the source, but it would generally range between 70 and 90 dBA at 50 ft 

35 (PEF 2009a). Except during especially limited periods of intense activities (e.g., pile driving), 

36 offsite daytime noise levels would generally remain below 65 dBA (PEF 2009a). The threshold 

37 at which birds and red foxes (used here as a surrogate for small and medium-sized mammals) 

38 are startled or frightened is 80 to 85 dBA (Golden et al. 1980). The review team expects that 

39 noise levels associated with development activities on the LNP site would generally be below 
Construction Impacts at the Proposed Site 

Draft NUREG-1941 4-38 August 2010 

1 those threshold levels at about 400 ft. Thus, overall impacts on wildlife from noise during site 

2 development are expected to be minor, temporary, and limited to onsite habitats adjacent to 

3 active operations. 

4 The erection of tall structures on the LNP site, such as cooling towers and transmission towers, 

5 and the presence of industrial cranes and other equipment pose a potential collision hazard for 

6 birds. Avian collisions are a consequence of numerous factors related to species characteristics 

7 such as flight behavior, age, habitat use, seasonal habits, and diurnal habits, as well as 

8 environmental characteristics such as weather, topography, land use, and orientation of 

9 structures. Most authors on the subject of avian collisions with utility structures agree that 

10 collisions are not a biologically significant source of mortality for thriving populations of birds 

11 with good reproductive potential (EPRI 1993). However, impacts on populations of less 

12 common bird species may be of greater biological concern. NRC (1996) reviewed monitoring 

13 data concerning avian collisions at nuclear power plants with large cooling towers and 

14 determined that overall avian mortality is low. Considering these studies, avian collisions with 

15 structures and equipment during LNP site development represent a small hazard for resident 

16 bird populations. The relatively low (56-ft-high) mechanical draft cooling towers proposed for 

17 LNP Units 1 and 2 represent a low threat to bird mortality (PEF 2009a). Noise and human 

18 activity associated with site development should also discourage bird use of active development 

19 areas. 

20 Bats are also documented to collide with building, towers and other tall structures (Erickson et 

21 al. 2002, Evans Ogden 1996). While bat mortality associated with wind energy turbines can be 

22 substantial, collision fatalities with other tall anthropogenic structures are rarely reported (Cryan 

23 and Barclay 2009). Few bat mortalities have been reported during monitoring for avian 

collisions at nuclear power plants with large cooling towers (NRC 1996)(a) 24 . While bat collisions 

25 with structures and tall construction equipment at the LNP site are possible, it is not expected to 

26 be a significant source of direct mortality. 

27 Migratory birds and their active nests are afforded protection under the Migratory Bird Treaty Act 

28 of 1918. A migratory bird is any species or family of birds that live, reproduce, or migrate within 

29 or across international borders at some point during their annual life cycle. Presently, 836 bird 

30 species are protected by the Migratory Bird Treaty Act, 58 of which are currently legally hunted 

31 as game birds (FWS 2009d). Numerous migratory bird species are expected to use habitats on 

32 the LNP site for nesting, as a winter refuge, or as a stopover site during annual migrations. The 

33 LNP site is situated within a branch of the Eastern Atlantic Flyway that crosses the Florida 

34 peninsula (FWS 2010a; Birdnature.com 2009). Proposed activities on the LNP site have the 

35 potential to affect migratory birds. Migratory birds would be expected to flee land-clearing 

36 activities and avoid direct mortality. However, if vegetation clearing occurs during the nesting 

 

(a)

 NUREG-1437 was originally issued in 1996. Addendum 1 to NUREG-1437 was issued in 1999. Hereafter, all 

references to NUREG-1437 include NUREG-1437 and its Addendum 1. 
Construction Impacts at the Proposed Site 

August 2010 4-39 Draft NUREG-1941 

1 season, nests and eggs of migratory birds could be destroyed. Migratory bird collisions with 

2 structures and tall construction equipment also are possible, but they likely would not be a 

3 significant source of direct mortality for nesting and winter residents. However, collisions with 

4 structures and equipment may be slightly higher for migrating birds that unexpectedly encounter 

5 these hazards. 

6 Increased traffic due to site workers would likely increase traffic-related wildlife mortalities over 

7 the time that workers are driving to the site. The primary access route to the LNP site would be 

8 US-19, and the peak number of workers traveling to the site would occur in 2014. If the 

9 proposed LNP project does not take place, PEF (2009a) estimates the peak traffic rate on 

10 US-19 to be 8923 daily trips in 2014. Traffic on US-19 approaching the LNP site from the north 

11 is projected to increase 15.9 percent (an additional 1418 daily trips) in 2014, with traffic 

12 approaching from the south increasing 37.1 percent (to 12,230 daily trips) in 2014 (PEF 2009a). 

13 US-19 is a large, busy highway that currently poses a significant hazard to wildlife attempting to 

14 cross it. Traffic from the LNP project would contribute to an incremental increase in traffic15 related wildlife mortalities. If road-kill rates were to exceed the rates of reproduction and 

16 immigration, local wildlife populations could suffer declines. While road kills are an obvious 

17 source of wildlife mortality, traffic mortality rates rarely limit population size (Forman and 

18 Alexander 1998). Consequently, the overall effect on local wildlife populations from increased 

19 vehicular traffic associated with LNP site development is expected to be minimal. 

20 4.3.1.2 Terrestrial Resources – Associated Offsite Facilities 

21 This section assesses impacts on terrestrial resources expected to occur with development of 

22 the associated offsite facilities including the heavy-haul road; barge slip and barge slip access 

23 road; and makeup-water and blowdown-water pipelines including associated cooling-water 

24 intake and discharge and transmission lines (Golder Associates 2008; CH2M HILL 2009a) 

25 needed to deliver the power generated by LNP into the Florida electrical grid system. For the 

26 purposes of this analysis, all impacts that lie within the zone of disturbance (i.e., the 

27 development footprint) are treated as permanent impacts. Temporary impacts are represented 

28 by a 50 foot buffer adjacent to the pipeline corridor and heavy haul road between the LNP site 

29 and the CFBC. All impacts associated with the transmission lines are treated as permanent 

30 impacts. 

31 The locations where associated facilities would be sited are known for all facilities except the 

32 transmission lines and their substations. In compliance with the PPSA, PEF (2008a, 2009a) 

33 has identified corridors (300 ft to 1 mi wide) within which the transmission lines and their 

34 substations would be sited. More than 90 percent of the new transmission lines would be 

35 collocated with existing PEF transmission lines (PEF 2009e). PEF expects to acquire 220-ft36 wide rights-of-way for the proposed 500-kV transmission lines and 100-ft-wide rights-of-way for 

37 the proposed 230-kV transmission lines (Golder Associates 2008). Once the final rights-of-way 

38 have been selected and approved by the State, FDEP would require PEF to complete more 
Construction Impacts at the Proposed Site 

Draft NUREG-1941 4-40 August 2010 

1 detailed terrestrial ecology surveys along the rights-of-ways so that unavoidable impacts from 

2 development of the transmission lines can be fully accounted for and mitigated (FDEP 2009a). 

3 PEF petitioned the State of Florida on April 29, 2010 for a modification to the currently certified 

4 corridor for the heavy-haul road, cooling-water makeup pipelines and the blowdown pipelines to 

5 be constructed between the LNP site and the CREC (Figure 3-7) (PEF 2010b). The purpose of 

6 the modification is to provide more flexibility in minimizing impacts on wetlands and other natural 

7 resources when siting these facilities, to reduce the use of State-owned lands along the CFBC, 

8 and to minimize disruption of recreational activities along the CFBC. Final right-of-way widths 

9 for each facility to be located within the corridor would remain the same. 

10 The following evaluation of potential impacts on cover types, wetlands, and wildlife is conducted 

11 subject to the above limitations. Impacts from the transmission lines are discussed in a generic 

12 manner because final rights-of-ways have not been established. Unless specifically noted, no 

13 distinction is made between transmission-line impacts up to the first substations and impacts 

14 extending beyond the first substations. 

15 Cover Types (Habitats) and Wetlands 

16 As land is cleared, graded, excavated, and filled to build the facilities, permanent and temporary 

17 impacts on vegetative communities, including wetlands, would result. Impacts for associated 

18 facilities, excluding the transmission lines (i.e., the heavy-haul road, barge slip and barge slip 

19 access road, the makeup-water and blowdown-water pipelines, and other miscellaneous 

20 impacts), are summarized in Table 4-7. Permanent losses would total about 219 ac, with the 

21 most losses incurred by upland communities such as coniferous plantations (FLUCFCS 441; 

22 66.8 ac); open land (FLUCFCS 190; 39.8 ac), which represents undeveloped land within urban 

23 areas; and mixed hardwood/conifer forest (FLUCFCS 434; 18.9 ac). Permanent wetland losses 

24 (all due to fill) would account for about 31.9 ac, as represented by the 600 series FLUCFCS 

25 cover types noted in Table 4-7. Most wetland losses would involve areas of cypress swamps 

26 (FLUCFCS 621; 12.5 ac) and freshwater marshes (FLUCFCS 641; 12.5 ac). These wetland 

27 impacts were estimated using FLUCFCS cover type mapping and would be revised once 

28 wetland delineations have been completed in these areas and jurisdictional determinations are 

29 reached by the USACE and FDEP. 

30 Temporary impacts for associated facilities, excluding the transmission lines, would affect 

31 another 29.6 ac of vegetation cover types within a 50-ft buffer adjacent to the heavy-haul road 

32 and makeup-water and blowdown pipelines (Table 4-7). This 50-ft buffer may be affected by 

33 activities such as the temporary placement of materials and a roadway (PEF 2009c). Most 

34 temporary impacts would involve cover types previously altered by land-management activities, 

35 including coniferous plantations (FLUCFCS 441; 11.8 ac) and other open lands (rural) 

36 (FLUCFCS 260; 8.4 ac), which represent unclassified agricultural land. Temporary wetland 

37 impacts would total 6.0 ac, with small impacts occurring on cypress (FLUCFCS 621), freshwater
August 2010 4-41 Draft NUREG-1941 

Construction Impacts at the Proposed Site 

Table 4-7. Extent of Development-Related Impacts on Cover Types for the Associated Offsite Facilities(a) 1 

Cover Type 

FLUCFCS 

Code(b)

Associated Facilities 

Excluding Transmission 

Lines (ac) 

Transmission Lines up to First Substation (ac) 

Transmission Lines 

Beyond First Substation 

(ac) Total Impacts 

Permanent Temporary(c) Permanent(d) Permanent(d) Permanent Temporary(c,d)

Extractive 160 4.5 0 0 0 4.5 0 Open land 190 39.8 0 0 0 39.8 0 

Other open lands (rural) 

260 15 8.4 0 0 15 8.4 

Shrub and brushland 

320 0.9 0 0 0 0.9 0 

Mixed rangeland 

330 9.4 0 0 0 9.4 0 

Upland coniferous forest 

410 5.7 1.6 0 0 5.7 1.6 

Pine flatwoods 411 3.8 0 26.8 3.4 34 0 

Longleaf pine – xeric oak 

412 0.7 0 178.6 7.4 186.7 0 

Sand pine(e) 413 0 0 54.2 1.3 55.5 0 

Xeric oak(e) 421 0 0 97.4 0.3 97.7 0 

Melaleuca 424 0 0 0.3 0.3 0 Live oak(e) 427 0 0 11.3 11.3 0 

Hardwood conifer mixed 

434 18.9 1.8 515.5 31.9 566.3 1.8 

Coniferous plantations(f)

441 66.8 11.8 245.8 1.1 313.7 11.8 

Streams and waterways 

510 1.7 1.5 0.6 3.8 0 

Lakes 520 0 0 0.9 0.9 1.8 0 Reservoirs 530 2.4 0.3 6.3 9 0 Reservoirs < 10 ac 

534 0 0 0 0.4 0.4 0 
Draft NUREG-1941 4-42 August 2010 

Construction Impacts at the Proposed Site Table 4-7. (contd) 1 Cover Type FLUCFCS Code(b) Associated Facilities Excluding Transmission Lines (ac) Transmission Lines up to First Substation (ac) Transmission Lines Beyond First Substation (ac) Total Impacts Permanent Temporary(c) Permanent(d) Permanent(d) Permanent Temporary(c,d) Stream and lake swamps (bottomland) 615 0 0 38.6 3.4 42 0 Cypress 621 12.5 3.8 189.3 2.4 204.2 3.8 Cypress – pine – cabbage palm(e) 624 0 0 2.6 0 2.6 0 Wetland forested mixed 630 2.4 0.8 26.7 3.8 32.9 0.8 Wetland scrub 631 0 0 0 0.1 0.1 0 Freshwater 

marshes 

641 12.5 1.4 25.9 33.5 71.9 1.4 

Saltwater marshes 

642 4.5 0 0 0 4.5 0 

Wet prairies 643 0 0 4.5 0.9 5.4 0 Transportation 810 3 0 0 0 3 0 

Utilities 830 14.8 0 89.8 180.5 285.1 0 Total 219.3 29.6 1509.7 278.5 2007.5 29.6 

Sources: PEF 2009c, f; CH2M HILL 2008; FDOT 1999 (Source for barge slip impacts added to Column 3). (a) Associated offsite facilities include the heavy-haul road, makeup-water and blowdown pipeline, barge slip and barge slip access road, site access 

roads, miscellaneous pipeline, and transmission lines. 

(b) FLUCFCS = Florida Land Use, Cover and Forms Classification System. 

(c) Temporary impacts are represented by a 50-ft buffer adjacent to the pipeline corridor and heavy-haul road between the LNP site and the CFBC. (d) Temporary impacts associated with the transmission lines are treated as permanent impacts. (e) This cover type was not identified from Water Management District FLUCFCS maps as being present in the Associated Facilities Corridors (note 

absence from Table 2-7). However, site inspections conducted by PEF to evaluate preliminary routing impacts for the transmission lines identified the presence of and the potential for impact on this cover type. 

(f) All tree plantations were assumed planted to pine and classified as coniferous plantations (FLUCFCS 441). 
Construction Impacts at the Proposed Site 

August 2010 4-43 Draft NUREG-1941 

1 marshes (FLUCFCS 641), and wetland forested mixed cover types (FLUCFCS 630). 

2 Temporarily disturbed sites would be regraded to pre-existing contours after development 

3 activities have ceased. Uplands would be seeded in accordance with project-developed 

4 sedimentation and erosion control plans, while wetlands would be allowed to regenerate 

5 naturally from the existing wetland seed bank (PEF 2009c, e). Refer to Section 4.3.1.7 for a 

6 description of the mitigation-planning effort and PEF’s proposed BMPs to restore temporarily 

7 disturbed lands. 

8 The amount of impact on vegetation cover types and wetlands is roughly estimated to be 

9 1509.7 ac for transmission lines up to the first substation and 278.5 ac for transmission lines 

10 beyond the first substation (Table 4-7). These estimates were derived using preliminary rights11 of-way locations for the proposed transmission lines within the identified corridors (PEF 2009c; 

12 Golder Associates 2008). For purposes of this analysis and to provide a conservative estimate 

13 of mitigation needs, all impacts associated with transmission-line development were assumed to 

14 be permanent (i.e., temporary impacts were treated as permanent impacts). 

15 Impacts on cover types and wetlands for transmission lines beyond the first substation are much 

16 less than those estimated for transmission lines up to the first substation because most of these 

17 lines would be co-located within existing rights-of-way that already have been cleared (PEF 

18 2009h). 

19 Under the PPSA, the final impacts resulting from transmission-line development would be 

20 determined through a post-certification process after the final rights-of-way have been selected 

21 and approved by the State. To comply with USACE and FDEP regulatory requirements, PEF is 

22 obliged to minimize impacts on wetlands and waterbodies while siting final transmission-line 

23 rights-of-way and during development of the lines. Transmission-line activities generally would 

24 entail erosion control, corridor clearing and site preparation, placement of foundations, 

25 assembly and erection of structures, and installation of conductors. Clearing of vegetation from 

26 the selected rights-of-way would account for most of the terrestrial and wetland impacts. 

27 Because the selected rights-of-way would be narrow (100 to 220 ft wide) and co-located with 

28 existing transmission lines over about 90 percent of their distance (PEF 2009e; Golder 

29 Associates 2008), the required clearing would be greatly minimized. Wherever existing corridor 

30 widths are insufficient for the proposed transmission lines, additional clearing would be 

31 necessary. Based upon cover type mapping for the identified transmission-line corridors, the 

32 most affected upland cover types would be hardwood conifer mixed (FLUCFCS 434, 547.4 ac), 

33 coniferous plantations (FLUCFCS 441, 246.9 ac), and longleaf pine-xeric oak forest 

34 (FLUCFCS 412, 186.0 ac). Cypress swamp (FLUCFCS 621, 191.7 ac) would be the most 

35 affected wetland cover type (Table 4-7). Based upon the preliminary rights-of-way locations for 

36 the proposed transmission lines, total wetland losses could reach about 331.7 ac, as 

37 represented by the 600 series FLUCFCS cover types noted in Table 4-7. 
Construction Impacts at the Proposed Site 

Draft NUREG-1941 4-44 August 2010 

1 Clearing of vegetation for final transmission-line rights-of-way would be dependent upon pre2 existing site conditions, environmental constraints, and line design requirements. As 

3 summarized by PEF (2009a) and Golder Associates (2008), vegetation in uplands would be 

4 cleared to ground level. Stumps would be treated with an approved herbicide or grubbed to 6 

5 in. below grade. Cut vegetation would be mulched or chipped onsite or piled and burned in 

6 compliance with local fire regulations. Vegetation in wetlands would be partially cleared using 

7 restrictive techniques, with the expectation that the cleared wetlands would be maintained in an 

8 herbaceous state. Wetland vegetation would be cleared by hand using chain saws or low 

9 ground pressure shear or rotary machines to reduce soil compaction and minimize damage to 

10 retained vegetation. Trees and vegetative growth with a mature height greater than 12 ft would 

11 be removed from the final rights-of-way. Other wetland vegetation (outside of access road and 

12 structure pad areas) would be left in place. Removed trees would be cut as low as possible and 

13 treated with an approved herbicide. Debris would be removed from wetlands using either low 

14 ground pressure equipment or temporary wetland construction mats and disposed of in upland 

15 areas. 

16 Clearing for the final transmission-line rights-of-ways would constitute only a partial loss of 

17 wetland function because, although trees and tall vegetation would be removed, nonforested 

18 wetland functions would be maintained. However, some wetlands may have to be filled to 

19 install access roads and build structure pads. PEF is obligated under USACE and FDEP 

20 regulatory requirements to site roads and pads in ways that avoid or minimize wetland impacts, 

21 to the extent practicable. Because transmission lines would be co-located with existing 

22 transmission lines over about 90 percent of their distance, many opportunities exist to use 

23 existing access roads and pad sites. Pursuant to the PPSA, FDEP (2010a) would require an 

24 accounting of any unavoidable impacts on wetlands under a post-certification process. 

25 Mitigation for unavoidable impacts on wetlands is required through both the Section 404 permit 

26 process and the ERP process. As previously noted, PEF has prepared a wetland mitigation 

27 plan to compensate for the loss or impairment of wetland functions, including those resulting 

28 from the associated offsite facilities (Entrix 2010). This plan includes an assessment of potential 

29 wetland impacts and UMAM functional losses based upon preliminary rights-of-way for the 

30 transmission lines within the identified corridors (Golder Associates 2008). Refer to Section 

31 4.3.1.7 for a description of the wetland mitigation plan, including an account of the functional 

32 losses predicted to occur and the functional gains to be incurred with implementation of the 

33 mitigation plan. 

34 In-stream activities proposed under the LNP project would mainly be associated with the CFBC 

35 (e.g., building the intake system or blowdown pipeline crossing and connection of the barge slip 

36 to the CFBC). Prior to conducting any in-stream activities, a Clean Water Act Section 10 permit 

37 under the Rivers and Harbors Act would be required. In-stream activities are addressed in 

38 Section 4.3.2. 
Construction Impacts at the Proposed Site 

August 2010 4-45 Draft NUREG-1941 

1 Wildlife 

2 Wildlife present on and around the associated facilities would be subjected to many of the same 

3 impacts described for the LNP site. Some wildlife would perish or be displaced during clearing, 

4 and, as a consequence of habitat loss, fragmentation and competition for remaining resources 

5 could occur. Less mobile animals, such as reptiles, amphibians, and small mammals, would 

6 incur greater mortality than more mobile animals, such as birds which would be displaced to 

7 adjacent communities. Land clearing done during the spring and/or early summer nesting 

8 period would be more detrimental to avian reproductive success than clearing conducted during 

9 non-nesting periods. Adjacent undisturbed habitats could support some displaced wildlife, but 

10 increased competition for available space and resources could depress population levels. 

11 Wildlife habitat affected (permanent and temporary) to develop the associated facilities is 

12 estimated at 2037.1 ac (Table 4-7). Refer to the discussion presented under Cover Types and 

13 Wetlands (above) for a description of how these losses were calculated and apportioned for the 

14 associated facilities excluding the transmission lines, transmission lines up to the first 

15 substation, and transmission lines beyond the first substation. The co-location of the 

16 transmission lines with existing lines over about 90 percent of their distance (PEF 2009e; Golder 

17 Associates 2008) would greatly reduce potential impacts on wildlife and their habitat. Based 

18 upon cover type mapping, affected habitats would include upland and wetland forests that may 

19 provide high value habitat for wildlife, including approximately 568.1 ac of hardwood conifer 

20 mixed (FLUCFCS 434); 208 ac of cypress (FLUCFCS 621); 186.7 ac of longleaf pine-xeric oak 

21 (FLUCFCS 412); 97.7 ac of xeric oak (FLUCFCS 421); 55.5 ac of sand pine (FLUCFCS 413); 

22 and 73.3 ac of freshwater marshes (FLUCFCS 641). However, much of the affected habitats 

23 have lower wildlife value, including approximately 325.5 ac of coniferous plantations (FLUCFCS 

24 441) and 285.1 ac of existing utility land (FLUCFCS 830), mostly existing transmission-line right25 of-way. Actual losses of wildlife habitat would be determined upon final selection of the 

26 transmission-line rights-of-way, as a post-certification condition pursuant to the PPSA (FDEP 

27 2010a). 

28 Creation of new transmission-line corridors could be beneficial for wildlife species that occupy 

29 early successional habitat or benefit from increased habitat edge (i.e., forest/clearing interface 

30 environments). Species, such as white-tailed deer (Odocoileus virginianus), eastern cottontail 

31 rabbit (Sylvilagus floridanus), northern bobwhite (Colinus virginianus), northern cardinal 

32 (Cardinalis cardinalis), eastern meadowlark (Sturnella magna), and the gopher tortoise 

33 (Gopherus polyphemus), could exploit new corridors as groundcover redevelops. Raptors such 

34 as red-tailed hawks (Buteo jamaicensis) and great horned owls (Bubo virginianus) would likely 

35 hunt the corridors. Forested wetlands within the corridors would be converted to and 

36 maintained in an herbaceous or scrub-shrub condition. These wetlands may provide foraging 

37 habitat for wading birds. However, species dependent on forest habitats or sensitive to forest 

38 fragmentation could decline or be displaced, such as the Florida black bear (Ursus americanus 
Construction Impacts at the Proposed Site 

Draft NUREG-1941 4-46 August 2010 

1 floridanus), cavity-nesting birds (e.g., woodpeckers), and numerous birds that nest and feed in 

2 the crowns of trees (e.g., nuthatches and warblers). 

3 Wildlife would also be affected by equipment noise and traffic, and birds could be injured if they 

4 collide with new transmission towers and conductors or the equipment used to install these 

5 components. Noise levels associated with installation of the transmission lines would be brief 

6 and intermittently spaced and would occur mostly during daylight hours (PEF 2008a). 

7 Installation of the transmission lines is expected to take only about 4 weeks per mile. Thus, the 

8 impact on wildlife from noise is expected to be temporary and minor. The potential for 

9 traffic-related wildlife mortality is also expected to be low because relatively small crews 

10 (compared to LNP site development) would spend only a limited time in each area as they 

11 progress over large geographic areas. Avian mortality resulting from collisions with structures 

12 and equipment during transmission-line installation would represent a small hazard for bird 

13 populations. Over 90 percent of the new transmission lines would be collocated with existing 

14 PEF transmission lines, which would reduce the potential for collisions by limiting how frequently 

15 birds need to cross rights-of-way (PEF 2009e). As a Condition of Certification, the FDEP 

16 (2010a) would require PEF to coordinate with the FFWCC in the development of an Avian 

17 Protection Plan for the transmission lines that would include measures to reduce potential 

18 collision impacts by birds. The Avian Protection Plan is discussed in more detail in 

19 Section 4.3.1.7 and Section 5.3.1.2. 

20 4.3.1.3 Impacts on Important Terrestrial Species and Habitats 

21 This section describes potential impacts on important terrestrial species, as defined by NRC in 

22 NUREG-1555 (NRC 2000) (see Section 2.4.1.3), resulting from development activities on the 

23 LNP site and associated offsite facilities, including transmission lines. Unless specifically noted, 

24 no distinction is made between transmission-line impacts up to the first substations and impacts 

25 extending beyond the first substations. To meet responsibilities under Section 7 of the 

26 Endangered Species Act of 1973, as amended (ESA), the review team has prepared a 

27 biological assessment that documents potential project impacts on Federally listed threatened 

28 or endangered terrestrial species. The biological assessment is provided in Appendix F. 

29 Federally Listed Terrestrial Species 

30 Federally listed terrestrial species that may occur on or in the vicinity of the LNP site and 

31 associated offsite facilities are noted in Table 2-8. No designated or proposed critical habitat for 

32 Federally listed terrestrial species occurs in counties containing the LNP site or the corridors for 

33 the associated offsite facilities. The potential impacts of development activities on these 

34 Federally listed species are described below. 
Construction Impacts at the Proposed Site 

August 2010 4-47 Draft NUREG-1941 

1 Eastern Indigo Snake – Threatened 

2 LNP Site

3 Eastern indigo snakes (Drymarchon corais) in Florida occupy a variety of habitats ranging from 

4 scrub and sandhill habitats to moister communities such as wet prairies and swamps (FNAI 

5 2009). The species often seeks shelter during winter in gopher tortoise burrows, especially in 

6 northern Florida where temperatures are cooler. No eastern indigo snakes were observed on 

7 the LNP site during pedestrian surveys conducted over a 2-year period (PEF 2009a). However, 

8 the species has been documented in the site vicinity (PEF 2008a; FFWCC 2009). Most of the 

9 upland habitat on the LNP site has been converted to pine plantation and provides poor-quality 

10 habitat for eastern indigo snakes. Potentially suitable, though highly fragmented, forested 

11 wetland habitat is scattered throughout the site. Gopher tortoise burrows are present in the 

12 southeastern portion of the site (PEF 2009a). These factors suggest a potential for eastern 

13 indigo snakes to occur on the LNP site. However, their presence is likely limited due to highly 

14 fragmented habitat conditions and the dominance of pine plantations across the landscape. 

15 Proposed development activities on the LNP site have the potential to affect the eastern indigo 

16 snake and its habitat. Because this species is not readily observed, its presence and extent of 

17 site use cannot be confirmed. Although the potential for impact on this species is thought to be 

18 low, incidental mortality to eastern indigo snakes is a possibility. During site development, FWS 

19 (2004) Standard Protection Measures for the Eastern Indigo Snake would be implemented to 

20 minimize impacts. A condition of certification by the FDEP would require surveys for and 

21 relocation of any gopher tortoises that could be harmed during “clearing and construction” at the 

22 LNP site (FDEP 2010a). Any eastern indigo snakes recovered during gopher tortoise burrow 

23 excavations would also be relocated in accordance with applicable guidelines. Under mitigation 

24 plans proposed for the LNP site, intensive commercial forest management would cease on most 

25 remaining undisturbed lands, and pine plantations and other disturbed habitats would be 

26 rehabilitated and restored to native plant communities (see Section 4.3.1.7). The restored 

27 communities would likely provide higher-quality habitat for eastern indigo snakes than the 

28 existing pine plantations and other vegetation altered by recent logging. 

29 Associated Offsite Facilities

30 The eastern indigo snake is listed as potentially occurring in all counties through which the 

31 proposed corridors pass (FWS 2009a, b). Potentially suitable habitats and areas with prevalent 

32 gopher tortoise burrows are present along portions of the corridors, and one eastern indigo 

33 snake was observed in Sumter County during limited reconnaissance surveys conducted in the 

34 corridors (PEF 2008a). Therefore, activities in the associated corridors have the potential to 

35 affect the eastern indigo snake and its habitat. Because this species cannot be readily 

36 observed, its presence and extent of use within corridors cannot be readily confirmed. 
Construction Impacts at the Proposed Site 

Draft NUREG-1941 4-48 August 2010 

1 As noted for the site, FWS Standard Protection Measures for the Eastern Indigo Snake would 

2 be implemented during development to minimize impacts. These measures require that 

3 clearing activities temporarily cease when eastern indigo snakes are observed, to provide time 

4 to escape. The likelihood that undetected individuals could escape disturbance is high because 

5 final rights-of-way would be narrow (100 to 220 ft wide) and collocated with existing corridors 

6 over most of their range, limiting the actual extent of required clearing. A condition of 

7 certification by the FDEP would require surveys for and relocation of any gopher tortoises that 

8 could be harmed during “clearing and construction” of offsite facilities (FDEP 2010a). Any 

9 eastern indigo snakes recovered during gopher tortoise burrow excavations would be relocated 

10 in accordance with applicable guidelines. 

11 Sand Skink – Threatened 

12 LNP Site

13 The sand skink (Neoseps reynoldsi) is a short, nearly legless lizard that principally occurs in 

14 rosemary scrub, but it also inhabits sand pine and oak scrub, scrubby flatwoods, turkey oak 

15 ridges within scrub, and edges of citrus groves occupying former scrub (FNAI 2009). It requires 

16 loose sand for burrowing in areas with large patches of sparse to no groundcover or tree canopy. 

17 The sand skink is not identified as potentially occurring in Levy County (FWS 2009a; FNAI 2009), 

18 and the sandy scrub habitats it prefers do not occur on the LNP site. No sand skinks were 

19 observed on the LNP site during pedestrian surveys conducted over a 2-year period (PEF 

20 2009a). Therefore, it is unlikely that sand skinks would be affected by activities on the LNP site. 

21 Associated Offsite Facilities

22 The sand skink is identified as potentially occurring in Marion, Lake, and Polk counties through 

23 which the proposed corridors pass (FWS 2009a, b; FNAI 2009). No sand skinks were observed 

24 during limited reconnaissance surveys conducted for wildlife within the corridors. However, 

25 preferred scrub habitats, although not prevalent, are present along portions of the corridors 

26 (PEF 2008a). Activities on the corridors therefore have the potential to affect the sand skink 

27 and its habitat. Because final rights-of-way would be narrow (100 to 220 ft wide) and mostly 

28 collocated with existing corridors, the actual extent of required clearing is greatly limited, thereby 

29 reducing the potential for impacts. A condition of certification by the FDEP would require 

30 surveys for sand skink prior to clearing finalized rights-of-way (FDEP 2010a). If sand skinks 

31 were identified and impacts could not be avoided, PEF would be required to coordinate with the 

32 FFWCC to determine the need for appropriate mitigation. 
Construction Impacts at the Proposed Site 

August 2010 4-49 Draft NUREG-1941 

1 American Alligator – Threatened by Similarity of Appearance 

2 LNP Site

3 The American alligator (Alligator mississippiensis) is listed by the FWS as threatened due to its 

4 similarity in appearance to the endangered American crocodile (Crododylus acutus). The LNP 

5 site is not located within the range of the crocodile, which is limited to coastal estuarine marshes 

6 and tidal swamps in south Florida. Consequently, no impacts on the American crocodile would 

7 be possible. Alligators are common in almost all permanent bodies of freshwater throughout 

8 Florida, including marshes, swamps, lakes, and ditches (FNAI 2009). One juvenile alligator was 

9 observed on the LNP site during field surveys conducted by PEF (2009a), and alligators may 

10 occasionally occur wherever permanent water is present. Habitat suitability for many onsite 

11 wetlands and swamps is low for the alligator because these wetlands are subject to seasonal 

12 drying. Nevertheless, potentially suitable wetlands and swamps would be filled, and activities in 

13 and around wetlands may temporarily disturb and displace alligators. Because alligators adapt 

14 easily to different aquatic and wetland habitats, individuals would likely relocate to adjacent 

15 areas with suitable habitat. Because the surrounding landscape is rural, movement of alligators 

16 into urban and suburban areas where they could pose a nuisance or danger is not likely. 

17 Impact on the American alligator from activities on the LNP site is therefore expected to be 

18 minor. 

19 Associated Offsite Facilities

20 The American alligator is widespread in all counties through which the corridors pass (FNAI 

21 2009). None of the counties lies within the range of the endangered American crocodile. Some 

22 wetlands and swamps that may support alligators would be filled, but most affected habitats 

23 would only experience overstory vegetation removal, retaining the open water component 

24 required by alligators. Higher-quality lake and stream habitats would generally be spanned by 

25 transmission lines, avoiding any impact on alligator habitat. Activities in and around wetlands 

26 could temporarily disturb and displace alligators. Because alligators adapt easily to different 

27 aquatic and wetland habitats, individuals would likely relocate to adjoining natural areas with 

28 suitable habitat. Because the surrounding landscape is generally rural, movement of alligators 

29 into urban and suburban areas where they could pose a nuisance or danger is not likely to 

30 occur. Impact on the American alligator is therefore expected to be minor. 

31 Wood Stork – Endangered 

32 LNP Site

33 Wood storks (Mycteria americana) nest in a variety of inundated forested wetlands and forage in 

34 shallow open waters wherever prey is concentrated (FNAI 2009). Individuals have been 

35 occasionally observed feeding in ditches and wetlands on the LNP site, but no nesting colonies 
Construction Impacts at the Proposed Site 

Draft NUREG-1941 4-50 August 2010 

1 (rookeries) are present (PEF 2009a). Wood storks have been observed roosting with other 

2 wading birds in forest stands 8 to 9 mi west of the LNP site (Entrix 2009). Long-term forest 

3 management on the LNP site and a lack of favored open water habitat limit suitable rookery 

4 habitat. The LNP site is not located within the core foraging area of any active wood stork 

5 rookery (FWS 2009c). Activities on the LNP site could remove or alter potential foraging habitat 

6 for the wood stork, and birds foraging onsite could be disturbed or displaced. Because wood 

7 storks are highly mobile and similar habitats are abundant in the project vicinity, it is unlikely that 

8 the species would be directly affected. Impact on the wood stork from activities on the LNP site 

9 is therefore expected to be minor. 

10 Associated Offsite Facilities

11 The wood stork is listed as potentially occurring in all counties through which the associated 

12 facilities corridors would pass (FWS 2009a, b). No wood stork rookeries were observed during 

13 limited reconnaissance surveys within these corridors. However, individuals were observed on 

14 the 230-kV Polk-Hillsborough-Pinellas transmission-line corridor, and areas of potentially 

15 suitable habitat (forested wetlands, shallow emergent wetlands, and ditches) occur throughout 

16 portions of all corridors (PEF 2008a). In addition, the proposed corridors pass within the core 

17 foraging area of a number of active wood stork rookeries (FWS 2009c). Activities on the 

18 associated corridors have the potential to affect foraging and nesting habitat for the wood stork. 

19 Because final rights-of-way would be narrow (100 to 220 ft wide) and collocated with existing 

20 corridors over most of their range, the actual extent of clearing required to site-associated 

21 facilities is greatly limited, reducing the potential for impact on wood storks. A condition of 

22 certification by the FDEP would require surveys for wood storks and their rookeries prior to 

23 “clearing and construction” within finalized rights-of-way (FDEP 2010a). If wood stork foraging 

24 and nesting areas are identified and impacts cannot be avoided, PEF would be required to 

25 coordinate with the FFWCC to determine the need for appropriate mitigation. 

26 Red-Cockaded Woodpecker – Endangered 

27 LNP Site

28 In northern and central Florida, the red-cockaded woodpecker (Picoides borealis) favors mature 

29 longleaf pine forests for nesting and foraging. The young (<30-years-old), heavily managed 

30 pine plantations on the LNP site do not provide favorable habitat. No red-cockaded 

31 woodpeckers were observed on the LNP site during pedestrian surveys conducted over a 2-

32 year period (PEF 2009a, e). The species does, however, occur on the Goethe State Forest, 

33 located immediately north and northeast of the LNP site. Several active clusters (an 

34 aggregation of cavity trees used by a family group of red-cockaded woodpeckers) lie between 

35 1.5 and 2.5 mi from the LNP site boundary (Petersen 2010). Considering the size of red 

36 cockaded woodpecker home ranges (100-400 ac; FWS 2003), the distance of these active 

37 clusters from the LNP site, and the lack of suitable habitat onsite, no more that incidental use of 
Construction Impacts at the Proposed Site 

August 2010 4-51 Draft NUREG-1941 

1 LNP site would be expected by red cockaded woodpeckers. Consequently, it is unlikely red2 cockaded woodpeckers would be affected by activities on the LNP site. A condition of 

3 certification by the FDEP would require protocol surveys for red-cockaded woodpeckers prior to 

4 “clearing and construction” on the LNP site (FDEP 2010a). If red-cockaded woodpeckers were 

5 detected and impacts could not be avoided, PEF would be required to coordinate with the 

6 FFWCC to determine the need for appropriate mitigation. 

7 Associated Offsite Facilities

8 The red-cockaded woodpecker is listed as potentially occurring in all counties through which the 

9 corridors pass (FWS 2009a, b). Based upon FLUCFCS cover type mapping, areas of 

10 potentially suitable habitat for red-cockaded woodpeckers (e.g., FLUCFCS 411, 412) may occur 

11 within the corridors (PEF 2008a). Populations are known from the Withlacoochee State Forest, 

12 through which certain transmission line corridors would pass. Because reconnaissance surveys 

13 for wildlife have been limited, it is possible that red-cockaded woodpeckers could occur on or 

14 near the corridors. 

15 Activities in the corridors therefore have the potential to affect the red-cockaded woodpecker 

16 and its habitat. Because final rights-of-way would be narrow (100 to 220 ft wide) and mostly 

17 collocated with existing corridors, the actual extent of clearing would be greatly limited, thereby 

18 minimizing the potential for impact on red-cockaded woodpeckers. A condition of certification 

19 by the FDEP would require protocol surveys for red-cockaded woodpeckers prior to “clearing 

20 and construction” in finalized rights-of-way (FDEP 2010a). If red-cockaded woodpeckers are 

21 detected and impacts cannot be avoided, PEF would be required to coordinate with the FFWCC 

22 to determine the need for appropriate mitigation. 

23 Florida Scrub Jay – Threatened 

24 LNP Site

25 The Florida scrub jay (Aphelocoma coerulescens) favors fire-dominated, low-growing oak scrub 

26 habitat on well-drained sandy soils (FNAI 2009). This habitat generally corresponds with 

27 FLUCFCS 413 (sand pine) and FLUCFCS 421 (xeric oak). Populations may persist in areas 

28 with sparser oaks or overgrown scrub, but at lower densities. Although scrub jays have been 

29 documented in the vicinity (PEF 2008a; FFWCC 2009), no scrub jays were observed on the 

30 LNP site during pedestrian surveys conducted over a 2-year period (PEF 2009a). The xeric, 

31 well-drained scrub habitats preferred by scrub jays are lacking on the site. The conversion of 

32 most upland habitats to pine plantations where oaks and other hardwoods are discouraged has 

33 removed suitable habitat for this species and reduced the likelihood of its occurrence onsite. It 

34 is therefore unlikely that Florida scrub jays would be affected by development activities on the 

35 LNP site. 
Construction Impacts at the Proposed Site 

Draft NUREG-1941 4-52 August 2010 

1 A condition of certification by the FDEP would require protocol surveys for the Florida scrub jay 

2 prior to “clearing and construction” on the LNP site (FDEP 2010a). If scrub jays are detected 

3 and impacts cannot be avoided, PEF would be required to coordinate with the FFWCC to 

4 determine the need for appropriate mitigation. 

5 Associated Offsite Facilities

6 The Florida scrub jay is listed as potentially occurring in all counties through which the corridors 

7 pass (FWS 2009a, b; FNAI 2009). Based upon FLUCFCS cover type mapping, areas of 

8 potentially suitable habitat, although not prevalent, may occur within portions of the corridors 

9 (PEF 2008a). Six scrub jays were observed in Marion County during reconnaissance surveys 

10 conducted along the 500-kV LNP-Central Florida South transmission-line corridor (PEF 2008a). 

11 In addition, populations are known to occur in the Halpata Tastanaki Preserve in Marion County, 

12 the southern perimeter of which is crossed by this corridor. FNAI records for the scrub jay are 

13 also known to occur for the associated corridors in Citrus County (PEF 2008a). Because wildlife 

14 reconnaissance surveys have been limited within the corridors and potentially suitable habitat is 

15 present in some places, it is possible that other scrub jay populations could occur on or near the 

16 associated offsite corridors. 

17 Activities on the associated corridors therefore have the potential to affect the Florida scrub jay 

18 and its habitat. Because final rights-of-way would be narrow (100 to 220 ft wide) and mostly 

19 collocated with existing corridors, the actual extent of clearing would be greatly limited, thereby 

20 reducing the potential for scrub jay impacts. A condition of certification by FDEP would require 

21 protocol surveys for Florida scrub jays prior to “clearing and construction” within finalized rights22 of-way (FDEP 2010a). If scrub jays are detected and impacts could not be avoided, PEF would 

23 be required to coordinate with the FFWCC to determine the need for appropriate mitigation. 

24 Piping Plover – Threatened 

25 LNP Site

26 The piping plover (Charadrius melodus) is a very rare to uncommon winter resident found on 

27 open, sandy beaches and tidal mudflats and sandflats along both coasts of Florida. It is not 

28 identified as potentially occurring in Levy County (FWS 2009a; FNAI 2009), and its favored 

29 sandy beach and tidal mudflat habitats do not occur on the LNP site. No piping plovers were 

30 observed on the LNP site during pedestrian surveys conducted over a 2-year period (PEF 

31 2009a). The closest potential habitat (tidal mudflats) is more than 5 mi west of the site. It is 

32 therefore unlikely that piping plover would be affected by activities on the LNP site. 
Construction Impacts at the Proposed Site 

August 2010 4-53 Draft NUREG-1941 

1 Associated Offsite Facilities

2 The piping plover is identified as potentially occurring in Pasco and Hillsborough counties 

3 through which the corridors pass (FWS 2009a; FNAI 2009). No piping plovers were observed 

4 during limited reconnaissance surveys conducted within the corridors. However, saltwater 

5 marsh is present within a small portion of the 230-kV CREC-to-Brookridge transmission-line 

6 corridor (PEF 2008a). Consequently, it is possible that tidal mudflats used by piping plover may 

7 occur on portions of this corridor. Nevertheless, impacts on this species are expected to be 

8 limited to a minor disturbance of loafing and foraging birds. Therefore, it is unlikely that piping 

9 plovers would be affected by the activities involving associated offsite facilities. 

10 Florida Salt Marsh Vole – Endangered 

11 LNP Site

12 The Florida salt marsh vole (Microtus pennsylvanicus dukecampbelli) is a very rare small 

13 mammal known only from salt marsh habitat near Cedar Key and the Lower Suwannee National 

14 Wildlife Refuge in Levy County (FWS 2010b; FNAI 2009). No salt marsh habitat that could 

15 support this species is found on the LNP site. The closest salt marsh habitat is more than 5 mi 

16 west of the site, and the closest known location for the species is more than 30 mi to the west17 northwest. It is therefore unlikely that Florida salt marsh vole would be affected by activities on 

18 the LNP site. 

19 Associated Offsite Facilities

20 The Florida salt marsh vole is not identified as potentially occurring in the other counties through 

21 which the corridors pass (FWS 2009a; FNAI 2009). However, salt marsh habitat preferred by 

22 this species is present within a portion of the blowdown pipeline corridor between the LNP site 

23 and the CREC. Considering the proximity to known locations for this species, it is possible 

24 (though unlikely considering the rarity of this species) that salt marsh habitat along the 

25 blowdown pipeline corridor route could support the salt marsh vole. If this species is present, 

26 development activities along this corridor could disturb the Florida salt marsh vole and its 

27 habitat. A Condition of Certification by FDEP would require protocol surveys for Florida salt 

28 marsh vole prior to “clearing and construction” within suitable habitats in the finalized rights-of29 way (FDEP 2010a). If salt marsh voles are detected and impacts cannot be avoided, PEF 

30 would be required to coordinate with the FFWCC to determine the need for appropriate 

31 mitigation. 

32 The review team is aware that PEF has proposed to the FDEP an alternate route to minimize 

33 impacts to important wetland habitats (including salt marsh) along the blowdown pipeline 

34 corridor route (PEF 2010b, c). FDEP has not made a decision on the proposal. Should the 
Construction Impacts at the Proposed Site 

Draft NUREG-1941 4-54 August 2010 

1 blowdown pipeline corridor be rerouted to avoid salt marsh habitat, no impact to Florida salt 

2 marsh vole would be expected. 

3 Florida Panther – Endangered 

4 LNP Site

5 The Florida panther (Puma concolor coryi) is a top of the food chain carnivore that historically 

6 ranged throughout Florida and much of the southeastern United States (FNAI 2009). This very 

7 rare subspecies is currently restricted to a small population of less than 100 animals in 

8 southwest Florida, where it occupies large expanses of upland and wetland forest habitat (Land 

9 et al. 2008). Young transient males are occasionally documented outside of the known 

10 breeding range. Considering the distance from the LNP site to the current breeding range of 

11 this species (more than 175 mi), it is unlikely that Florida panthers would be affected by 

12 activities on the LNP site. 

13 Associated Offsite Facilities

14 The 230-kV Polk-Hillsborough-Pinellas transmission-line corridor would pass through the 

15 eastern perimeter of Polk County, which is identified as potentially supporting the Florida 

16 panther (FWS 2009a; FNAI 2009). Although outside of the known breeding range for the 

17 Florida panther, it is possible that young transient males could occasionally occur in Polk 

18 County. Therefore, project activities along the transmission-line corridor have the potential to 

19 affect the Florida panther. These impacts would likely be limited to temporary disturbance and 

20 displacement of individual animals that may at times travel north of the known breeding range. 

21 Because the final right-of-way for the Polk-Hillsborough-Pinellas transmission line would be 

22 narrow (about 100 ft wide) and mostly collocated with existing corridors, little clearing of habitat 

23 would occur. Consequently, the potential for fragmentation of suitable forest habitat that could 

24 support Florida panther would be limited. 

25 Plants 

26 LNP Site

27 No Federally listed plant species are known to occur in Levy or Citrus County (FWS 2009a; 

28 FNAI 2009). Consequently, it is unlikely that such plants would be affected by development 

29 activities on the LNP site. 

30 Associated Offsite Facilities

31 Thirteen Federally listed plant species are identified as potentially occurring in the corridors 

32 (Table 2-8). None was observed during the limited reconnaissance surveys conducted within 

33 the corridors (PEF 2009a; Golder Associates 2008). However, one documented occurrence is 
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August 2010 4-55 Draft NUREG-1941 

1 known for the longspurred mint (Dicerandra cornutissima) from the PEF (2008a) and FFWCC 

2 (2009) databases. Potentially suitable habitat for many of these species may be present within 

3 portions of the corridors. Eleven of these plant species are usually associated with well-drained, 

4 sandy, xeric upland habitats, such as sandhill and scrub, and several may also occur on 

5 scrubby flatwoods, which are found on moderately well-drained sandy flatland. These include 

6 the Florida bonamia (Bonamia grandiflora), pygmy fringe tree (Chionanthus pygmaeus), Florida 

7 goldenaster (Chrysopsis floridana), longspurred mint, scrub wild buckwheat (Eriogonum 

8 longifolium var. gnaphalifolium), Britton’s beargrass (Nolina brittoniana), Lewton’s polygala 

9 (Polygala lewtonii), Small’s jointweed (Polygonella myriophylla), scrub plum (Prunus geniculata), 

10 wide-leaf warea (Warea amplexifolia), and Carter’s mustard (Warea carteri). Although not 

11 prevalent, sandhill and scrub habitats are present along corridors supporting the associated 

12 offsite facilities, and clearing, grading, and other development activities have the potential to 

13 affect these species and their habitat. Two Federally listed plants associated with wetlands may 

14 also occur on the associated facilities corridors: Brooksville bellflower (Campanula robinsiae), 

15 which is found on wet grassy slopes and drying pond edges in Hernando County, and Cooley’s 

16 water-willow (Justicia cooleyi), which occurs in mesic hardwood hammocks of central Florida. 

17 These two plants and their habitats may also be affected by development activities. Because 

18 final rights-of-way for the transmission lines would be narrow (100 to 220 ft wide) and collocated 

19 with existing corridors over most of their range, the actual extent of clearing required to build 

20 associated facilities is limited. This would reduce the area over which Federally listed plant 

21 species could be affected. 

22 Federal Threatened and Endangered Species Summary 

23 Based on wildlife reconnaissance surveys, life-history information, known threatened and 

24 endangered species locations, and information provided by PEF in its ER and responses to 

25 RAIs, little use of the LNP site is expected by Federally listed threatened and endangered 

26 terrestrial species. Only limited site reconnaissance work has been completed for threatened 

27 and endangered species along the associated offsite facilities (Golder Associates 2008). A 

28 condition of certification by the FDEP would require protocol surveys for State-listed species 

29 (excluding plants) that may occur on the LNP site and corridors prior to land “clearing and 

30 construction” (FDEP 2010a). All federally listed species potentially affected by the LNP project 

31 are also listed by the state of Florida, and are therefore subject to FDEP protocol survey 

32 requirements. If threatened or endangered species are identified and impacts cannot be 

33 avoided, PEF would be required to coordinate with the FFWCC to determine the need for 

34 appropriate mitigation. Potential impacts to Federally listed threatened or endangered terrestrial 

35 species are also addressed in the biological assessment the review team prepared under 

36 Section 7 of the ESA. The biological assessment, which will be submitted to the FWS, is 

37 provided in Appendix F. 
Construction Impacts at the Proposed Site 

Draft NUREG-1941 4-56 August 2010 

1 Restoration and enhancement of several hundred acres of low-ecological value pine plantations 

2 is proposed under the wetland mitigation plan for the LNP project (see Section 4.3.1.7). 

3 Commercial forest management would cease over portions of the site, and many pine 

4 plantations and other disturbed habitats would be restored to plant communities functionally 

5 similar to native upland and wetland habitats present prior to logging. Mitigation activities would 

6 entail land preservation, thinning of pines to more natural densities, targeted plantings of native 

7 species to improve species diversity, hydrologic restoration (e.g., culvert removal, ditch 

8 plugging, and planting bed removal), control of invasive species, and establishment of a 

9 prescribed fire regime (Entrix 2010). These actions are expected to be beneficial to most listed 

10 wildlife affected by the proposed LNP and could provide compensation for many potential 

11 impacts realized from development of the LNP and associated offsite facilities. 

12 State-Listed Terrestrial Species 

13 Florida-listed terrestrial species that may occur on or in the vicinity of the LNP site and 

14 associated offsite facilities are listed in Table 2-8. The State list includes species classified as 

15 endangered, threatened, or species of special concern. The potential impacts of development 

16 activities on these State-listed species are described below. 

17 LNP Site

18 As many as 16 State-listed animals could, at times, use the LNP site (Table 2-8). Of these, the 

19 Florida scrub jay, wood stork, American alligator, and eastern indigo snake, which are also 

20 regulated under the ESA, are discussed under Federally listed species and not repeated here. 

21 Targeted surveys for gopher tortoises conducted by PEF (2009a) detected the presence of this 

22 species in the southeastern portion of the LNP site. Most burrows were located along existing 

23 roads, edges of wetlands, and in spoil areas. Well-drained, sandy habitats preferred by the 

24 gopher tortoise are not prevalent on the LNP site. The shallow groundwater depth across much 

25 of the site acts to limit the distribution and density of gopher tortoise burrows, and the extensive 

26 alteration of upland habitats from decades of forest management has further degraded habitat 

27 suitability for this species. Nevertheless, clearing and grading activities pose a hazard to 

28 gopher tortoises, as well as to other State-listed species that occupy similar sandy uplands, 

29 such as the Florida pine snake (Pituophis melanoleucus mugitus), gopher frog (Rana capito), 

30 and Florida mouse (Podomys floridanus) – commensal species that use gopher tortoise burrow 

31 systems as a refuge – and the short-tailed snake (Stilosoma extenuatum). Gopher tortoises are 

32 also susceptible to traffic-related mortality, and construction traffic on the LNP site could 

33 contribute to additional losses for this species. 

34 American kestrels (Falco sparvenius) have been observed on the LNP site (PEF 2009a, e), and 

35 it is possible that the listed resident subspecies, Southeastern American kestrel (Falco 

36 sparverius paulus), could occasionally visit open habitats on the site. A loss of potentially 
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August 2010 4-57 Draft NUREG-1941 

1 suitable habitat would occur with site clearing, and, if the listed subspecies is present, noise and 

2 human activity could disturb or displace individuals. Because kestrels are highly mobile and 

3 suitable habitats are widely dispersed in the project’s vicinity, the impact on southeastern 

4 American kestrel from site-development activities is expected to be minor. 

5 A variety of State-listed wading birds (e.g., little blue heron [Egretta caerulea], white ibis 

6 [Eudocimus albus], snowy egret [Egretta thula], tricolored heron [Egretta tricolor], and limpkin 

7 [Aramus guarauna]) may occasionally forage on the LNP site, but no wading bird rookeries are 

8 documented (PEF 2009a). Wading birds throughout central Florida forage in a variety of 

9 permanently and seasonally flooded wetlands, creeks, ditches, ponds, and lakes. Activities on 

10 the LNP site would remove over 300 ac of wetlands that could provide potential foraging habitat 

11 for wading birds, and birds foraging onsite could be disturbed or displaced by development 

12 activities. Because wading birds are highly mobile and similar wetland habitats are abundant in 

13 the project’s vicinity, the impact on them from development activities on the LNP site is 

14 expected to be minor. 

15 Although no Florida black bears were identified during field surveys of the LNP site, black bears 

16 may occasionally visit or move through the site (PEF 2009a). Habitat on the site has been 

17 degraded by decades of forest management, but the remaining forested wetlands could provide 

18 diurnal cover and foraging opportunities for black bears. Given their nature, Florida black bears 

19 would likely avoid the LNP site while development is ongoing. Nonetheless, loss and 

20 fragmentation of lower-quality black bear habitat could occur with site development. 

21 The distribution of the Homosassa shrew includes a wide variety of upland and wetlands 

22 habitats throughout the northern two-thirds of peninsular Florida (Jones et al. 1991). Given the 

23 presence of suitable habitat on the LNP site, if this small secretive species is present, clearing 

24 and grading activities could pose a mortality hazard. 

25 Forty-eight State listed plant species are identified as potentially occurring on the LNP site 

26 (Table 2-8), based upon distribution records and habitat preferences. No targeted surveys for 

27 individual State-listed plants have been conducted on the site. However, plant species were 

28 recorded by PEF contractors during extensive pedestrian surveys conducted between 

29 September 2006 and November 2008, in conjunction with habitat mapping and wetland 

30 delineation efforts (PEF 2009e). No State-listed plants were identified during these surveys 

31 (PEF 2009a). PEF (2008a) records identify five State-listed species from the LNP site vicinity – 

32 Godfrey’s swampprivet (Forestiera godfreyi), pinewood dainties (Phyllanthus leibmannianus), 

33 corkwood (Leitneria floridana), spoonleaf sundew (Drosera intermedia), and coastal mock 

34 vervain (Glandularia maritima). The past conversion of much of the LNP site to managed pine 

35 plantation reduces the likelihood that many of these rare plants are present. Nevertheless, 

36 clearing and grading activities could remove State-listed plants, particularly when native habitats 

37 are disturbed (e.g., mixed wetland hardwoods – FLUCFCS 617; cypress swamp – FLUFCS 

38 621; wetland forested mixed – FLUCFCS 630; and freshwater marsh – FLUCFCS 641). 
Construction Impacts at the Proposed Site 

Draft NUREG-1941 4-58 August 2010 

1 A condition of certification by the FDEP would require protocol surveys for State-listed species 

2 (excluding plants) prior to “clearing and construction” on the LNP site (FDEP 2010a). If State3 listed species are detected and impacts cannot be avoided, appropriate mitigation could be 

4 required on a case-by-case basis. For example, the capture and relocation of any gopher 

5 tortoises that occupy habitat to be affected by project activities would be required pursuant to 

6 permitting authorized by the FFWCC. Under wetland mitigation planning for the LNP project, 

7 commercial forest management would cease on portions of the remaining undisturbed lands on 

8 the LNP site, and many pine plantations and other disturbed habitats would be rehabilitated and 

9 restored to native upland and wetland plant communities (see Section 4.3.1.7). The higher10 quality habitat provided by these restored communities would likely be beneficial to many State11 listed species. 

12 Associated Offsite Facilities

13 As many as 32 State-listed animals and 76 State-listed plants could occur along the corridors 

14 (Table 2-8). Many of these plant and animal species are usually associated with well-drained, 

15 sandy, xeric upland habitats, such as sandhill and scrub. Although not prevalent, sandhill and 

16 scrub habitats are present along corridors supporting the associated offsite facilities. Limited 

17 reconnaissance surveys (PEF 2009a, e; Golder Associates 2008) and PEF (2008a) and 

18 FFWCC (2009) database searches of the corridors have verified the presence of species, such 

19 as Sherman’s fox squirrels (Sciurus niger shermani), Florida scrub jays, gopher tortoises, 

20 longspurred mint, and giant orchid (Pteroglossaspis ecristata); and potentially suitable habitat 

21 was identified for many other State-listed species (see Table 2-8). Targeted surveys for gopher 

22 tortoise in portions of the corridor segment between the LNP site and the CFBC detected 

23 numerous burrows for this species. Considering the linear extent of the associated facilities 

24 corridors and the variety of habitats through which they pass, it is possible that other State-listed 

25 plants and animals may be present. 

26 Vegetation clearing, grading, and other development activities necessary to site the associated 

27 offsite facilities have the potential to affect many of these State-listed species and their habitats. 

28 Many State-listed mammals and most State-listed birds are highly mobile and should be able to 

29 avoid mortality during clearing and grading. However, more sedentary animals, such as reptiles 

30 and amphibians, are susceptible to injury or mortality during clearing and grading. Forest31 dependent species may suffer local population declines as suitable forest habitat is permanently 

32 cleared for the final rights-of-way. However, if corridor management does not reduce suitability, 

33 species known to exploit disturbed corridors, such as the gopher tortoise, fox squirrel, and 

34 burrowing owl (Athene cunicularia floridana), may benefit after vegetation reestablishes. The 

35 impacts on State-listed animals associated with coastal tidelands and waters are expected to be 

36 limited to temporary noise disturbance or displacement. If State-listed plants are physically 

37 disturbed during clearing and grading or become stressed by microhabitat changes, these 

38 populations could decline in vigor, be reduced, or be eliminated. However, the conditions 
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August 2010 4-59 Draft NUREG-1941 

1 created and to be maintained along some corridors (e.g., low-growing non-woody habitats) 

2 could favor establishment of other listed plant species. 

3 The final rights-of-way for the transmission lines and their substations would be determined as a 

4 post-certification effort under the PPSA. Because the final rights-of-way would be narrow 

5 (100 to 220 ft wide) and collocated with existing corridors over most of their range, the actual 

6 extent of clearing required to site associated facilities is greatly limited. As a condition of 

7 certification by the FDEP (2010a), PEF is obliged to conduct protocol surveys for State-listed 

8 species (excluding plants) prior to “clearing and construction.” If State-listed species are 

9 detected and impacts cannot be avoided, appropriate mitigation could be required on a case-by10 case basis. For example, the capture and relocation of any gopher tortoises that occupy habitat 

11 to be affected by site development would be required pursuant to permitting authorized by the 

12 FFWCC. Under wetland mitigation planning for the LNP project, commercial forest 

13 management would cease on approximately 1549 ac of undisturbed lands on the LNP site and 

14 property owned by PEF directly to the south, and pine plantations and other disturbed habitats 

15 would be rehabilitated and restored to native upland and wetland plant communities (see 

16 Section 4.3.1.7). The higher-quality habitat provided by these restored communities would likely 

17 be beneficial to many State-listed species. 

18 Other Important Terrestrial Species and Habitats 

19 LNP Site

20 Other than wetlands, no unique or rare habitats, or habitats with priority for protection are 

21 identified on the LNP site as being potentially affected by development activities (PEF 2009a). 

22 Plant communities on the LNP site have been extensively altered by decades of intensive forest 

23 management. The Goethe State Forest is located along the northeast border of the LNP site, 

24 but the closest LNP development activities (other than conservation-related mitigation activities) 

25 would be more than 1 mi from the Goethe State Forest boundary. Perimeter fencing would not 

26 be erected around the LNP property line in a way that could disrupt movement and dispersal of 

27 wildlife between the Goethe State Forest and the northern portion of the LNP site, which would 

28 remain undeveloped. Fencing would be limited to areas close to plant facilities to provide for 

29 security or industrial safety (PEF 2009g). Daytime noise could present a minor disturbance 

30 impact on wildlife in the Goethe State Forest during very limited periods of intense activity (e.g., 

31 pile driving). No other development-related impacts on terrestrial resources found within 

32 preserves or conservation areas are expected. 

33 Some recreationally valuable game species that occupy the LNP site (e.g., white-tailed deer, 

34 bobwhite quail, wild turkey [Meleagris gallopavo]) would be affected by development activities. 

35 These highly mobile species should be able to avoid mortality during site clearing, but local 

36 population declines may occur due to habitat loss and fragmentation, and from competition for 
Construction Impacts at the Proposed Site 

Draft NUREG-1941 4-60 August 2010 

1 resources on lands to which they are displaced. These impacts on game species are 

2 considered minor because they and their preferred habitats are locally abundant. 

3 Federally protected under the Bald and Golden Eagle Protection Act of 1940, bald eagles 

4 (Haliaeetus leucocephalus) also are expected to incur minor impacts. The LNP site does not 

5 provide quality aquatic foraging habitat for the bald eagle, and nesting is not documented there. 

6 However, several bald eagle nests are known to exist between 1 and 2 mi from the LNP site. If 

7 these nests are active during the bald eagle nesting season (October 1–May 25), daytime noise 

8 could represent a minor disturbance impact during very limited periods of intense development 

9 activity (e.g., pile driving) near active nests. 

10 Little impact on whooping cranes is expected from actions on the LNP site. No whooping 

11 cranes were identified during field surveys of the LNP site (PEF 2009a, e). Whooping cranes 

12 could pass near the LNP site during their seasonal migrations, and birds from the nonmigratory 

13 population could stray into this area. Although recently cutover forestland and emergent 

14 wetlands could provide some low quality foraging habitat, use of the LNP site by whooping 

15 cranes is highly unlikely and any use would likely be incidental. 

16 Associated Offsite Facilities

17 A number of wetlands (see Section 4.3.1.2) wildlife sanctuaries, refuges, and preserves (see 

18 Section 2.4.1.4) lie near or are crossed by the corridors. Clearing for the final rights-of-way 

19 traversing or adjoining these conservation areas could alter native habitats that are presently 

20 preserved. However, development impacts are expected to be minor because the final rights21 of-way would be narrow (100 to 220 ft wide) and collocated with existing PEF corridors through 

22 or along most of these areas. This would minimize the actual extent of clearing required within 

23 conservation areas and limit further fragmentation to terrestrial resources. Any forested 

24 wetlands that lie within cleared zones would be converted to an herbaceous or scrub-shrub 

25 condition, retaining partial wetland functions. Lands bordering streams classified as 

26 Outstanding Florida Waters would be spanned by the transmission lines (i.e., Withlacoochee 

27 River, Blackwater Creek, Hillsborough River, Trout Creek, Cypress Creek), thereby avoiding 

28 impact on these resources. 

29 A variety of recreationally valuable game species is expected to occur along the associated 

30 offsite facilities wherever suitable habitat is present. Most of these species are highly mobile 

31 and should be able to avoid mortality during site clearing. Forest-dependent game species, 

32 such as gray squirrels, may suffer local population declines as suitable forest habitat is 

33 permanently cleared for the final rights-of-way. However, many of the other game species are 

34 multicover users (e.g., white-tailed deer and mourning dove [Zenaida macroura]), inhabit early 

35 successional upland (e.g., northern bobwhite and eastern cottontail rabbit), or wetland 

36 (e.g., common snipe [Gallinago gallinago]) communities. Unless landowner management 

37 reduces habitat suitability, these species likely would benefit following the reestablishment of 
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August 2010 4-61 Draft NUREG-1941 

1 herbaceous and shrub vegetation within cleared rights-of-way. Because these game species 

2 and their habitats are abundant throughout central Florida, impacts on them are considered to 

3 be minor for corridors both up to and beyond the first substations. 

4 Bald eagles are widely distributed throughout central Florida wherever suitable aquatic foraging 

5 habitat is present. A number of bald eagle nests (both active and inactive) exist within or near 

6 the corridors for the associated offsite facilities, including corridors both up to and beyond the 

7 first substations. Activities within the associated corridors have the potential to affect nesting 

8 bald eagles. A condition of certification by the FDEP would require protocol surveys for bald 

9 eagles prior to “clearing and construction” for the associated offsite facilities (FDEP 2010a). If 

10 impacts on bald eagle nests cannot be avoided following FWS (2007) and the FFWCC (2008) 

11 guidelines for bald eagles, PEF would need to obtain a FFWCC Eagle Permit as conditioned by 

12 the FDEP (2010a) and FWS authorization under the Bald and Golden Eagle Protection Act. 

13 Whooping cranes, although rare, may occasionally occur within areas through which the offsite 

14 corridors would pass. Substantial portions of the transmission-line corridors lie within the 

15 primary range of the nonmigratory Kissimmee Prairie population, and the CREC-to-Brookridge 

16 corridor would pass within 2 mi of the wintering site for the migratory whooping crane 

17 population. Although no records or observations of whooping crane are known from the offsite 

18 corridors, emergent wetlands, or maintained grasslands, and other suitable foraging habitats do 

19 lie within these corridors. Development activities along the corridors could result in minor 

20 disturbances to loafing or foraging birds. Newly cleared rights-of-way could provide additional 

21 foraging habitat (for example, forested wetlands converted to emergent wetlands). 

22 4.3.1.4 Floodplains and Historic Basin Storage 

23 Floodplains are normally dry or semi-dry lands that provide temporary natural storage areas for 

24 floodwater. Although development within floodplains is not prohibited under Florida statutes, 

25 compensating storage is required for encroachment into the 100-year floodplain that would 

26 adversely affect conveyance, storage, water quality, or adjacent lands (SWFWMD 2009). To 

27 allow storage during lesser flood events, any required compensating storage must be provided 

28 between the seasonal high-water level and the 100-year flood level. Historic basin storage is 

29 the retention storage provided by topographic depressions present on a site (in floodplains or 

30 elsewhere) prior to development. Stormwater captured by historic basin storage remains onsite, 

31 unable to run off, and loss occurs by evaporation or percolation into the soil. Florida statutes 

32 require replacement or mitigation for the loss of historic basin storage from a project site 

33 (SWFWMD 2009). 

34 The distinction between floodplain storage and historic basin storage is landscape dependent. 

35 In general, floodplain storage is the detention volume above the landscape elevation where 

36 stormwater runoff occurs by sheet flow from natural low areas. Historic basin storage is the 

37 detention and/or retention volume below this discharge elevation. Floodplain and historic basin 
Construction Impacts at the Proposed Site 

Draft NUREG-1941 4-62 August 2010 

1 storage areas act to minimize flood damage to adjacent areas, recharge groundwater aquifers, 

2 improve water quality by capturing sediments and other contaminants, and provide specialized 

3 natural habitats for many plant and animal species. 

4 Development of the LNP project would require placing permanent fill into the 100 year floodplain 

5 as mapped by FEMA and into historic basin storage areas. For the purposes of this Draft EIS, 

6 PEF prepared a preliminary floodplain analysis to estimate the maximum amount of floodplain 

7 and historic basin storage encroachment that could occur, and to demonstrate that adequate 

8 floodplain compensation is feasible (CH2M HILL 2009a). Encroachment by fill into the 100-year 

9 floodplain (estimated volume of 252.4 ac-ft) and into historic basin storage (estimated volumes 

10 of 73.9 ac-ft for connected floodplains and 13.9 ac-ft for isolated floodplains) was calculated 

11 using a “volume for volume” analysis for the LNP site and for the associated offsite facilities 

12 lying between the LNP site and the CFBC. Refer to Section 4.2.1 for a detailed accounting of 

13 the preliminary floodplain analysis. PEF intends to prepare a revised floodplain analysis utilizing 

14 a dynamic modeling approach to estimate floodplain and historic basin storage encroachment 

15 and compensation requirement to satisfy formal floodplain permitting under the ERP. 

16 PEF identified 5 potential floodplain compensation areas on lands it owns immediately south of 

17 the LNP site that encompass about approximately 322 ac, where excavation could yield up to 

18 320.9 ac-ft of floodplain compensating storage (CH2M HILL 2009a). These 5 areas presently 

19 support upland vegetation that has mostly been degraded by prior forest-management activities 

20 such as coniferous plantations (FLUCFCS 441) and other open lands (rural) (FLUCFCS 260). 

21 No wetlands are identified in these areas (Table 4-8). Compensation for fill within historic basin 

22 storage would not require the disturbance of additional land area. Compensation for loss of 

23 historic basin storage in connected floodplains could be provided by excavating depressions 

24 below the seasonal high groundwater level within the five potential floodplain compensation 

25 areas to trap and retain floodwater. According to SWFWMD policy, permanent pool volume 

26 within the proposed wet detention ponds, which total 105 ac in area, can serve as compensation 

27 storage for the loss of historic basin storage from isolated (i.e., not connected) floodplains. For 

28 a detailed account of the potential availability of compensating storage, refer to Section 4.2, 

29 Water-Related Impacts. Based upon the preliminary floodplain analysis, there appears to be 

30 adequate upland area available on lands south of the LNP site to compensate for floodplain and 

31 historic basin storage losses. 

32 As noted, additional upland impacts of roughly 250 ac could be required to compensate for LNP 

33 project floodplain losses, depending upon the results of the dynamic modeling approach for 

34 floodplain assessment. Floodplain compensation areas would be cleared of existing vegetation, 

35 excavated to achieve available storage volume, and restored to native plant communities typical 

36 of natural floodplains in the region. Wildlife occupying these areas would be subjected to many 

37 of the same types of development impacts as described for the LNP site. Some wildlife would 

38 perish or be displaced during clearing and excavation. Less mobile animals, such as reptiles, 

39 amphibians, and small mammals, would incur greater mortality than more mobile animals, such 
Construction Impacts at the Proposed Site 

August 2010 4-63 Draft NUREG-1941 

1 Table 4-8. Cover Types Present Within Potential Floodplain Compensation Areas 

Compensation 

Site Area (ac) 

FLUCFCS 

Code(a)

FLUCFCS 

Description 

Area (ac) by 

FLUCFCS 

Type 

Percent of 

Compensation 

Site 

C-74 20.1 441 Coniferous 

Plantations(b)

20.1 100 

C-76A 84.9 260 Other Open Lands 

<Rural> 

14.4 17.0 

 410 Upland Coniferous 

Forest 

3.5 4.1 

 441 Coniferous 

Plantations(b)

67.0 78.9 

C-76B 78.5 260 Other Open Lands 

<Rural> 

50.8 64.7 

 434 Hardwood Conifer 

Mixed 

3.8 4.8 

 441 Coniferous 

Plantations(b)

23.8 30.3 

C-76C 102.9 260 Other Open Lands 

<Rural> 

20.4 19.8 

 441 Coniferous 

Plantations(b)

82.5 80.2 

C-96A 9.3 260 Other Open Lands 

<Rural> 

1.9 20.4 

 441 Coniferous 

Plantations(b)

7.4 79.6 

C-100 10.7 441 Coniferous 

Plantations(b)

10.7 100 

C-101 15.6 441 Coniferous 

Plantations(b)

15.6 100 

Total Area 322.0 322.0 

Sources: CH2M HILL 2009a, FDOT 1999. 

(a) FLUCFCS = Florida Land Use, Cover and Forms Classification System. 

(b) All tree plantations were assumed to be planted in pine and classified as coniferous plantations (FLUCFCS 441). 

2 
Construction Impacts at the Proposed Site 

Draft NUREG-1941 4-64 August 2010 

1 as birds, which would be displaced to adjacent communities. Land clearing conducted during 

2 the spring and/or early summer nesting periods would be detrimental to avian reproductive 

3 success. Wildlife would also be subjected to minor, short-term impacts from noise and traffic. 

4 Adjacent habitats could support some displaced wildlife, but increased competition for available 

5 space and resources likely would depress population levels. As restored habitats become 

6 available for use by wildlife, the higher-quality habitat provided by the restored communities 

7 would allow for an increase in wildlife diversity and species population levels. 

8 Although degraded from past forest-management activities, it is possible that floodplain 

9 compensation areas could support listed species, particularly the State-listed gopher tortoise 

10 and those species commensal with the tortoise. A condition of certification by the FDEP would 

11 require protocol surveys for all State-listed species (excluding plants) prior to land “clearing and 

12 construction” for the LNP project (FDEP 2010a). If listed species are identified on floodplain 

13 compensation areas, PEF intends to avoid these areas (CH2M HILL 2009a). If listed species 

14 are identified on floodplain compensation areas, PEF would attempt to avoid these areas 

15 (CH2M HILL 2009a). If these areas cannot be avoided, PEF would be required to coordinate 

16 with the FFWCC to determine the need for appropriate mitigation. Potential impacts to 

17 Federally listed threatened or endangered terrestrial species are addressed in the biological 

18 assessment the review team prepared under Section 7 of the ESA. The biological assessment 

19 is provided in Appendix F. 

20 Additional floodplain and historic basin storage encroachment (not yet determined) would be 

21 incurred to develop the offsite facilities, primarily the transmission lines. Because new 

22 transmission lines would be collocated with existing PEF transmission lines over about 

23 90 percent of their distance, opportunities should be available to situate most access roads and 

24 tower pad sites outside of floodplains and depressions that provide historic basin storage. Most 

25 pipeline length would be installed in trenches and backfilled to restore existing grade, and hence 

26 existing surface water runoff patterns. Compensation storage for floodplain and historic basin 

27 storage encroachment that cannot be avoided typically would be provided immediately adjacent 

28 to the resource area within the approved right-of-way and addressed through the Florida ERP 

29 process (CH2M HILL 2009a). 

30 4.3.1.5 Impacts from Fill Acquisition 

31 Another potential source of terrestrial resource impacts is mining of fill material used during 

32 building activities at the LNP site. PEF has not yet determined where it would obtain its needed 

33 fill material. However, to provide the reader with additional context of the potential impacts of fill 

34 mining, the review team has assessed impacts assuming that PEF would obtain its entire fill from 

35 the proposed Tarmac King Road Limestone Mine. Due to the proximity of the Tarmac mine to 

36 the LNP site, use of the Tarmac mine would cumulatively affect many of the same terrestrial 

37 habitats as those affected by the LNP project. Considering the proximity of the two sites and the 

38 presence of wetlands and other sensitive coastal habitats on both sites, use of the Tarmac mine 
Construction Impacts at the Proposed Site 

August 2010 4-65 Draft NUREG-1941 

1 would constitute a worst-case bounding assumption for assessing potential impacts from fill 

2 acquisition attributable to the Levy project. The proposed Tarmac mine would be located 1 mi 

3 west of the intersection of US-19 and King Road in Levy County, about 2 mi west of the LNP site. 

4 Additional information regarding the Tarmac mine is provided in Chapter 7. 

5 Tarmac has applied for permits to begin site development in 2011, with operations beginning in 

6 2013. Development of the Tarmac mine would result in the phased disturbance of up to 

7 4000 ac of terrestrial habitats and resources over a 100-year period, including approximately 

8 1140 ac of wetlands (BRA 2010). Terrestrial resources on the mine site are generally similar to 

9 those found on the LNP site and vicinity. Impacts on terrestrial resources would include upland 

10 and wetland habitat loss and fragmentation, hydrological alterations to adjoining wetlands, 

11 sedimentation and erosion, noise from blasting and operations, impacts from fugitive dust, and 

12 traffic-related wildlife mortalities. These impacts, while substantial, would be localized. Tarmac 

13 plans to mitigate for wetland impacts by conducting a variety of conservation measures on a 

14 4500-ac site adjacent to the proposed mine site that would be protected by a conservation 

15 easement. The Tarmac Mine would not be developed solely for providing fill material to the 

16 LNP site. The same would be true for other commercial mines used by PEF as sources of fill. 

17 Therefore only a portion of the impacts from any mine would be considered directly attributable 

18 to the LNP project. 

19 4.3.1.6 Terrestrial Monitoring 

20 PEF plans to perform monitoring for species and habitats as required by Federal and State 

21 regulatory agencies during site preparation and development at the LNP site and associated 

22 offsite facilities (PEF 2009a). To meet responsibilities under Section 7 of the ESA, the review 

23 team has prepared a biological assessment that documents potential LNP project effects on 

24 Federally listed threatened or endangered terrestrial species (see Appendix F). If adverse 

25 effects on Federally listed species are predicted, PEF would be required to comply with any 

26 monitoring specified in the Biological Opinion issued by the FWS. Monitoring of certain State 

27 listed species may be required by the FDEP (2010a). Bald eagle nests are documented near 

28 the LNP site and associated facilities. Monitoring could be required if development activities are 

29 anticipated to occur within 660 ft of active nests (FWS 2007; FFWCC 2008). No monitoring of 

30 recreationally important species is anticipated because these species and their habitat are 

31 locally abundant. 

32 Monitoring of wetlands during site preparation and development could be required under the 

33 CWA Section 404 permit issued by the USACE and the ERP issued by the State of Florida. 

34 PEF has prepared a wetland mitigation plan (Entrix 2010) to compensate for the loss or 

35 impairment of wetland functions during project development (see Section 4.3.1.7). It is 

36 expected that implementation of the wetland mitigation plan would begin during the 8-year 

37 project-development period. 
Construction Impacts at the Proposed Site 

Draft NUREG-1941 4-66 August 2010 

1 Monitoring of wetland and upland communities enhanced under the plan is an important 

2 component of this adaptive management plan. Monitoring would be conducted annually using 

3 permanent transects and sample plots located in habitats representing all vegetative 

4 communities present in mitigation areas (PEF 2009l). Data to be collected includes vegetative 

5 species composition and cover by stratum (e.g., ground, shrub understory, and tree canopy), 

6 hydrologic indicators (e.g., percent cover of water and water depth), invasive species presence, 

7 and documentation of wildlife observations. Transects and location data would be mapped 

8 using a global positioning system and selected sampling points would be photo documented. 

9 Monitoring results would be reported annually to appropriate regulatory agencies. 

10 PEF also plans to perform hydrological monitoring during temporary groundwater dewatering 

11 associated with excavation for the powerblocks. If any detrimental impact on water levels 

12 supporting adjacent wetlands were to be detected during monitoring, mitigative measures, such 

13 as additional drilling and grouting, sheeting, or re-design of the recharge basins, would be 

14 implemented (PEF 2009c). This monitoring is discussed further in Section 4.2.4. 

15 4.3.1.7 Potential Mitigation Measures for Terrestrial Impacts 

16 PEF has proposed mitigation measures intended to reduce and compensate for impacts on 

17 terrestrial resources expected during site preparation and development for the LNP project. A 

18 brief summary of these mitigation measures follows. 

19 Wetland Mitigation Plan 

20 PEF submitted a wetland mitigation plan to the FDEP on April 30, 2010 (Entrix 2010), fulfilling a 

21 State condition of certification imposed by the FDEP (2010a) under the Florida PPSA. The plan 

22 outlines compensation for the loss or impairment of functions in wetlands affected by both 

23 activities on the LNP site and on the associated offsite corridors, including transmission line 

24 corridors. Both the FDEP and the USACE will review the wetland mitigation plan for compliance 

25 with Federal Clean Water Act Section 404 and Florida ERP permitting processes. PEF is 

26 required under these Federal and State permitting processes to avoid or minimize wetland 

27 impacts to the extent practicable, and to mitigate for unavoidable impacts by fully offsetting the 

28 functional wetland losses predicted to occur from the LNP project. The wetland mitigation plan 

29 is based upon conservative wetland impact assumptions to ensure that adequate compensation 

30 is achieved. Impacts on both jurisdictional and non-jurisdictional wetlands are pooled for the 

31 impacts analysis, and both temporary and partial wetland impacts are treated as permanent. 

32 The extent of wetland impacts from building the transmission lines is a rough estimate because 

33 final rights-of-way have not been selected. Under the PPSA, final impacts would be determined 

34 through a post-certification process. Using conservative assumptions regarding the likely rights35 of-way ultimately selected for the transmission lines within the identified corridors, PEF 

36 estimated potential wetland impacts and calculated UMAM functional losses. To comply with 

37 USACE and FDEP regulatory requirements, PEF is obliged to minimize impacts on wetlands 
Construction Impacts at the Proposed Site 

August 2010 4-67 Draft NUREG-1941 

1 while routing final transmission-line corridors and during installation of the lines. Consequently, 

2 actual impacts likely would be less than those predicted due to the expected ability to identify 

3 practicable avoidance and minimization opportunities during upcoming detailed planning and 

4 development phases for each transmission-line segment. 

5 The wetland mitigation plan provides a landscape-level ecosystem benefit by enhancing and 

6 restoring ecological functions to several hundred acres of wetland habitat and supporting 

7 uplands in each watershed affected by wetland impacts (Entrix 2010). It identifies several 

8 geographically distinct mitigation parcels in each affected watershed that could be combined to 

9 achieve needed mitigation credits. The purchase of mitigation credits from established wetland 

10 mitigation banks was also considered; however, regional banks are unlikely to have enough 

11 available credits to fully meet PEF’s mitigation requirements. About half of the proposed 

12 wetland impacts (by acreage and relative functional loss of impact) would occur on or near the 

13 LNP site in the Waccasassa and Withlacoochee river watersheds. However, wetland impacts 

14 associated with the transmission-line corridors would span several other watersheds as small, 

15 disconnected, linearly distributed footprints of impacts. 

16 Most of the mitigation areas identified in the plan are former Florida flatwoods and wetlands that 

17 have been subjected to intense forest management. Most have been converted to pine 

18 plantations managed on a short harvest rotation of less than 30 years. Activities such as 

19 bedding, planting of slash pine, repeated harvesting, fire suppression, ditching, and road 

20 building and maintenance have severely degraded wetland functions and value. The wetland 

21 mitigation plan primarily targets the restoration and rehabilitation of degraded wetlands and 

22 uplands. Intensive commercial forest management would cease in mitigation areas, and pine 

23 plantations and other disturbed habitats would be restored to plant communities functionally 

24 similar to native upland and wetland habitats present prior to initial logging. Other mitigation 

25 activities would entail selective thinning of planted pines to more natural densities, targeted 

26 plantings of native species to improve species diversity, hydrologic restoration of wetlands 

27 (e.g., culvert removal, ditch plugging, and bed removal), control of invasive species, and the 

28 establishment of a prescribed fire regime (Entrix 2010). 

29 A UMAM assessment was completed to evaluate wetland functional losses from the LNP 

30 project and estimate wetland functional gains that could be realized with implementation of the 

31 wetland mitigation plan (Entrix 2010). Results are presented in Table 4-9. The preliminary 

32 assessment assumed the LNP project would result in a loss of approximately 289 UMAM 

33 functional units, spread over five watersheds. The plan could generate a functional lift 

34 (i.e., a gain in function) of approximately 490 UMAM units, substantially more than the minimum 

35 needed to achieve no net loss of wetland function. The net UMAM gain generated by 

36 implementation of the proposed mitigation would be approximately 201 lift units, or nearly a 70 

37 percent gain in functional value expressed in terms used by the UMAM process. The lift would 

38 be spread over all five affected watersheds, although not in exact proportion to the impacts. 
Draft NUREG-1941 4-68 August 2010 

Construction Impacts at the Proposed Site 

Table 4-9. Preliminary UMAM Assessment for the LNP Project 1 

Source: Entrix 2010. 2 (a) GSF – Goethe State Forest. 3 (b) Includes property south of the LNP site owned by PEF. 4 (c) WSF – Withlacoochee State Forest. 5 Impact Watershed 

UMAM Impact Units (Losses) 

Mitigation Component (Showing Watershed[s] Served) 

Action UMAM Lift Units (Gains) 

Wetland Upland Total 

Waccasassa -182.4 Daniels Island 

Tract, GSF(a)

Re-establishment and rehabilitation of wetlands on land owned by the Division of Forestry 

61.1 0 61.1 

LNP Site(b) Rehabilitation (enhancement) and preservation of 

wetlands and adjoining uplands on land owned by the applicant 

180.6 145.0 325.6 

Withlacoochee -50.1 

Boarshead Ranch Re-establishment, rehabilitation, creation, and 

preservation of wetlands on privately owned dedicated for conservation 

52.9 0 52.9 

Hillsborough -16.6 Upper Coastal -33.6 Five Mile Creek Re-establishment and creation of wetlands and 

rehabilitation of wetlands and adjoining uplands on land owned by Pasco County 

4.7 0.6 5.3 

Homosassa Tract, WSF(c)

Re-establishment of wetlands and rehabilitation of wetlands and adjoining uplands on land owned by the Division of Forestry 

34.3 1.8 36.1 

Tampa Bay -6.6 Brooker Creek Re-establishment and rehabilitation of wetlands on 

land owned by Pinellas County 

9.2 0 9.2 

Total -289.3 342.8 147.4 490.2 
Construction Impacts at the Proposed Site 

August 2010 4-69 Draft NUREG-1941 

1 The plan seeks to distribute lift to the benefit of all affected watersheds using a few strategically 

2 chosen locations that improve and expand existing conservation areas and meet regional 

3 watershed conservation goals. 

4 Avian Protection Plan 

5 In coordination with the FFWCC and FWS, PEF would be required to prepare an Avian 

6 Protection Plan as a condition of certification by the FDEP (2010a). The plan would seek to 

7 reduce the risk to birds posed by development and operation of the LNP transmission lines and 

8 other electric utility facilities with the goal of reducing avian mortality. The specific mitigation 

9 measures to be included in the plan would be developed concurrently with final design and 

10 routing of the transmission lines. Pursuant to PPSA, the determination of the final rights-of-way 

11 for the transmission lines would be determined through a post-certification process. 

12 Temporary Restoration Plan 

13 PEF would develop BMPs to restore temporarily disturbed areas on the LNP site and for the 

14 associated offsite facilities (PEF 2009e). Temporarily disturbed areas would be regraded to pre15 existing contours after development activities have ceased (PEF 2009c). Sediment- and 

16 erosion-control measures, such as silt fencing and seed mixtures, would be used to limit erosion 

17 and minimize impacts on terrestrial and wetland resources. Uplands would be seeded in 

18 accordance with project-developed sedimentation- and erosion-control plans, while wetlands 

19 would be allowed to regenerate naturally from the existing wetland seed bank (PEF 2009e). All 

20 vegetation-management activities would be supervised by PEF or qualified contractors under 

21 PEF control. Invasive species monitoring and control would be conducted as needed to 

22 promote restoration to desired conditions. 

23 4.3.1.8 Summary of Impacts on Terrestrial Resources 

24 The review team evaluated the potential impacts to terrestrial ecological resources from building 

25 the proposed LNP Units 1 and 2 and the associated offsite facilities, including but not limited to 

26 water pipelines, a heavy haul road, and transmission lines and substations. Development of the 

27 LNP project would proceed according to Federal and State regulations, permit conditions, 

28 existing procedures, and established BMPs. Permanent cover type (habitat) losses would total 

29 about 627 ac on the LNP site and roughly 2008 ac for the associated offsite facilities (offsite 

30 impacts for the transmission lines are based on preliminary rights-of-way) (Tables 2-6 and 2-7). 

31 Additional temporary habitat losses are estimated at about 150 acres for the LNP site and 30 ac 

32 for the associated offsite facilities (note – temporary impacts associated with transmission line 

33 installation are treated as permanent for this analysis). Up to an additional 250 ac of habitats 

34 (primarily degraded uplands) may have to be excavated to lower elevations to create enough 

35 
Construction Impacts at the Proposed Site 

Draft NUREG-1941 4-70 August 2010 

1 new floodplain storage capacity to compensate for LNP site encroachments into the 100-year 

2 floodplain; lands disturbed for floodplain expansion would, however, be restored to native 

3 vegetation. 

4 Although wetlands would be avoided to the extent possible, the proposed LNP project is 

5 estimated to permanently affect approximately 683 ac of wetlands (319 ac on the LNP site and 

6 roughly 364 ac for the associated offsite facilities) and temporarily impact another 90 ac of 

7 wetlands (84 ac on the LNP site and 6 ac for the associated offsite facilities) (Tables 2-6 and 

8 2-7). Because pre-project hydrology would be restored within no more than 4 years, additional 

9 temporary wetland impacts (not quantified) that may occur during dewatering are not considered 

10 significant. Many of the upland and wetland cover types that would be affected by the proposed 

11 development have been altered by prior land-use activities, particularly commercial forest 

12 management on the LNP site. Although the loss and alteration of wetlands are substantial, PEF 

13 has proposed a mitigation plan to compensate for the loss or impairment of functions in 

14 wetlands affected by development. Compensation for unavoidable wetland impacts is required 

15 under both the Clean Water Act Section 404 permit and the Florida ERP processes. 

16 Site preparation and development for the proposed LNP project would affect wildlife and 

17 important species as defined by the NRC. The review team has determined that habitat loss, 

18 hazards posed by site preparation, noise, collisions with elevated structures, and increased 

19 traffic may adversely affect wildlife. However, the impacts on wildlife populations are expected 

20 to be localized in their effect, and mitigable through onsite habitat enhancement and 

21 conservation measures. 

22 Federal and State-listed threatened and endangered species, at times, may occur on or in the 

23 vicinity the LNP site and the associated offsite facilities. As many as 32 listed wildlife species 

24 (9 Federally listed and 32 State-listed) and 76 listed plant species (13 Federally listed and 76 

25 State-listed) could be affected (see Table 2-8). To comply with Section 7 of the ESA, the review 

26 team has prepared a biological assessment that documents potential LNP project effects on 

27 Federally listed threatened or endangered terrestrial species. The biological assessment is 

28 provided in Appendix F. A condition of certification by the FDEP (2010a) would require protocol 

29 surveys for all State-listed species (excluding plants) that may occur on the LNP site and 

30 associated offsite facilities prior to land “clearing and construction.” If listed species are 

31 identified during predevelopment surveys or are encountered during development, this condition 

32 of State certification by FDEP also requires PEF to consult with the FFWCC to determine the 

33 need for appropriate mitigation (FDEP 2010a). Provided that adequate surveys are conducted 

34 prior to commencement of development, consultation with the FWS and FFWCC is initiated as 

35 needed, the wetland mitigation plan is initiated at the scope and scale proposed, and other 

36 identified mitigation is implemented, impacts on threatened and endangered species from the 

37 LNP project likely would be minimized. However, without proper surveys, consultation, and 

38 appropriate mitigation, the impact would be substantially greater. 
Construction Impacts at the Proposed Site 

August 2010 4-71 Draft NUREG-1941 

1 Based on the review team’s independent evaluation of the LNP project, including the ER, the 

2 SCA, PEF’s responses to NRC’s Requests for Additional Information, the identified mitigation 

3 measures and BMPs, and consultation with other federal and state regulatory agencies, the 

4 review team concludes that the impacts of construction and preconstruction activities to 

5 terrestrial ecological resources (including wetlands and threatened and endangered species) 

6 would be MODERATE. This moderate conclusion reflects the impacts on wetlands, wildlife, and 

7 Federally and State-listed species at the LNP site and the associated offsite facilities. Even with 

8 implementation of best management practices, the proposed wetland mitigation plan, and other 

9 mitigation outlined in the SCA application, the review team believes that the impacts to wetland 

10 and upland terrestrial habitats and their associated wildlife would still be noticeable in the 

11 surrounding landscape, especially in the short term. However, the review team also believes 

12 that the proposed mitigation measures, especially those in the wetland mitigation plan, would 

13 substantially offset the adverse losses to upland as well as wetland habitats in the long term. 

14 The review team therefore concludes that the terrestrial impacts resulting from the Levy project 

15 would not destabilize the continued existence of any wetland or upland habitats and associated 

16 wildlife in the surrounding landscape. 

17 The LWA rule (72 FR 57416) specifically states that transmission lines, pipelines, heavy-haul 

18 roads and other offsite actions that support the proposed LNP project are not included in the 

19 definition of construction. NRC-authorized construction activities would be limited to activities 

20 necessary to develop safety-related structures on the LNP site, a subset of the total 

21 development activities on the site analyzed above for impacts on terrestrial resources. NRC22 authorized construction activities with the potential to affect terrestrial species and habitats 

23 include the use of cranes and the erection of safety-related structures; movement of 

24 construction vehicles and heavy equipment around the site; the noise associated with 

25 construction, machinery, and testing of diesel and combustion turbine generators; and minor 

26 changes in surface-water drainage. These NRC-authorized construction activities are not 

27 expected to increase floral or faunal mortality rates enough to destabilize affected populations, 

28 and detectable changes in abundance would not be expected at a regional population level. In 

29 addition, impacts to wetlands and important terrestrial species during NRC-authorized 

30 construction activities are expected to be minor. Temporary water table fluctuations caused by 

31 dewatering the power block excavations during construction are not expected to affect wetland 

32 hydrology outside of the known range of natural periodic water table fluctuations. Based on 

33 these analyses, the NRC staff concludes that impacts to terrestrial ecological resources from 

34 NRC-authorized construction activities would be SMALL, and no mitigation beyond the actions 

35 stated would be warranted. 

36 4.3.2 Aquatic Impacts 

37 Impacts on the aquatic ecosystem from building proposed LNP Units 1 and 2 would mainly be 

38 associated with impacts on LNP site ponds, CFBC, Inglis Lock bypass channel, and the CREC 
Construction Impacts at the Proposed Site 

Draft NUREG-1941 4-72 August 2010 

1 Crystal Bay discharge area. A few small ponds that exist on the LNP site would be filled to 

2 accommodate preparation of facilities. The CFBC would be affected by the installation of a 

3 water-intake system, placement of discharge piping, and connection of a barge-unloading 

4 facility to the CFBC. The Inglis Lock bypass channel may be affected by building activities 

5 associated with crossing intake and discharge pipelines. The CREC discharge canal would be 

6 affected by installation of a discharge outfall. 

7 The Withlacoochee River, Hillsborough River, and other small lakes and streams are within 

8 existing transmission-line corridors and would be crossed by additional transmission lines. The 

9 new transmission lines are expected to span these waterbodies.

10 4.3.2.1 Aquatic Resources – Site and Vicinity

11 LNP Site 

12 A few of the intermittent ponds described in Section 2.4.2 would be permanently filled for 

13 preparation of facilities, but other onsite ponds would be unaffected. Ponds on the LNP site 

14 were examined visually for aquatic species and were not observed to have active populations of 

15 fish or macroinvertebrates due to the shallow or seasonal nature of these habitats. Years of 

16 forest-plantation activities on the LNP site potentially contributed to lack of viable aquatic 

17 communities in these resources (PEF 2009a). Erosion and runoff mitigation practices would be 

18 used to prevent siltation of preserved ponds onsite (PEF 2009i). Stormwater-management 

19 basins and cessation of forest-plantation activities on the site would likely create improved 

20 freshwater aquatic habitat (PEF 2009a). 

21 CFBC 

22 The installation of the intake structure, connection of a barge slip to the CFBC, and placement 

23 of discharge piping would result in temporary disturbances to the aquatic habitat in portions of 

24 the CFBC. Until excavation is complete, preparation of the barge slip would occur on the 

25 northern shore of the CFBC in upland areas behind an earth bank that separates the barge slip 

26 excavation activities from the CFBC (see Figure 3-1). The intake structure would be installed 

27 0.5 mi downstream of the Inglis Lock. Steel sheet piling would be installed at the barge slip and 

28 in a cofferdam for intake structure installation. Sheet piles would be driven from land using a 

29 pile hammer. Turbidity barriers and erosion-control measures would be installed in the canal 

30 during activities associated with sheet-pile installation to control impacts on water quality (Figure 

31 3-5). 

32 Building activities are expected to commence with installation of permanent piling over a 

33 60-week time frame for the barge slip and over a 13-week period for temporary piling at the 

34 intake structure. Removal of temporary piling at the intake structure is expected to occur after 

35 6 months of installation activities proposed for an October–March time frame. Turbidity barriers 
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August 2010 4-73 Draft NUREG-1941 

1 and erosion-control measures are expected to be installed commensurate with piling-installation 

2 activities and remain in place prior to operations (PEF 2008a). Use of BMPs and measures to 

3 control water quality should prevent adverse impacts to the few species that inhabit the portion 

4 of the CFBC near the proposed intake. Motile invertebrates, fish, sea turtles, or manatees may 

5 swim into this portion of the CFBC, but they would be able to swim away or likely would avoid 

6 the area due to vibratory noise. Mobile, benthic invertebrates in this area, primarily polychaetes, 

7 may be able to occupy adjacent habitat in the CFBC because installation activities would take 

8 place only along the northern shore. However, sessile invertebrates in this area, such as the 

9 false dark mussel (Mytilopsis leucophaeata) and barnacles (Chthamalus fragilis), would be 

10 affected by removal and modification of shoreline structures in the affected areas only. 

11 Section 4.3.2.3 of this chapter discusses additional concerns related to the impacts of building 

12 on important species. 

13 Dredging would be necessary for preparation of a trench for two 54-in.-diameter discharge pipes 

14 across the 150-ft width of the CFBC. PEF has committed to testing any sediments to be 

15 removed by dredging prior to dredging using EPA Method 1311 for toxicity characteristics for 

16 determination of final disposition of dredged spoil materials. Nonhazardous sediments would be 

17 used to backfill pipeline trench, as fill material onsite, or disposed of in upland areas. Sediments 

18 deemed unsuitable for use or placement in upland areas would be disposed of appropriately in 

19 landfills approved for hazardous disposal (PEF 2009k). In addition, PEF has stated that 

20 residual water from dredging activities would be tested for compliance with NPDES and Florida 

21 standards for surface-water quality (Fla. Admin. Code 62-302) before being returned to the 

22 CFBC. Discharge piping running from the LNP site to the CREC discharge would run parallel 

23 along the northern CFBC berm, enter and exit CFBC water supported by anchor piers along 

24 both CFBC berms, and run south to CREC along an existing transmission-line corridor (PEF 

25 2009a). Benthic habitat in the area proposed for discharge pipeline trenching is dominated by 

26 polychaete and oligochaete worms (CH2M HILL 2009b). Once pipeline installation is complete, 

27 these species may be able to colonize adjacent habitat and re-colonize original habitat. Motile 

28 invertebrates, fish, sea turtles, or manatees may swim into this portion of the CFBC, but they 

29 would be able to swim away or likely would avoid the area due to vibratory noise. 

30 Section 4.3.2.3 of this chapter discusses additional concerns related to building impacts on 

31 important species. 

32 Transportation of large components for building LNP will include use of barging in the CFBC to 

33 the barge-unloading facility. Barge traffic could interact with aquatic organisms (e.g., sea turtles 

34 and manatees) within the CFBC. 

35 Inglis Lock Bypass Channel 

36 Intake and discharge piping would be placed over the Inglis Lock bypass channel along an 

37 existing bridge and would not be placed in this waterbody. Pipeline placement over this 

38 waterbody would follow BMPs associated with stream-crossing regulations related to 
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Draft NUREG-1941 4-74 August 2010 

1 minimization of sedimentation and bank erosion (PEF 2009i). No aquatic impacts are expected 

2 to occur with this activity. 

3 CREC Discharge Canal 

4 The LNP discharge pipeline (two 54-in. high-density polyethylene pipes, according to the 

5 conceptual design) would discharge directly into the CREC onsite discharge – a concrete-lined, 

6 open channel just downstream of the discharge culverts for Units 4 and 5. This 0.7-mi open 

7 discharge channel drains directly into the Gulf of Mexico. A headwall structure would be 

8 necessary to join the LNP discharge piping to the CREC discharge (PEF 2009e). No building 

9 activities related to LNP would be conducted beyond the western terminus of the LNP headwall 

10 structure less than one mile from the Gulf of Mexico. No aquatic impacts are expected to occur 

11 with this activity provided appropriate BMPs are utilized during the construction of the headwall 

12 structure. 

13 4.3.2.2 Aquatic Resources – Transmission Lines 

14 PEF would site the new 500- to 230-kV and 65-kV transmission lines in accordance with 29 

15 Florida Statutes 403.501. In addition, PEF has committed to complying (PEF 2009a) with all 

16 applicable laws, regulations, and permit requirements and using good engineering and 

17 construction practices as required by FDEP (Fla. Admin. Code 62-17). PEF states that all work 

18 would be conducted in accordance with Federal and State permitting requirements for 

19 maintaining water quality and protecting natural resources, such as maintenance of a 15-ft or 

20 greater buffer of natural vegetation for installation near waterbodies (Citrus County 2006). PEF 

21 plans to leave a 25-ft buffer of existing vegetation with mature heights not exceeding 12 ft at 

22 locations where the transmission-line corridor crosses a navigable waterway (PEF 2008a). 

23 Permits required include a USACE Section 10 Rivers and Harbors Act Permit, FDEP ERP, 

24 FDEP and Southwest Water Management District dewatering permit, and a FDEP NPDES 

25 construction stormwater permit (PEF 2009a). County listings for threatened and endangered 

26 species have been identified for each delineated corridor. Although several threatened or 

27 endangered aquatic species are listed for Levy and Citrus Counties (as outlined in Section 

28 2.4.2), the activities associated with placement of new lines would not require in-water 

29 installation activities. Therefore, the review team finds that impacts on aquatic resources due to 

30 transmission-line preparation and installation would be minor. 

31 Beyond First Substation 

32 County listings for threatened and endangered species have been identified for candidate 

33 corridors in Hernando, Hillsborough, Pinellas, and Polk Counties. The Suwannee cooter 

34 (Pseudemys concinna suwanniensis), a State species of concern, and the State and Federally 

35 endangered Florida manatee (Trichechus manatus latirostris) are the only listed aquatic species 

36 likely to occur in waterbodies associated with transmission-line corridors in these four counties. 
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August 2010 4-75 Draft NUREG-1941 

1 Activities associated with placement of new lines would not require in-water installation 

2 activities. Therefore, the review team finds that impacts on aquatic resources due to 

3 transmission-line preparation beyond the first substation would be minor. 

4 4.3.2.3 Aquatic Species and Habitats 

5 Important Species and Habitats 

6 This section describes the potential impacts on important aquatic species resulting from site 

7 preparation for the new units at the LNP site, barge slip, intake structures, discharge structures, 

8 and addition of transmission lines in existing corridors. The review team has determined that 

9 building impacts on aquatic resources would be limited to the CFBC and the CREC discharge 

10 canal, excluding the Gulf of Mexico at the point of discharge and beyond. The general life 

11 histories of these species are presented in Section 2.4.2. The NRC staff prepared biological 

12 assessments and an essential fish habitat assessment (see Appendix F) documenting the 

13 impacts on the Federally listed threatened and endangered terrestrial species described in the 

14 FWS and NMFS correspondence (FWS 2009e; NOAA 2008a, b) associated with building a new 

15 nuclear unit. The NRC staff’s impact determinations from the biological assessments and 

16 essential fish habitat assessment are reiterated in this section. 

17 Commercial Species

18 With the exception of the blue crab (Callinectes sapidus), all commercial fishery activities occur 

19 well offshore of the CFBC and CREC point of discharge into the Gulf of Mexico. Commercial 

20 blue crab pots were observed by the review team within the lower portion of the CFBC on two 

21 separate occasions, with some sighted near the proposed trenching site for the discharge 

22 piping. Installation and dredging activities in this area may disrupt commercial harvest success, 

23 but these impacts are assumed to be temporary and minor with the use of BMPs to minimize 

24 sedimentation, and typical seasonal abundance should resume after building activities are 

25 completed. 

26 Recreational Species

27 Recreational angling occurs in the CFBC. Recreational angling also occurs in the vicinity of the 

28 CREC discharge canal, but is prohibited in the discharge canal. Building activities associated 

29 with the barge-unloading facility, intake structure, and discharge pipeline trenching may affect 

30 successful recreational angling in the vicinity of these activities due to avoidance by recreational 

31 species near any in-water work. These impacts are expected to be temporary and minor with 

32 the use of BMPs to minimize sedimentation and erosion to prevent degradation of water quality. 

33 It is expected that fish and crabs should resume use of the habitats within the CFBC after 

34 completion of building activities. 
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Draft NUREG-1941 4-76 August 2010 

1 Essential Species

2 The presence of forage fish within the CFBC is summarized in Table 2-14. Building activities 

3 associated with the barge-unloading facility, intake structure, and discharge pipeline trenching 

4 may affect the presence or habitat use by these forage species in the vicinity of these activities 

5 due to noise avoidance by recreational species. However, these impacts are expected to be 

6 temporary and minor because fish should return to these areas within the CFBC after 

7 completion of building activities. 

8 Rare Species

9 The speckled hind (Epinephelus drummondhayi) and the Warsaw grouper (Epinephelus 

10 nigritus) are both listed by NMFS as species of concern that are known to occur in inland waters 

11 of the Florida Gulf Coast. However, neither of these species was collected or observed within 

12 the CFBC, so any building-related impacts on these species are unlikely. Building activities 

13 within the CREC discharge canal would not occur outside the point of discharge of the canal 

14 into the Gulf of Mexico. Therefore, no building-related impacts are expected to occur. 

15 Federally and State-Listed Species 

16 As part of NRC’s responsibilities under ESA Section 7, the staff has prepared a biological 

17 assessment documenting potential impacts on the Federally listed threatened or endangered 

18 aquatic and terrestrial species as a result of the site building activities at the LNP site. The 

19 biological assessment is provided in Appendix F and the findings and determinations are 

20 summarized in this section. The NRC staff has determined that no critical habitat occurs near 

21 any of the planned building areas. 

22 Manatee – Federally Endangered

23 Manatees migrate to warmer waters in the winter near the coast, are known to occur in the 

24 CREC discharge canal particularly in the fall and winter (PEF 2008b), and have been sighted in 

25 the CFBC and Old Withlacoochee River (OWR, a remnant arm of the Withlacoochee River) 

26 throughout the year (CH2M HILL 2009c). Boating-speed restrictions are set by the FFWCC to 

27 limit the potential of boat and propeller strikes on manatees within the CFBC and the OWR 

28 (FFWCC 2002). Dredging activities likely would require work done from a vessel within the 

29 CFBC and must adhere to boating-speed regulations. To prevent impacts on manatees in the 

30 vicinity of building activities, as required by the FFWCC and USACE, PEF would comply (PEF 

31 2009a) with the Standard Manatee Conditions for In-Water Work (FDEP 2009b) for building 

32 activities in the CFBC. These conditions include halting all building-related activities if 

33 manatees are spotted within a 50-ft radius of the activity. A wildlife spotter is required during all 

34 building-related activities. 
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August 2010 4-77 Draft NUREG-1941 

1 While boating activities are not allowed within the CREC discharge canal, installation of 

2 discharge piping from the proposed LNP to the CREC may require in-canal activities. PEF has 

3 a Manatee Protection Plan approved by FDEP for minimization of hazards to manatees while 

4 performing in-water work, including avoidance of in-water work in the discharge canal from 

5 November 15 through March 31 when manatees use the warmer waters in this system as a 

6 refuge. 

7 Sea Turtles

8 Adult, subadult, and juvenile loggerhead sea turtles (Caretta caretta) are known to occur in the 

9 area of the CREC and may enter the CREC discharge canal or the CFBC. Juvenile green 

10 turtles (Chelonia mydas) and juvenile and subadult Kemp’s ridley turtles (Lepidochelys kempii) 

11 are also known to occur near the CREC discharge canal and may also enter the CFBC. 

12 Leatherback (Dermochelys coriacea) and hawksbill (Eretmochelys imbricata) sea turtles are 

13 rare off the coast of Levy and Citrus Counties and are not expected to occur near the dredging 

14 and installation activities associated with the proposed LNP. Sea turtles present in the CREC 

15 discharge canal or CFBC areas during building activities are likely to avoid disturbances and 

16 swim away. Sea turtles may be affected by barging traffic. The speed of the barges is low 

17 enough that turtles that come in contact with the barges or are entrained in the cavitations 

18 created by the moving barges would not be severely damaged (National Research Council 

19 1990). 

20 Smalltooth Sawfish – Federally Endangered

21 Although the spawning critical habitat for smalltooth sawfish (Pristis pectinata) is located along 

22 the southwestern coast of Florida, occurrence records indicate that juvenile sawfish are present 

23 near the CREC discharge and CFBC areas. However, adverse impacts are unlikely because 

24 these fish would avoid activities occurring in these areas. 

25 Gulf Sturgeon – Federally Endangered

26 Gulf sturgeon (Acipenser oxyrinchus desotoi) were not collected in sampling efforts and are not 

27 likely to be encountered during building activities in the CFBC or CREC discharge canal 

28 because neither of these areas is critical habitat or preferred spawning areas. However, if 

29 individuals are present adverse impacts are unlikely because juvenile or adult fish could avoid 

30 activities occurring in these areas. 

31 Aquatic Threatened and Endangered Species Summary 

32 Based on threatened and endangered species surveys, historical records, life-history 

33 information, known threatened and endangered species locations, and information provided by 

34 PEF in its ER and responses to RAIs, the review team concludes that the impacts on aquatic 
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Draft NUREG-1941 4-78 August 2010 

1 Federally listed threatened and endangered species from building activities on the LNP site 

2 would be minimal. A detailed account of the review team’s assessment can be found in 

3 Appendix F. 

4 Essential Fish Habitats 

5 The evaluation of essential fish habitat for both the CFBC and CREC discharge canal includes a 

6 determination of the presence of Habitat Areas of Particular Concern (HAPC), as well as a site7 specific assessment of essential fish habitat. HAPC are identified geographical areas that have 

8 elevated importance, provide important ecological functions, and are vulnerable to degradation. 

9 No HAPC occur in either waterbody or in associated Gulf of Mexico nearshore areas (NOAA 

10 2004). Site-specific assessment of essential fish habitat associated with the CFBC and CREC 

11 discharge canal are presented in Appendix F. Appendix F provides the known distributions and 

12 records of Ecoregion 2 listed species and life stages and the potential ecological impacts of 

13 building activities on the species, their habitat, and their prey. Based upon the project building 

14 plans, the minimal short-term impacts associated with the dredging, and intake installation, the 

15 review team believes that adverse effects on essential fish habitat that could be affected by the 

16 building of the LNP would be minimal. 

17 4.3.2.4 Aquatic Monitoring 

18 PEF plans to perform building-related monitoring in the CFBC associated with installation of the 

19 cooling-water intake structure (CWIS) and with placement of the discharge piping. Both 

20 installation activities would result in displacement of benthic invertebrates and building-related 

21 monitoring is intended to assess changes in this community. To determine recovery of benthic 

22 communities at these two locations, sampling events are planned for 6 months prior to 

23 installation activities, 1 year after installation activities, and 3 years after installation. Sampling 

24 at each area would be conducted using a Ponar dredge along transects directly along the 

25 dredged area and 500 ft upstream and downstream of the CWIS and discharge piping locations 

26 (PEF 2009a). 

27 During building activities, a biologist would be present to visually monitor for threatened and 

28 endangered species that may appear in the CFBC or CREC discharge areas (FDEP 2009b). 

29 Sea turtles and manatees might approach these areas, and their presence near the installation 

30 and dredging areas during activity may require a temporary halt of work (FDEP 2009b). PEF 

31 does not plan on any building-related monitoring of aquatic ecosystems during installation of the 

32 transmission lines. Because most of the new lines would follow existing corridors, no footings 

33 are planned for placement in waterbodies. 
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August 2010 4-79 Draft NUREG-1941 

1 4.3.2.5 Potential Mitigation Measures for Aquatic Impacts 

2 Impacts on aquatic resources are expected to be temporary and minor because fish and motile 

3 invertebrates likely avoid areas of building activities in the CFBC. Therefore, there are no plans 

4 for additional mitigation as a result of building activities. 

5 4.3.2.6 Summary of Impacts on Aquatic Resources 

6 Based on the information provided by PEF and the review team’s independent evaluation, the 

7 review team concludes that the impacts of construction and preconstruction activities on the 

8 freshwater, estuarine, and marine aquatic biota and habitats, including impacts on aquatic 

9 threatened and endangered species and other important species onsite, offsite, and within the 

10 transmission-line corridors would be SMALL, and no additional mitigation measures are 

11 proposed at this time. The LWA rule (72 FR 57416) specifically indicates that transmission lines 

12 and heavy-haul roads are not included in the definition of construction. Based on the 

13 expectation that no NRC-authorized construction activities would affect freshwater, estuarine, 

14 and marine aquatic biota and habitats, the NRC staff concludes that the impacts on aquatic 

15 resources due to NRC-authorized construction activities would also be SMALL. 

16 4.4 Socioeconomic Impacts 

17 Construction and preconstruction activities can affect individual communities, the surrounding 

18 region, and minority and low-income populations. This evaluation assesses the impacts of 

19 building-related activities and the construction workforce on the region. The review team 

20 reviewed the ER prepared by PEF and verified the data sources used in its preparation by 

21 examining cited references and independently confirming data in discussions with community 

22 members and public officials (NRC 2009). To verify data in the ER, the review team requested 

23 clarifications and additional information from PEF as needed. Unless otherwise specified in the 

24 sections below, the review team has drawn upon verified data from PEF (2009a, d, e, i, j). 

25 Where the review team used different analytical methods or additional information for its own 

26 analysis, the sections include explanatory discussions and citations for the additional sources. 

27 Although the review team considered the entire region within the 50-mi radius of the LNP site 

28 when assessing socioeconomic impacts, because of expected commuter patterns, the 

29 distribution of residential communities in the area, and the nature of the likely socioeconomic 

30 impacts, the review team identified a primary Economic Impact Area (EIA) composed of the 

31 three counties that surround the site – Levy, Citrus, and Marion – as the area with the greatest 

32 potential for economic impacts. 
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Draft NUREG-1941 4-80 August 2010 

1 4.4.1 Physical Impacts 

2 Construction and preconstruction activities can cause temporary and localized physical impacts, 

3 such as noise, fugitive dust, air emissions, and visual aesthetic disturbances. Many of these 

4 impacts can be mitigated. All of the mitigation activities discussed below were identified by PEF 

5 in its ER (PEF 2009a). Vibration and shock impacts are not expected because of the strict 

6 control of blasting and other shock-producing activities. This section discusses potential 

7 impacts on people, buildings, and roads from site-clearing and building activities. For more than 

8 a century, the LNP site has been used for forest plantation. Most of the LNP site would be 

9 preserved in its present condition with forest surrounding the industrial area. The closest 

10 residential properties are located 1.6 mi northwest and 1.7 mi west-southwest of the site. The 

11 nearest recreational resources are Goethe State Forest, the Marjorie Harris Carr Cross-Florida 

12 Greenway, Inglis Island Trail, Inglis Lock Recreation Area, and the CFBC (see Table 2-24). 

13 These recreational resources are located south and northeast of the site. PEF estimates the 

14 peak onsite workforce during the construction and preconstruction of LNP Units 1 and 2 to be 

15 3300 workers (specific assumptions are discussed in the following sections), with less than the 

16 total number of workers present onsite at one time because of shift work. 

17 4.4.1.1 Workers and the Local Public 

18 This section discusses potential impacts of air emissions and noise on workers, nearby 

19 residents, and nearby users of recreational areas. 

20 Fugitive dust and other air emissions would be generated by ground clearing, wind erosion, 

21 excavation, grading, cut-and-fill operations, a temporary concrete batch plant, and increased 

22 vehicular traffic. As discussed in Section 4.4.1.2 of the ER (PEF 2009a), Levy County is an 

23 attainment area for all criteria pollutants for which NAAQSs have been established 

24 (40 CFR 81.310). Ambient air quality would be affected by a temporary increase in fugitive 

25 particulate matter onsite and offsite along the pipeline and heavy-haul road and at the pump 

26 house and intake structure, and by emissions from construction equipment and vehicle exhaust. 

27 Emissions from construction equipment would include sulfur dioxide (SO2), nitrogen oxides 

28 (NOx), carbon monoxide (CO), and volatile organic compounds (VOCs) as well as particulate 

29 matter. The impacts on offsite receptors would be limited by the vegetation buffer around the 

30 area of the site that would be cleared – with the exception of activities along offsite areas of the 

31 pipeline and heavy-haul road and at the pump house and intake structure. 

32 BMPs and control measures would be used to limit the impacts of emissions. The concrete 

33 batch plant would be operated in compliance with FDEP regulations and would avoid emissions 

34 from trucks that otherwise would deliver concrete to the site. BMPs and control measures 

35 would include development and implementation of a fugitive dust-control plan, grading to 

36 promote drainage and minimize mud on vehicles, stabilization of ground surfaces as soon as 

37 practical after clearing (e.g., reseeding), wetting of bare ground and unpaved roadways during 
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August 2010 4-81 Draft NUREG-1941 

1 dry conditions, conducting any burning in accordance with applicable regulations and forest-fire2 safety measures, and inspecting and servicing construction equipment regularly (PEF 2009a). 

3 Noise associated with the use of substantial numbers of vehicles and equipment would be 

4 expected to raise background noise levels, principally during daytime hours. To limit onsite 

5 noise impacts, workers would use noise protection as required by the Occupational Safety and 

6 Health Administration (OSHA) when engaging in work subject to noise hazards. A noise 

7 analysis of the LNP project, conducted in March 2008 as part of the LNP’s Site Certification 

8 Application to the State of Florida, indicated that during certain activities, such as pile driving, 

9 noise would be perceptible from the nearest offsite locations, i.e., the recreational resources and 

10 the nearest residences. The analysis found that noise levels associated with most building 

11 activities would be below the daytime noise limit under Levy County’s Noise Ordinance (Levy 

12 County Code 50-349 2008) for residential, rural, and commercial districts. To limit noise 

13 impacts at offsite locations, PEF would develop and implement BMPs such as scheduling 

14 activities with high noise levels during daytime hours and maintenance of mufflers on engines 

15 (PEF 2009a). 

16 People living near the LNP site or using the local recreation areas would not experience any 

17 building-activity-related noise or air quality impacts greater than those that would be considered 

18 an annoyance or nuisance because of their distance from the activities and the vegetation 

19 screening, both of which would limit exposure. Construction and preconstruction activities 

20 would be performed in compliance with Federal, State, and local regulations and site-specific 

21 permitting conditions, as well as the BMPs already mentioned. Consequently, the review team 

22 expects that air quality and noise impacts at the LNP site would be minimal, and no further 

23 mitigation would be warranted beyond what is identified in the ER. 

24 4.4.1.2 Buildings 

25 The LNP site is a greenfield site that has no onsite buildings. Construction and preconstruction 

26 activities would not affect any offsite buildings due their distance from the site. 

27 4.4.1.3 Roads 

28 Public roads, a private haul road, and barges would be used for the transport of materials and 

29 equipment. Roads within the vicinity of the LNP site would experience an increase in traffic at 

30 the beginning and the end of each shift (see Section 4.4.4.1). Commuter, delivery, and 

31 construction equipment traffic would be controlled by onsite speed limits. The access road from 

32 the west to the LNP site would be paved. Stabilizing and wetting unpaved roads and cleared 

33 areas onsite would be an established dust-control measure. Other measures would reduce the 

34 potential traffic noise and vehicle exhaust impacts generated by the transport of materials, 

35 equipment, and workers onsite and entering and leaving the LNP site. For these reasons, the 
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Draft NUREG-1941 4-82 August 2010 

1 review team determined that project-related physical impacts on roads within the vicinity of the 

2 site would be minimal, and additional mitigation would not be warranted. 

3 4.4.1.4 Aesthetics 

4 Most of the LNP site would be preserved in its present condition with forest surrounding most of 

5 the site. Vegetation and distance would screen construction and preconstruction activities from 

6 most offsite viewers, including the closest residences. Recreational users would be able to see 

7 the construction site from portions of Goethe State Forest near the north site boundary where 

8 vegetation would be cleared. Building activities would also be seen from portions of the 

9 Marjorie Harris Carr Cross-Florida Greenway, the Inglis Island Trail, the Inglis Lock Recreation 

10 Area, near the intake structure and pump house where there is no existing vegetation, and 

11 along transmission-line corridors or the pipeline corridor where vegetation would be cleared. 

12 Users of the local recreation areas may choose to avoid locations near the site. If so, this 

13 potential displacement would be a slight impact because other parts of these recreation areas 

14 would be available and unaffected by building activities and other recreational facilities farther 

15 away, but still within the region, would be available for use. 

16 Long-term visual impacts would result from the building of some of the LNP components. The 

17 central industrial area, pipeline, intake structure, and pump house would be cleared, 

18 permanently replacing existing vegetation with maintained grass. While the central industrial 

19 area would be screened from offsite viewers by forest vegetation, other components would be 

20 visible. The area surrounding the site in the vicinity of the proposed pipeline, haul road, intake 

21 structure, and pump house presently includes some mixed development and visual intrusions 

22 on the forest/forested wetland landscape, such as roads, powerlines, commercial development, 

23 and land clearing along the CFBC (PEF 2009a). Additional clearing and structures would create 

24 minor aesthetics impacts in these areas. In places requiring the clearing of new transmission25 line corridors, aesthetic impacts would be noticeable but not destabilizing depending upon the 

26 location of viewers and the nature of vegetation remaining between them and the corridors. 

27 4.4.1.5 Summary of Physical Impacts 

28 Based on the information provided by PEF (PEF 2009a), the review team’s independent 

29 analysis, and taking into account the BMPs and mitigation measures identified, the review team 

30 concludes that the overall physical impacts of construction and preconstruction on workers and 

31 the local public, buildings, and aesthetics near the LNP site would be SMALL, although localized 

32 MODERATE impacts would be felt along newly cleared transmission-line corridors. 
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August 2010 4-83 Draft NUREG-1941 

1 4.4.2 Demography 

2 PEF (PEF 2009a) estimates the peak workforce during construction and preconstruction would 

be 3300 workers, with the peak workforce by year during this period estimated as follows(a) 3 : 

4 • 2012: 750 workers 

5 • 2013: 1000 workers 

6 • 2014: 1950 workers 

7 • 2015: 3100 workers 

8 • 2016: 3300 workers 

9 • 2017: 2900 workers 

10 • 2018: 1250 workers 

11 • 2019: 100 workers. 

12 PEF indicates that 140 operations engineers who would be working during the construction and 

13 preconstruction phases are included among these workers, about half of whom would be onsite 

14 at any time (PEF 2009d). The impacts associated with these operations workers during the 

15 construction and preconstruction phases are found in this chapter, and the underlying 

16 assumptions for their demographic effects are discussed in Section 5.4. 

17 PEF assumes preconstruction would start with site preparation in 2012 or 2013, which would 

18 extend for 1.5 years (18 months). NRC-authorized construction activities on Unit 1 would then 

19 start, followed a year later by NRC-authorized construction activities on Unit 2. Construction on 

20 each unit would extend for about 3.5 years (42 months). Before starting commercial operation, 

21 each unit would undergo about 6 months of testing. PEF expects Unit 1 to begin commercial 

22 operation in 2018 or 2019 and Unit 2 to begin commercial operation in 2019 or 2020. PEF 

23 anticipates peak employment would occur in 2016 (PEF 2009a). 

24 As indicated in Section 2.5.2.1, qualified workers exist in this region of Florida in many of the 

25 heavy-construction trade groups that would be needed for construction and preconstruction 

26 activities, but not in sufficient numbers or with all of the special skills that would be needed for 

27 the plant. Thus, workers from outside the EIA and region would be needed. 

28 Based on PEF’s estimates of phase duration and schedule, the review team assumes the 

29 following, for the purpose of this study: 

30 • Site preparation would start in 2012, peak employment would be reached in 2016, Unit 1 

31 would commence commercial operation in 2018, and Unit 2 would commence 

32 commercial operation in 2019. 

 

(a) The review team understands that project scheduling is subject to change, and that actual years 

portrayed in this discussion may not be the actual years of construction. However, the review team 

believes the general sequence and the magnitude of the estimated work force are accurate.
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Draft NUREG-1941 4-84 August 2010 

1 • Fifty percent of the workers and their families would move their place of residence to the 

2 50-mi region surrounding the LNP site. 

3 • The place of residence for in-migrating workers and the distribution of indirect jobs they 

4 create within the EIA would be 20 percent in Levy County, 45 percent in Citrus County, 

5 20 percent in Marion County, and 15 percent divided among the other 8 counties within 

6 50 mi of the site. 

7 • The average household size of the in-migrating workforce would be 2.49 persons (State 

8 of Florida average). 

9 • The job of each worker migrating into the EIA would support the generation of an 

10 additional 0.6 indirect jobs in the EIA (BEA 2009). 

11 • The indirect jobs created as a result of the LNP would be filled by people already 

12 residing in the region, some of whom would be unemployed without the project. 

13 • At some point after the peak employment, 500 Unit 1 operations workers would begin 

14 arriving on the site. Additional operations workers for Unit 2 would arrive subsequently. 

15 The impacts from these operations workers are addressed in Section 5.4. 

16 The review team projects that 4110 people (in-migrating construction workers and their families) 

17 would have moved into the region at peak employment (2016), 85 percent of whom would move 

18 into the EIA. An additional 244 in-migrating operations workers and their families would have 

19 moved into the region at peak employment, 80 percent into the EIA, for a total increase of 3689 

20 people in-migrating into the EIA during the peak year (2016). These people would be 

21 distributed among Levy (859 at peak), Citrus (1935 at peak), and Marion (895 at peak) 

22 Counties. This increase would be approximately 0.61 percent of the entire EIA population 

23 projected for 2015 (Table 2-16) when the construction and preconstruction workforce is 

24 expected to be near its peak. The increase for Levy County is projected to be 1.85 percent, 

25 1.20 percent for Citrus County, and 0.23 percent for Marion County. The review team assumes 

26 that the characteristics of the additional population are reasonably approximated by the 

27 characteristics of the current population shown in Tables 2-19, 2-20, and 2-21. The review team 

28 determined that the overall population increase would not be noticeable within the EIA. 

29 4.4.3 Economic Impacts on the Community 

30 This section evaluates the social and economic impacts of construction and preconstruction 

31 on the area within 50 mi of the LNP site, focusing primarily on the three counties of the EIA – 

32 Levy, Citrus, and Marion. The evaluation assesses the impacts and demands placed by the 

33 larger workforce on the surrounding region. Key assumptions relate to the number and value of 

34 new jobs and where jobholders would reside. 
Construction Impacts at the Proposed Site 

August 2010 4-85 Draft NUREG-1941 

1 As indicated in Section 4.4.2, the assumption that 50 percent of the workforce would come from 

2 outside the region acknowledges the availability of some heavy-construction workers within the 

3 region and in the EIA. Historically, the area has experienced a relatively low unemployment 

4 rate. Therefore, since some workers would remain employed elsewhere in the region, and that 

5 some special skills for nuclear power plant production would not be present within the region 

6 demonstrates the demand for in-migrating workers. The review team determined that an 

7 assumption that 50 percent of the workforce would in-migrate is reasonable. The impacts of a 

8 different level of in-migration could be estimated by adjusting the impacts discussed below by 

9 the appropriate factor. 

10 As indicated in Section 4.4.2, the review team assumed the place of residence for in-migrating 

11 workers within the EIA would be 20 percent in Levy County, 45 percent in Citrus County, and 20 

12 percent in Marion County. Of the remaining 15 percent of in-migrating workers, the review team 

13 assumed that 7 percent would move into Alachua County and 2 percent (each) would move into 

14 Dixie, Gilchrist, Hernando, and Sumter Counties. Table 4-10 shows the expected distribution of 

15 in-migrating workers in the EIA at peak employment. 

16 The review team’s assumptions about the distribution of in-migrating workers differ from those 

17 PEF used in its ER. The review team determined that there was adequate housing capacity in 

18 each one of the counties in the region for the 1650 worker households expected at peak. Given 

19 this availability of housing, the review team assumed, based on experience at other construction 

20 sites, that workers would consider commute time, the quality of housing (including availability of 

21 rental units and space for motor homes), and, to some extent, access to amenities, such as 

22 shopping and healthcare, in selecting residence location. Local officials familiar with the area 

23 also provided input about the likely distribution of workers (NRC 2009). 

24 Levy, Citrus, and Marion Counties offer a number of residential areas within a 40-minute driving 

25 time of the LNP site (see Table 2-28). In part because of development that followed 

26 construction of the CREC, Citrus County offers proportionally more housing and amenities than 

27 Levy and Marion Counties within the 40-minute driving time. Ocala (in Marion County) and 

28 Gainesville (in Alachua County) are larger cities with more amenities that would be accessible 

29 for occasional visits, but these would be expected to see relatively fewer in-migrant workers 

30 because they are a 50- to 70-minute commute from the site. The other counties also are at 

31 least 60 minutes away. 

32 4.4.3.1 Economy 

33 The impacts of the project during construction and preconstruction on the local and regional 

34 economy depend on the region’s current and projected economy and population. For this 

35 analysis, the review team assumes that if a COL is issued, site clearing and building activities 

36 would begin in 2012 and end in 2018 for LNP Unit 1 and in 2019 for LNP Unit 2, with 

37 commercial operation beginning in 2018 for Unit 1 and 2019 for Unit 2. 
Draft NUREG-1941 4-86 August 2010 

Construction Impacts at the Proposed Site 1 Table 4-10. New Jobs at Peak Employment During Construction and Preconstruction Activities (Estimated 2016) 2 County Percent of In-migrating Workers Jobs Filled by In-migrating Workers New Indirect Jobs Supported by Building Jobs Total LNP- Related Jobs (in-migrant plus local) Jobs Filled by In-migrating Operations Workers New Indirect Jobs Supported by Operations Jobs Grand Total of LNP- Related Jobs at Peak Employment 2005 Employ- ment 2005 Unemploy- ment 2005 Number of Un- employed Levy 20 330 198 858 15 18 891 15,829 3.7% 614 Citrus 45 743 446 1931 34 41 2006 48,761 4.2% 2140 Marion 20 330 198 858 29 35 922 120,098 3.7% 4723 EIA 85 1403 842 3647 78 94 3819 184,688 3.9% 7477 Source: For employment and unemployment numbers: BLS 2005. Other numbers based on 3300 peak employment, BEA multipliers, and 50 percent in-migrant EIA = economic impact area 
Construction Impacts at the Proposed Site 

August 2010 4-87 Draft NUREG-1941 

1 When a new job is added to the economy, that new (direct) job supports the existence of other 

2 (indirect) jobs through the following process. Every new direct job in a given area – in this, 

3 case, a job building the LNP – stimulates spending on goods and services. This spending 

4 results in the economic need for a fraction of another indirect job, typically in the service 

5 industries. The U.S. Department of Commerce Bureau of Economic Analysis (BEA), Economics 

6 and Statistics Division, provides regional multipliers for industry employment and earnings. The 

7 review team obtained multipliers from the BEA for the EIA. The review team was advised that 

8 1.6 was the expected employment multiplier for the construction and preconstruction jobs 

9 created by the LNP project, and 2.2 was the expected employment multiplier for the operations 

10 jobs created by the project. That is, 1.6 minus 1, or 0.6, jobs would be supported for every 

11 construction and preconstruction job, and 2.2 minus 1, or 1.2, jobs for every operations job in 

12 the EIA (BEA 2009). The BEA employment multiplier is applied to only in-migrating workers 

13 because the BEA model assumes the direct employment of workers that already live in the area 

14 would have no additional impact on employment. The review team cautions that use of these 

15 multipliers provides only rough indications of what may be expected as a result of new jobs. 

16 Table 4-10 lists the total number of jobs created by the proposed project and filled by existing or 

17 in-migrating workers at the peak of construction employment in the EIA. It also provides 2005 

18 employment and unemployment numbers for these counties as well. The table demonstrates 

19 that jobs related to building the LNP, both direct and indirect, would be a small percentage of 

20 total jobs in each county. These jobs would not noticeably affect unemployment numbers, with 

21 the exception of Levy County where the review team anticipates 546 new (direct plus indirect) 

22 jobs for people already in the county, which is close to the 616 unemployed in 2005. Thus, the 

23 review team finds that the project would have a minor beneficial impact on unemployment in 

24 Citrus and Marion Counties throughout the building phase, but would have a noticeable and 

25 beneficial impact on unemployment in Levy County for 2 to 3 years around the peak of 

26 employment. 

27 PEF (2009d) found the average annual income for heavy-construction workers in Florida to be 

28 $45,919 in 2007 dollars, resulting in an estimated $151.5 million in annual salaries for the peak 

29 workforce, which includes $75.8 million annual salaries for the 1650 in-migrating workers at 

30 peak employment. The income for the peak workforce in the EIA would be $128.8 million in 

31 annual salaries, including $64.4 million for the 1403 in-migrating workers at peak employment. 

32 The income for the operations workers present during construction and preconstruction would 

33 be $12.3 million in the region, including $6.9 million for the in-migrating workers in the EIA at 

34 peak employment, assuming an $88,000 annual salary as discussed in Section 5.4.3.1. The 

35 review team believes these incomes represent a lower bound on the actual peak income 

36 because some of the skills required for nuclear power plant construction would command higher 

37 salaries than the highest salaries paid to other heavy-construction workers in Florida. In 

38 addition to the salaries of incoming construction, preconstruction, and operations workers, the 

39 review team estimated that the new indirect jobs would generate $34 million in salaries in the 
Construction Impacts at the Proposed Site 

Draft NUREG-1941 4-88 August 2010 

1 EIA based on the estimated median household income for the EIA in 2005–2007 (USCB 2009a, 

2 b, c). The result would be almost $170 million in earnings in the EIA in the peak employment 

3 year. This is slightly less than 3 percent of the total 2005 earnings of more than $6 billion in the 

4 EIA (see Table G-5). For Levy County, the earnings of all construction, preconstruction, and 

5 operations workers and associated indirect jobs would total more than $39 million in the peak 

6 year – more than 10 percent of the 2005 earnings in the county. For Marion County, the 

7 earnings of all construction, preconstruction, and operations workers and associated indirect 

8 jobs would total more than $41 million in the peak year – slightly less than 1 percent of the 2005 

9 earnings in the county. For Citrus County, the earnings of all construction, preconstruction, and 

10 operations workers and associated indirect jobs would total more than $89 million in the peak 

11 year – more than 6 percent of the 2005 earnings in the county. 

12 The $45,919 average heavy-construction salary would be higher than the per capita income in 

13 the region (see Table 2-22). Even in counties such as Levy, Dixie, and Gilchrist, which have 

14 small workforces, the relatively small number of new heavy-construction jobs would have only a 

15 minor impact on per capita income, even in peak years. 

16 The review team was advised by BEA that 1.5 was the expected earnings multiplier for 

17 construction work in the EIA, and 1.4 was the expected earnings multiplier for operations work 

18 in the EIA. The appropriate earnings multiplier is applied to all construction, preconstruction, 

19 and operations jobs because the BEA model assumes that wages are an infusion to the general 

20 economy. The review team applied the appropriate earnings multipliers to total annual 

21 construction, preconstruction, and operations salaries during the peak year in the EIA, resulting 

22 in an estimated $210 million in economic impact. 

23 As shown in Table 10-4 and explained in Section 10.6.2.1, the review team estimates that the 

24 total cost of constructing the two LNP units would be $14.1 billion in 2008 dollars, including 

25 labor. PEF (2009a) assumes that 10 percent of its expenditures for materials would be within 

26 the region. This would amount to a maximum of $1.41 billion over 6 years, assuming all non27 labor costs were for materials. This would average $235 million/year for materials and products 

28 from the region. The review team has determined that beneficial economic impacts could be 

29 experienced throughout the region. The increase in employment, earnings, and expenditures 

30 within Levy County during peak employment would have a noticeable beneficial effect. In the 

31 region as a whole, the increase in employment, earnings, and expenditures from direct and 

32 indirect jobs and purchases associated with building the LNP would have a minor beneficial 

33 effect on the economy of the region. 

34 4.4.3.2 Commercial Fishing 

35 As noted in Section 4.3.2.3, the review team found that with the exception of the blue crab, all 

36 commercial fishery activities occur well offshore of the CFBC and CREC point of discharge into 

37 the Gulf of Mexico and would not be affected by construction and preconstruction activities. 
Construction Impacts at the Proposed Site 

August 2010 4-89 Draft NUREG-1941 

1 With regard to commercial blue crab, installation and dredging activities may disrupt commercial 

2 harvest success near barge sites and intake/outflow structures, but the review team expects 

3 these impacts will be minor and temporary with the use of BMPs. 

4 4.4.3.3 Taxes 

5 Primary tax revenues associated with construction and preconstruction of the LNP would be 

6 from property tax for the site and from sales and use taxes on goods and services purchased for 

7 construction and preconstruction and by workers. Corporate income taxes would not be applied 

8 until the units were in operation because PEF would not earn income until that time. Florida has 

9 no personal income tax. 

10 Property Tax 

11 As indicated in Section 2.5.2.2 and according to the Levy County tax collector (NRC 2009), tax 

12 on the LNP site is currently calculated by applying the current millage rate (15.78 in 2008) to the 

13 assessed value of the land after reducing the value by 90 percent for its agricultural exemption. 

14 The site currently is in multiple parcels that had not been merged as of December 2008. Before 

15 site preparation, PEF would continue to pay property tax according to the millage rate in effect 

16 for the site’s assessed value reflecting the agricultural exemption. According to the Levy County 

17 assessor (NRC 2009), the county would remove the exemption for a parcel once site 

18 preparation begins and reassess it at the value of the property according to its future use (as a 

19 power plant). As PEF completes ancillary buildings, Levy County would reassess the value of 

20 the property to include the value of improvements. This could be done before either of the 

21 reactor buildings is completed. Levy County has not completed its appraisal process of land to 

22 be used as a power plant and is unable to advise what that value would be or how it would treat 

23 the assessment of improvements to the land. Consequently, the review team applied PEF’s 

24 estimates of tax on the completed facilities. 

25 The review team estimated a lower bound for tax revenues as follows. The Levy County tax 

26 assessor indicated that property in Levy County that is in agricultural use can receive up to a 

27 90-percent exemption in its property tax. The LNP property is currently a forested plantation 

28 and would lose that exemption once construction begins on the proposed two units. Based 

29 upon the tax assessor information that a typical rural 125-ac parcel in 2008 had an assessed 

30 value of $219,000 ($1752 per acre), the review team estimated the LNP property in its current 

31 state would have an assessed value of $5,439,960 (NRC 2009). Applying the exemption to the 

32 entire LNP site, the tax payment to Levy County in 2008 would have been $8584 ($15.78 per 

33 $1000 for 10 percent of $5,439,960). Without the exemption, the increased annual revenue 

34 would be $77,259. Against Levy County’s annual property tax revenue of $18 million, this would 

35 have a minimal effect. 
Construction Impacts at the Proposed Site 

Draft NUREG-1941 4-90 August 2010 

1 Once the facility is substantially completed, Levy County would reassess property values and 

2 receive additional taxes that cannot be reasonably estimated at this time. 

3 Once the project is completed, the value of the LNP property would be assessed at the value of 

4 construction cost, less the cost of pollution-control components, or approximately three-quarters 

5 of the total construction cost based on the historical costs of pollution-control components of the 

6 nuclear facility at CREC (PEF 2009m). The millage rate then in force would be applied to the 

7 new value; approximately $10.6 billion (see Section 10.6.2.1). The impact of these property tax 

8 revenues is discussed in Section 5.4. 

9 Sales and Use Taxes 

10 Many of the materials and items of equipment purchased for construction and preconstruction of 

11 the LNP would fall under Florida’s steam-production and pollution-control exemptions (Florida 

12 Statutes, Sections 212.051(1) and 212.08(5)(c)) and would not generate sales or use tax 

13 revenue. Based on PEF’s assumption that one-quarter of the estimated $234 million/year the 

14 project would spend in the region, or about $59 million, was not exempt, these purchases would 

15 generate a maximum of $3.5 million in sales tax revenue at 6 percent, with additional tax 

16 revenue up to 1 percent of $59 million, or about $590,000, for purchases in counties with a 

17 surtax (see Section 2.5.2.2). The added sales tax collected in the region for purchases would 

18 be less than 1 percent of the $712 million collected in 2004–2005 (see Table 2-23). In addition 

19 to surtax collected where applicable, each county would also receive its share of the one-half 

20 percent of the 6 percent base sales tax that is returned to counties by the State (about $17,500). 

21 These are a small proportion of the annual tax revenues in each of the counties in the EIA (see 

22 Table G-6 in Appendix G). 

23 Nonexempt material and equipment bought outside the region or outside of Florida would also 

24 be subject to Florida sales or use taxes. Assuming that one-quarter of the 90 percent of 

25 materials bought outside the region or the State was non-exempt, this would be 

26 $529 million/year (one-quarter of 90 percent of $14.1 billion divided by 6 years). At 6 percent, 

27 this would generate an additional $32 million in sales and use tax revenue to the State. 

28 Combining in- and out-of-State purchases, the total annual sales and use tax revenue would be 

29 about $35.5 million or less than 2/100 of 1 percent of the $19.9 billion annual sales tax revenue 

30 collected in 2004–2005 (see Table 2-23). 

31 Some of the earnings of workers and local residents who take the indirect jobs created by the 

32 multiplier effect would be spent on goods and services subject to sales tax. The review team 

33 estimated State sales tax revenue could increase by $3 million during the peak-employment 

34 year, assuming that about one-quarter of the $168 million total earnings in the EIA, or $42 

35 million, is subject to sales tax. A maximum of 1 percent, (about $420,000) would be collected 

36 for county surtaxes. In addition, one-half percent (about $210,000) would be distributed in the 

37 
Construction Impacts at the Proposed Site 

August 2010 4-91 Draft NUREG-1941 

1 EIA and the local governments within it as their one-half-percent share of the 6-percent State 

2 tax. These are small percentages of the annual tax revenue in the EIA (see Table G-6 in 

3 Appendix G). 

4 The review team concludes that construction and preconstruction of the LNP would have minor 

5 beneficial impacts on tax revenue in the EIA, the region, and State. 

6 4.4.3.4 Summary of Economic Impacts on the Community 

7 Based upon information provided by PEF in its ER and its own independent analysis, the review 

8 team determined that the economic impacts would be MODERATE and beneficial for Levy 

9 County and SMALL and beneficial for the rest of the EIA and the region. The review team also 

10 determined that the tax impacts from construction and preconstruction activities would be 

11 SMALL and beneficial for the entire EIA and region. 

12 4.4.4 Infrastructure and Community Service Impacts 

13 This section provides the estimated impacts on infrastructure and community services to include 

14 transportation, recreation, housing, public services, and education. 

15 4.4.4.1 Transportation 

16 Public roads and the CFBC would be used to transport construction materials and equipment to 

17 the LNP site. Material from a barge slip at the CFBC would be transported on a private heavy18 haul road crossing CR-40 using standard 15-T trucks or, for certain modules, a special heavy19 haul crawler. 

20 The review team’s analysis draws on a traffic study conducted by Kimley-Horn and Associates 

21 (Kimley-Horn or KH) to determine the impacts of construction, preconstruction, and operation of 

22 the LNP site on the surrounding road network (Kimley-Horn 2009). The KH study adopted Levy 

23 County’s level of service (LOS) standards for roads in the county (Levy County 2008). The 

24 study considered the roads likely to be used to transport construction materials and equipment 

25 to the LNP site and to transport commuting workers to and from the site. KH used 24-hour 

26 traffic counts collected in July 2008 from a previous study (Kimley-Horn 2009), 2007 24-hour 

27 counts from the FDOT, and p.m. peak hour counts collected in November and December 2008 

28 by KH staff. 

29 In considering future traffic volumes for the peak employment, the KH study included projected 

30 traffic volumes from the planned Tarmac King Road Limestone Mine in the area and considered 

31 a 2.2-percent annual growth rate for existing traffic. In calculating traffic during a.m. and p.m. 

32 peaks, the study considered vehicles with construction workers (3300), operations workers 
Construction Impacts at the Proposed Site 

Draft NUREG-1941 4-92 August 2010 

(500)(a) 1 , trucks and other construction vehicles (150), daily vendor trucks (5), and the commodity 

delivery-truck fleet (15). Assuming 1.8 workers per car, the KH study estimated 2262(b) 2 project 

3 trips each way during peak employment – daily to and from the LNP site in two shifts (split 

4 70/30 percent). 

5 Using a model based on the population of communities within 35 mi of the site, the KH study 

6 found that construction-related traffic along US-19 would be split 30 percent to and from the 

7 north and 70 percent to and from the south. Of the 70-percent traffic from the south, most (65 of 

8 the 70 percent) would come to Crystal River and other points along US-19, while 5 of the 

9 70 percent would use CR-40, with 4 percent to and from Inglis, Dunnellon, and other points to 

10 the east and 1 percent to and from the west. Of the 30-percent traffic from the north, 26 percent 

11 is projected to come to and from State Route 121 (SR-121), which traverses the city of Williston, 

12 northeast of the site, and 4 percent from farther north on US-19. Based on its own assessment 

13 of worker distribution, the review team determined that the study’s assumption of a 70-30 split 

14 between north and south was consistent with the review team’s expected traffic patterns and 

15 that the review team could rely on the traffic study’s results. 

16 Using the KH study’s assumption of 1.8 workers per vehicle, at peak employment, 397 vehicles 

17 would come into the plant site from the north and 1025 vehicles from the south in the morning. 

18 Assuming two 12-hour shifts, 165 vehicles would leave to the north and 385 vehicles would 

19 leave to the south at the same time. In the evening, these traffic patterns would be reversed. In 

20 addition, the review team estimates that approximately 170 trucks would be entering and 

21 leaving the site each day, primarily during non-peak daytime hours. 

22 Given these assumptions for traffic patterns, the KH study examined roadway segments in 

23 which LOS could be affected by project-related traffic on US-19, SR-121, and a short segment 

24 on US-41. The study also examined US-19 from SR-121 to the project site and CR-40 from US25 19 to the heavy-haul road crossing. In addition, the study looked at the following intersections: 

26 US-19 with SR-121, US-19 with CR-40, US-19 with the site construction driveway, and CR-40 

27 with the heavy-haul access road. 

28 As shown in Table 4-11, the LOS on some road segments would be adversely affected by 

29 construction-related traffic. However, none of the segments would have an LOS performance 

30 that would fall below its LOS standard. 

31 

 

(a) Because PEF indicated that, at most, 70 operations workers would be onsite at any one time during 

the construction phase, the NRC staff used this reduced number in estimating traffic impacts. The 

review team assumed that all 70 operations workers would work the day shift and would follow the 

same north-south distribution in travel patterns. 

(b) Review team calculated that 2281 would be the correct number of trips, using the KH study’s 

assumptions. 
Construction Impacts at the Proposed Site 

August 2010 4-93 Draft NUREG-1941 

1 Table 4-11. 2008 and Projected 2015 P.M. Peak-Hour Roadway LOS Conditions Near the 

2 LNP Site 

Roadway 

LOS 

Standard 

2008 

Roadway 

LOS (2-way) 

2015 

Roadway 

LOS (2-way) 

US-19 SR-121 to LNP site B A A 

US-19 project site to CR-40 B A B 

SR-121 US-19 to NW 27th Street C A C 

US-41 SE 80th Street/NW 27th Street to CR-328 C B C 

CR-40 US-19 to heavy-haul driveway C C C 

Source: Kimley-Horn 2009. 

3 Table 4-12 shows the LOS performance for each intersection resulting from the implementation 

4 of the following mitigation measures: 

5 • extending turn lanes at the intersection of US-19 with CR-40, 

6 • constructing turn lanes and adding a traffic signal at the intersection of US-19 with the 

7 construction driveway, 

8 • constructing a turn lane and an approach lane at the intersection of CR-40 with the 

9 heavy-haul road, and 

10 • using flagmen when a heavy-haul crawler is crossing CR-40. 

11 Table 4-12. 2008 and Projected 2015 P.M. Peak-Hour Intersection LOS Conditions Near the 

12 LNP Site 

Intersection 2008 Overall Intersection LOS 2008 Approach LOS 

Standard Construction Traffic NB SB EB WB 

US-19 + SR-121 (unsignalized) C A -- -- -- A 

US-19 + CR-40 (unsignalized) C B B B C C 

Intersection 

2015 Overall Intersection LOS 2015 Approach LOS 

Standard Construction Traffic NB SB EB WB 

US-19 + SR-121 (unsignalized) C B -- -- -- B 

US-19 + CR-40 (signalized) C B B B C C 

US-19 + Construction Driveway 

(signalized) B C B B -- D 

CR-40 and Heavy-Haul 

Driveway (unsignalized) C B B B -- -- 

Source: Kimley-Horn 2009.
Construction Impacts at the Proposed Site 

Draft NUREG-1941 4-94 August 2010 

1 The KH study concluded that, with the aforementioned modifications, only one intersection 

2 would fall below its LOS standard – US-19 with the construction driveway access to the LNP 

3 site, which would operate at LOS “C” only when the traffic signal is operating. The study notes 

4 that the traffic signal would be used only periodically while the units are being built. The review 

5 team presumes this would be at a.m. and p.m. shift changes, approximately 2 to 3 hours daily. 

6 Approaches from both north and south along US-19 would operate at an acceptable LOS 

7 (“B,” the standard for US-19). Based on its review of the KH traffic study and assuming 

8 implementation of the study’s mitigation recommendations, the review team anticipates minor 

9 impacts from construction and preconstruction of the LNP on the existing road network, with the 

10 exception of the intersection of US-19 and the construction driveway in Levy County where 

11 impacts would be noticeable and intermittent. 

12 Potential impacts on navigation associated with this project are limited to the construction and 

13 operation of the barge slip and CWIS on the CFBC. Both facilities would be constructed within 

14 the upland banks of the CFBC. PEF would use the barge facility to transport large components 

15 of the proposed plant to the proposed heavy-haul road. Currently, use of this portion of the 

16 CFBC is by recreational boating and not by barges or other large commercial vessels. The 

17 review team determined that recreational boaters would be able to navigate around large 

18 barges and avoid the CWIS and associated currents with minor impacts on their activities. 

19 4.4.4.2 Recreation 

20 As described in Section 4.4.1.1, construction and preconstruction activities are not expected to 

21 have significant physical impacts on nearby recreational resources. Impacts, such as increased 

22 noise, increased traffic, impacts on air quality, and visual aesthetics, would be temporary and 

23 would decrease with distance from the source. Socioeconomic impacts on recreation may 

24 result from increased demand for or use of existing and planned resources and from the 

25 physical impacts mentioned above. The increase in demand on existing/planned resources 

26 would result from usage by the increased population (4110 workers and their families, as 

27 discussed in Section 4.4.2). 

28 Recreation areas closest to the LNP that could be affected include Goethe State Forest, the 

29 Marjorie Harris Carr Cross-Florida Greenway, and the CFBC. These resources may experience 

30 an increase in use by construction workers and their families that migrate into the area. Goethe 

31 State Forest, which allows hunting, may experience an increase in demand from sport hunters 

32 who move into the area. Goethe State Forest has not reached hunter quotas and would be able 

33 to accommodate additional hunters in the area. Further, both Ocala National Forest and 

34 Withlacoochee State Forest offer hunting and are located within the region. The review team 

35 does not expect workers and their families to engage in subsistence hunting or fishing. 

36 As summarized in Table 2-24 and Table 2-25, recreational resources within the region would 

37 accommodate the increased population and associated increased demand on these resources 
Construction Impacts at the Proposed Site 

August 2010 4-95 Draft NUREG-1941 

1 that would occur during construction and preconstruction. The State parks, State forests, and a 

2 greenway within the region have the capacity to accommodate 22,059 users on a given day, 

3 and current use is only 7346 users per day, or an average usage rate of about 25 percent. 

4 Crystal River Preserve State Park, Fanning Springs State Park, Withlacoochee State Forest, 

5 and Ocala National Forest offer horse use, hunting, fishing, water sports, hiking/bicycling trails, 

6 and other recreational opportunities and have sufficient capacity to accommodate the in7 migrating workers and their families. The region has sufficient capacity to accommodate any 

8 displaced users at surrounding parks and recreational areas if such users choose to avoid 

9 certain recreational resources located near the LNP during its construction. 

10 The review team determined that impacts on recreational facilities and on the quality of the 

11 recreational experience during construction and preconstruction would be minor. 

12 4.4.4.3 Housing 

13 The assumptions underlying the review team’s estimated in-migration of workers were 

14 established in Section 4.4.3. Half of the 3300-person workforce (1650 workers) would move 

15 into the region; 1403 (85 percent) of them would move into the EIA. The review team also 

16 assumed all of the in-migrating workers would relocate to the region temporarily, moving out of 

17 the area when construction and preconstruction ends. In-migrating workers may choose to buy 

18 available vacant housing; rent; or stay in local hotels, motels, rooms, or 

19 campground/recreational vehicle (RV) areas. 

20 PEF gathered data from the U.S. Census Bureau (USCB) about the capacity of the housing 

21 market to absorb the construction workers and their families that are expected to move into the 

22 region. Table 4-13 lists the available housing, including camping, mobile homes, and public 

23 lodging units in the region. As indicated by the table, the EIA has 78,889 housing units for rent 

24 or purchase; 22,769 mobile homes; 21,855 RV/camping units; and 16,056 public lodging units 

25 for a total of 139,569 units available. These housing levels are enough to provide the entire in26 migrating workforce with living quarters. 

27 Because of the availability of adequate housing, the review team expects commute time would 

28 be a major factor in a worker’s selection of residence location. As described in Section 2.5.2.5 

29 and shown in Table 4-13, the workforce would find more housing options in Citrus and Marion 

30 Counties than in Levy County, which is more rural in nature and has fewer amenities. It is 

31 expected that 45 percent of in-migrating construction and preconstruction workers would settle 

32 in Citrus County due to the combination of available housing and amenities for their families 

33 near the LNP site. Twenty percent would settle in Levy County, and another 20 percent would 

34 settle in Marion County. A check of properties listed on the commercial “Realtor.com” website 

35 in early 2008 found, an estimated 1888 permanent housing units available within the cities of 

36 Williston, Dunnellon, Crystal River, and Yankeetown (PEF 2009a). Although Dunnellon,
Draft NUREG-1941 4-96 August 2010 

Construction Impacts at the Proposed Site 1 Table 4-13. Regional Housing and Residential Distribution for In-Migrating Construction Workers 2 County Spatial Percent of Region Permanent Housing Owner- Occupied Housing Housing Units Available to Rent or Purchase RV/ Camping Capacity 2005–2006 Mobile Homes Public Lodging Units Total Units Available to Workers Percent of Total Regional Units Allocated Workers at Peak Employment(a) Levy 20 16,570 11,591 4979 1752 1303 936 8970 3 330 or 20% Citrus 11 73,609 51,176 22,433 6008 5829 2269 36,539 13 743 or 45% Marion 24 152,858 101,381 51,477 14,095 15,637 12,851 94,060 32 330 or 20% Alachua 12 106,746 51,942 54,804 3244 3545 31,771 93,364 32 116 or 7% Dixie 6 7363 4498 2865 294 239 187 3585 1 33 or 2% Gilchrist 4 5906 4331 1575 244 741 130 2690 1 33 or 2% Hernando 9 77,423 56,709 20,714 5310 5823 2968 34,815 12 33 or 2% Sumter 8 25,195 17,972 7223 5445 2577 1859 17,104 6 33 or 2% 

Total 465,670 299,600 166,070 36,392 35,694 52,591 291,127 -- 1650 or 100% 

Source: PEF 2008b, using data from Florida Geographic Data Library on mobile homes and RV parks; USCB’s “American Factfinder Florida;” and Bureau of 

Economic and Business Research, “Florida Statistical Abstracts 2007.” (a) Reflects in-migration of 50 percent of 3300 peak construction and preconstruction workforce. Shaded cells indicate counties within the EIA. 
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August 2010 4-97 Draft NUREG-1941 

1 portions of Crystal River, Inverness, Inglis, and Yankeetown have neighborhoods with large, 

2 well-established residences, most housing is modest, with many mobile homes and RV parks. 

3 Small residential areas and trailer/RV parks are common along CR-40 east of Inglis (NRC 

4 2009). 

5 The boom-and-bust nature of large-scale construction projects aggravates the housing impacts 

6 in local communities. The typical pattern begins when in-migrating workers and their families, 

7 along with local residents with enhanced economic resources because of project- and worker8 related jobs and expenditures, increase the demand for housing. Increased demand creates 

9 upward pressure on both the housing supply and prices in the local area. When construction 

10 ends, most in-migrating workers leave and local indirect jobs are also lost. The presence of a 

11 considerable construction workforce that already lives locally, experience with seasonal 

12 population change and rapid growth, and the presence of zoning and land use development 

13 plans will all help prevent adverse impacts. Finally, the review team believes that although 

14 recent economic events have depressed the national and state economy, this economic 

15 downturn is temporary and current long-term growth projects are still reasonable. 

16 Based on the information provided by PEF, interviews with local officials, and its own 

17 independent review, the review team expects there would be minimal impacts on the availability 

18 of housing from construction and preconstruction of the LNP in the EIA and the region. 

19 4.4.4.4 Public Services 

20 This section describes the expected impacts of construction and preconstruction at the LNP site 

21 on water supply and waste treatment, and police, fire-protection, emergency, and medical 

22 services in the region. 

23 Water-Supply Facilities 

24 A discussion of construction- and preconstruction-related water requirements and associated 

25 impacts is presented in Section 4.2. The water-supply wells for LNP’s raw-water system (RWS) 

26 would tap into the freshwater aquifer at the site. The RWS would provide potable water, 

27 demineralized water treatment, and water for the fire-protection system. Water for the 

28 workforce present on the site prior to completion of the RWS would be trucked in until the 

29 potable-water system is operational (PEF 2009a). Therefore, the review team determined that 

30 water usage by the workforce while onsite would not affect municipal water supplies. 

31 The review team calculated the increase in demand for residential water based on population 

32 projections for the EIA for 2015 and using a per capita demand of 150 gpd (Levy County’s 

33 assumed value, Marion County’s LOS standard, and a mid-value of the range of rates reported 

34 for Citrus County as discussed in Section 2.5.2.6). The demand for residential water within the 

35 EIA would increase by 0.524 Mgd of potable water during peak employment due to the in-
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Draft NUREG-1941 4-98 August 2010 

1 migrating construction and preconstruction workers and their families. This increase, slightly 

2 more than a one-half percent increase over projected water demand in the EIA without the in3 migrants, would be spread proportionally among the EIA’s counties according to the distribution 

4 of workers discussed in Section 4.4.2. It would be 0.123 Mgd or a 1.8 percent increase in Levy 

5 County, 0.278 Mgd or a 1.1 percent increase in Citrus County, and 0.123 Mgd or a 0.21 percent 

6 increase in Marion County. The total water demand (including agricultural and industrial uses) 

7 projected for the EIA is 140 Mgd based on the county projections provided in Section 2.5.2.6. 

8 The added residential demand of 0.524 Mgd would be less than 0.4 percent of this total. The 

9 workforce is expected to settle into existing homes or camping/RV areas within the EIA that 

10 would already have access to water. New home construction for in-migrating workers, although 

11 unlikely, would have to be approved by local municipalities and permitting agencies if new 

12 water/wastewater infrastructure is needed. Given the small increase in demand that would 

13 result from the construction workers and their families that move into the area and requirements 

14 imposed by local municipalities and permitting agencies to demonstrate sufficient water capacity 

15 before allowing new construction, the review team has determined that impacts on water supply 

16 in the EIA would be minimal, and mitigation would not be warranted. 

17 Wastewater-Treatment Facilities 

18 The review team calculated the increase in wastewater treatment that would be required in the 

19 EIA during peak employment due to in-migrating workers and their families plus workers onsite. 

20 Using an average of 110 gpd (Marion County’s LOS standard, highest among those reported in 

21 Section 2.5.2.6) for in-migrating workers and their families, 55 gpd for two shifts of workers 

22 onsite, and based on 2015 population projections from Table 2-16, the wastewater-treatment 

23 needs would be 0.475 Mgd. Compared to the needs projected for EIA populations in 2015, this 

24 would be slightly more than a 0.7 percent increase within the EIA, distributed as a 3.5-percent 

25 increase in Levy County, 1.1 percent increase in Citrus County, and a 0.21 percent increase in 

26 Marion County, to support the in-migrating workers and their families and workers onsite. The 

27 workforce is expected to settle into existing homes or camping/RV areas within the EIA that 

28 would already have wastewater infrastructure. New construction, although unlikely as a result 

29 of the construction workforce, would have to be approved by local municipalities and permitting 

30 agencies if new water/wastewater infrastructure is needed. Given the small increase in demand 

31 that would result from the construction workers and their families that move into the area and 

32 requirements imposed by local municipalities and permitting agencies to demonstrate sufficient 

33 wastewater-treatment capacity before allowing new construction, the review team has 

34 determined that construction- and preconstruction-related impacts on wastewater-treatment 

35 capacity in the EIA would be minimal and mitigation would not be warranted. 

36 Police, Fire-Protection, Emergency Services, and Medical Services 

37 As indicated in Section 4.4.2, the review team projects that 85 percent of in-migrating 

38 construction workers and their families would settle within the EIA, resulting in 1850 new 
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August 2010 4-99 Draft NUREG-1941 

1 residents in Citrus County, 822 in Levy County, and another 822 in Marion County at peak 

2 employment (fewer in earlier and later years). The additional population amounts to slightly 

3 more than a one-half-percent increase in Levy, Citrus, and Marion Counties over 2015 

4 projections. Because it is unlikely that many new houses would be built for in-migrating 

5 construction workers, an increased load for fire-protection services would not be expected. This 

6 temporary population increase would potentially add to the workload for police and emergency 

7 services and increase the number of users of local medical facilities, although such small 

8 numbers should not noticeably affect performance except in localities where services are 

9 currently near or over capacity, as discussed below. 

10 Locally, for Inglis police and emergency services, the review team anticipates a noticeable 

11 impact. Local Inglis services are structured currently only to serve the residential town itself. 

12 Because of its location close to the LNP site (at the junction of two commuter routes), Inglis is 

13 likely to see more impacts of commuter traffic in addition to some increase in population. 

14 Likewise, the review team anticipates noticeable impacts on Dunnellon police and emergency 

15 services, because police services already are at capacity and the community is expected to 

16 attract a number of the workers who settle in Marion County. 

17 The review team expects no noticeable impact on fire-protection services in Marion and Citrus 

18 Counties because they have excess capacity and occupancy of new construction is not 

19 expected. Although the population increase in Levy County would be small and not result in 

20 new construction, the review team expects that even a small increase would cause a noticeable 

21 impact on Levy County fire-protection services because capacity is already inadequate. 

22 Given the proximity to large regional medical centers and the current 16-percent vacancy rate in 

23 the region’s hospitals, the review team expects a minor impact on access to medical care in the 

24 EIA and region. The increase in demand represented by a population increase of 0.3 percent 

25 should require only a small part of those vacancies.

26 4.4.4.5 Education

27 Construction and preconstruction of the LNP is expected to bring 1650 in-migrating workers to 

28 the region at the peak of employment in 2016. Many of these workers would be in the area for 

29 only a year or two (PEF 2009d). As indicated in Section 4.4.2, the review team projects that 

30 85 percent of in-migrating construction workers and their families would settle within the EIA, 

31 resulting in 743 new households in Citrus County, 330 in Levy County, and another 330 in 

32 Marion County. The review team used county school district estimates of students per 

33 household from Table 2-35 to calculate the added students attributable to in-migrating 

34 construction worker households, as indicated in Table 4-14. The addition of 432 students would 

35 be a small number compared to the existing rolls in the EIA (approximately 66,000 students in 

36 2007–2008, as shown in Section 2.5.2.7). 
Construction Impacts at the Proposed Site 

Draft NUREG-1941 4-100 August 2010 

1 Table 4-14. Expected Number of Students from In-Migrating Construction Worker Households 

2 at Peak 

 Elementary 

School Students 

Middle School 

Students 

High School 

Students 

Total Students 

Levy County 67 35 37 139 

Citrus County 85 45 51 185 

Marion County 52 26 30 108 

EIA 204 105 119 432 

3 As indicated in Section 2.5.2.7, there are capacity issues in Levy County schools, including 

4 Yankeetown School closest to the LNP site, and in Marion County schools, including Dunnellon 

5 High School and the elementary school closest to the LNP site. Citrus County, which would 

6 receive the largest number of new students, has minor capacity issues and offers some newer 

7 housing developments that would offer housing options to in-migrating workers. Because the 

8 State of Florida mandates that new development cannot be approved without appropriate 

9 accommodations for school-age children, the review team assumes that school capacity would 

10 be available for these locations. 

11 Because it takes up to 3 years to construct a new school, schools within the EIA accommodate 

12 new growth by using mobile classrooms. School district officials surmised that the children 

13 accompanying the construction workforce would be accommodated through excess capacity in 

14 the districts and, if needed, use of mobile classrooms at schools lacking capacity (NRC 2009). 

15 The review team concludes that impacts on public schools in the EIA would be minor, with 

16 noticeable impacts for 1 to 2 years during peak employment in schools serving Inglis, 

17 Yankeetown, and Dunnellon. 

18 4.4.4.6 Summary of Infrastructure and Community Service Impacts 

19 The review team determined impacts on all infrastructure and community services would be 

20 SMALL with the exception of the following larger impacts during peak employment years; 

21 MODERATE intermittent transportation impacts at the intersection of the access road from 

22 US-19 to the site; MODERATE impacts on Inglis and Dunnellon police and emergency services 

23 and Levy County fire-protection services; and MODERATE impacts on schools serving Inglis, 

24 Yankeetown, and Dunnellon. 

25 4.4.5 Summary of Socioeconomic Impacts 

26 The review team found physical, demographic, economic, infrastructure, and community service 

27 impacts of construction and preconstruction of the LNP generally would be SMALL. The review 

28 team identified MODERATE short-term beneficial employment impacts in Levy County and 

29 MODERATE short-term adverse impacts on police, emergency service, fire protection, and 
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August 2010 4-101 Draft NUREG-1941 

1 schools in specific local communities during peak employment years. MODERATE aesthetic 

2 impacts would be felt along newly cleared transmission-line corridors. 

3 Based on the aforementioned conclusions and because NRC-authorized construction activities 

4 represent only a portion of the analyzed activities, the NRC staff concludes that the impacts of 

5 NRC-authorized construction activities would be SMALL, with the exceptions discussed below. 

6 The NRC staff concluded that no further mitigation would be warranted for categories with 

7 SMALL impacts. 

8 The review team’s finding of MODERATE adverse impacts was based on the review team’s 

9 finding that specific community public services were either at capacity or otherwise limited. 

10 Consequently, any increase in demand for services would result in a noticeable impact. 

11 Therefore, the NRC staff concludes that the impacts of NRC-authorized construction activities 

12 would include MODERATE impacts on Inglis and Dunnellon police and emergency services and 

13 Levy County fire-protection services and MODERATE impacts on schools serving Inglis, 

14 Yankeetown, and Dunnellon during peak employment years. 

15 To determine the portion of this impact attributable to NRC-authorized construction activities, 

16 the NRC staff assumed, based on PEF’s estimated ratio of preconstruction-to-construction 

17 impacts, that 35 percent of the impact would be due to NRC-authorized activities. Although 

18 impacts from some NRC-related activities would be noticeable, NRC determined that additional 

19 mitigation measures would not be warranted given their temporary nature. 

20 4.5 Environmental Justice Impacts 

21 The review team reviewed PEF’s ER and verified the data sources used in its preparation by 

22 examining cited references and independently confirming data in discussions with community 

23 members and public officials, and personal visits to the region (NRC 2009). To verify data in the 

24 ER, the review team requested clarifications and additional information from PEF as needed. 

25 Unless otherwise specified in the sections below, the review team has drawn upon verified data 

26 from PEF (2009a, d, e, i, j). Where the review team used different analytical methods or 

27 additional information for its own analysis, the sections include explanatory discussions and 

28 citations for those sources. 

29 The review team evaluated whether the impact on minority and low-income populations at the 

30 census blocks identified in Section 2.6 could experience a disproportionately high and adverse 

31 effect from the potential impacts of construction and preconstruction of LNP Units 1 and 2. To 

32 perform this assessment, the review team (1) identified all potentially significant pathways for 

33 human health and welfare effects, (2) determined the impact of each pathway for populations 

34 within the identified census blocks and populations not identified with particular census block 

35 groups, and (3) determined whether or not there were any unique characteristics or practices 
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Draft NUREG-1941 4-102 August 2010 

1 among the minority or low-income populations identified that would result in a disproportionately 

2 high and adverse impact on minority or low-income people within each census block. As 

3 discussed in Section 2.6.2, the review team found only one unique characteristic with the 

4 potential for such impacts: an exceptional dependence on subsistence resources. 

5 To perform this assessment, the review team followed the methodology described in 

6 Section 2.6.1. In the context of construction and preconstruction activities at the PEF site, the 

7 review team considered the questions outlined in Section 2.6.1. For all three health-related 

8 questions, the review team determined through literature searches and consultations with NRC 

9 staff health experts that the level of environmental emissions projected is well below the 

10 protection levels established by NRC and EPA regulations and cannot impose a different effect 

11 on different segments of the population, including minority or low-income populations. 

12 4.5.1 Physical and Socioeconomic Impacts 

13 As shown in Figure 2-26, all census block groups with minority and low-income populations that 

14 meet the criteria discussed in Section 2.6 are located 10 mi or farther away from the LNP site. 

15 The closest minority populations (both aggregate and African-American) are in Citrus County 

16 between Citrus Springs and Dunnellon, approximately 10 mi from the site. The closest low17 income populations, near Otter Creek in Levy County, are almost 20 mi from the site. There are 

18 concentrations of block groups with African-American populations around the communities of 

19 Otter Creek, Usher, Chiefland, and Williston in Levy County between 20 and 30 mi from the site; 

20 around Ocala in Marion County, about 30 mi from the site; around Gainesville in Alachua 

21 County, about 45 mi from the site; and in the northwest corner of Sumter County, between 20 

22 and 30 mi from the site. (These are linear distances from the LNP site center; driving distances 

23 to all communities are greater.) Some block groups with low-income populations of interest 

24 overlap with African-American populations of interest around Otter Creek, Usher, and Chiefland 

25 in Levy County and around Ocala (Marion County) and Gainesville (Alachua County). 

26 The review team determined that there would be no disproportionately high and adverse 

27 physical impacts on minority or low-income people within the identified census blocks. Distance 

28 from the site and intervening vegetation would mitigate physical impacts of construction and 

29 preconstruction on soil, water, noise, and air such that they would be minimal for all populations, 

30 including the minority and low-income populations closest to the site. 

31 The review team reviewed socioeconomic impacts discussed in Section 4.4 to evaluate whether 

32 any construction- and preconstruction-related activities could have a disproportionately high and 

33 adverse effect on minority or low-income populations. The review team identified short-term 

34 MODERATE impacts on education, police, and emergency services in the area of Dunnellon 

35 because the Dunnellon high school, elementary school, and police department are at capacity. 

36 These impacts would extend to the African-American population in the census block group 

37 between Dunnellon and Citrus Springs to the extent that they use these Dunnellon and Marion 
Construction Impacts at the Proposed Site 

August 2010 4-103 Draft NUREG-1941 

1 County services. The review team also identified short-term MODERATE impacts on fire 

2 protection in Levy County because of the current lack of capacity. These impacts might extend 

3 to the African-American and low-income populations around Williston and Otter Creek4 Chiefland-Usher in Levy County. The review team also found MODERATE traffic impacts on 

5 US-19 at the intersection with the site access road for 2 to 3 hours daily during construction and 

6 preconstruction. These impacts would extend to any minority or low-income users of the 

7 highway. As discussed in Section 2.6.2, the review team did not identify any evidence of unique 

8 characteristics or practices in minority or low-income communities that may result in 

9 socioeconomic impacts that differ from those on the general population. Therefore, the review 

10 team found no evidence that adverse impacts on the minority and low-income populations in 

11 these instances would be disproportionately greater than to other populations also affected. 

12 Based on the above analysis, the review team determined that the environmental justice 

13 impacts from physical and socioeconomic sources would be minor. 

14 4.5.2 Health Impacts 

15 For health-related considerations, the review team determined through literature searches and 

16 consultations with NRC staff health physics experts that the expected building-related level of 

17 environmental emissions is well below the protection levels established by NRC and EPA 

18 regulations and therefore cannot impose a disproportionately high and adverse radiological 

19 health effect on minority or low-income populations. 

20 Section 4.9 assesses the radiological doses to construction workers after fuel loading for Unit 1 

21 and concludes that the doses would be within NRC and EPA dose standards. Section 4.9 

22 further concludes that radiological health impacts on the construction workers for proposed 

23 Units 1 and 2 would be SMALL. Therefore, there would be no disproportionately high and 

24 adverse impact on low-income or minority construction workers. From the review team’s 

25 investigation, no offsite project-related potential pathways to adverse health impacts were found 

26 to occur in excess of the safe levels stipulated by general health and safety standards. 

27 Therefore, the review team concludes that there would be no radiological health-related impacts 

28 on offsite minority and low-income populations. 

29 Where there are potential offsite nonradiological health effects, the review team did not identify 

30 any studies, reports, or anecdotal evidence that would indicate any environmental pathway that 

31 would physiologically affect minority or low-income populations differently from other segments 

32 of the general population during construction and preconstruction. Moreover, the review team’s 

33 regional outreach provided no indication of any unique characteristics or practices among 

34 minority or low-income populations in the region that could lead to disproportionately high and 

35 adverse nonradiological health impacts. No impacts would be expected on the migrant farm 

36 worker populations identified in Section 2.6.4, even if they were employed near the LNP site. 
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Draft NUREG-1941 4-104 August 2010 

1 Any increase in traffic accidents is unlikely to have a disproportionate impact on any particular 

2 demographic group in the region. The roads nearest the plant would be more crowded and can 

3 expect more traffic accidents, but these increases are likely to be located on the principal 

4 commuting routes, which are not located in the census block groups with populations of interest. 

5 There is no information to suggest that nearby minority or low-income communities would be 

6 disproportionately vulnerable to hazards while on the road. Furthermore, in examining 

7 communities of minority or low-income people, the review team did not identify any such 

8 community that would be affected disproportionately by nonradiological health items. Therefore, 

9 nonradiological health effects would not have a disproportionately high and adverse impact on 

10 minority or low-income populations, and the environmental justice impact would therefore be 

11 minor. 

12 4.5.3 Subsistence and Special Conditions 

13 NRC’s environmental justice methodology includes an assessment of populations with unique 

14 characteristics, such as minority communities exceptionally dependent on subsistence 

15 resources or identifiable in compact locations, such as Native American settlements or high16 density concentrations of minority populations. 

17 4.5.3.1 Subsistence 

18 As discussed in Section 2.6.2, some subsistence hunting and fishing reportedly take place in 

19 the region, but specific locations and quantities are not known. The review team considered 

20 that subsistence fisherman might use some of the areas affected by construction and 

21 preconstruction activities. As presented in Section 4.3.2.3, fish and shellfish harvesting near the 

22 site may be temporarily affected by increased turbidity due to construction and preconstruction 

23 activities. This may temporarily affect current subsistence catch rates of shellfish and finfish to 

24 the extent that they are occurring near the site, but the turbidity is not likely to alter fishing habits 

25 or harvest because fish and motile crustaceans present in the area during construction and 

26 preconstruction activities would avoid the area during active construction and preconstruction 

27 activities or would actively feed on suspended organisms during dredging operations and are 

28 unlikely to be adversely affected by the construction and preconstruction activities. The review 

29 team also considered that subsistence hunters might use some of the areas affected by 

30 construction and preconstruction activities. Bag rates of game in these areas may be 

31 temporarily affected because game in Goethe State Forest and other properties near the LNP 

32 site boundary may avoid the area during active construction and preconstruction, but the game 

33 populations are unlikely to be directly affected by the activities. Subsistence fishers and 

34 hunters, like recreational fishers and hunters, may choose to move to locations away from 

35 construction and preconstruction effects, but there are other locations available nearby, as 

36 indicated in Section 4.4.4.2. Consequently, the review team concludes that there would be 

37 minimal impacts on minority and low-income populations that can be linked to the construction 

38 and preconstruction of the LNP. 
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August 2010 4-105 Draft NUREG-1941 

1 4.5.3.2 High-Density Communities 

2 As discussed in Section 2.6.2, the review team determined that there are no high-density 

3 communities within the vicinity of the LNP site or along any pathway that might lead to 

4 disproportionately high and adverse effects. 

5 4.5.4 Summary of Environmental Justice Impacts 

6 The review team expects the physical impacts of plant construction and preconstruction on all 

7 populations in the region, including minority and low-income populations, would be SMALL 

8 because of their distance from the site. The adverse socioeconomic impacts on minority and 

9 low-income populations are also expected to be in proportion with the impacts discussed in 

10 Section 4.4 and, therefore, would be SMALL for most elements and MODERATE for education, 

11 police, emergency services, fire protection, transportation, and aesthetics in certain locations. 

12 In these locations, there is no evidence that effects would be disproportionately high and 

13 adverse on minority or low-income populations or to communities with unique characteristics. 

14 Based on the preceding analysis and because NRC-authorized construction activities represent 

15 only a part of the analyzed activities, the review team concludes that there are no 

16 disproportionately high and adverse impacts on minority and low-income populations resulting 

17 from construction and preconstruction of LNP, and environmental justice impacts would be 

18 SMALL. 

19 4.6 Historic and Cultural Resources Impacts 

20 NEPA requires Federal agencies to take into account the potential effects of their undertakings 

21 on the cultural environment, which includes archaeological sites, historic buildings, and 

22 traditional places important to local populations. The National Historic Preservation Act of 1966, 

23 as amended (NHPA) also requires Federal agencies to consider impacts on those resources if 

24 they are eligible for listing in the National Register of Historic Places (NRHP or National 

25 Register; such resources are referred to as “Historic Properties” in the NHPA). As outlined in 

26 36 CFR 800.8 (c), “Coordination with the National Environmental Policy Act of 1969,” the NRC 

27 is coordinating compliance with NHPA Section 106 in fulfilling its responsibilities under NEPA. 

28 Construction and preconstruction of new nuclear power plants can affect either known or 

29 undiscovered cultural resources. In accordance with the provisions of NHPA and NEPA, the 

30 NRC and USACE are required to make a reasonable and good faith effort to identify historic 

31 properties in the Area of Potential Effect (APE) and, if such properties are present, determine 

32 whether significant impacts are likely to occur. Identification of historic properties is to occur in 

33 consultation with the State Historic Preservation Office (SHPO), Native American Tribes, 

34 interested parties, and the public. If significant impacts are possible, efforts should be made to 

35 mitigate them. As part of the NEPA/NHPA integration, even if no important resources (i.e., 

36 places eligible for listing in the National Register or meeting the NEPA definition of important) 
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Draft NUREG-1941 4-106 August 2010 

1 are present or affected, the NRC and USACE are still required to notify the SHPO before 

2 proceeding. If it is determined that historic properties are present, the NRC and USACE are 

3 required to assess and resolve any adverse effects of the undertaking. 

4 For a description of the historic and cultural information on the LNP site, see Section 2.7. In 

5 2008, PEF conducted a Phase 1 archaeological and architectural resources survey of the direct 

6 and indirect effects APEs. PEF concluded that there are no NRHP-eligible archaeological sites, 

7 above-ground resources, or traditional cultural properties located within the direct effects APE 

8 and the indirect effects APE. Because no archaeological or other resources were determined 

9 eligible, PEF made a determination of “no historic properties affected,” and the Florida SHPO 

10 concurred with this determination (Florida SHPO 2008a). During the site visit in December 

11 2008, the NRC staff reviewed the documentation used by PEF to prepare the cultural resources 

12 section of the ER. The review team did not identify any important cultural resources that would 

13 be affected directly or indirectly by construction and preconstruction of LNP Units 1 and 2. 

14 Tarmac America, LLC is currently pursuing a Section 404 DA permit to mine limestone in Levy 

15 County at the Tarmac King Road Limestone Mine. Because of its proximity to the LNP site, the 

16 review team is considering the proposed Tarmac King Road Limestone Mine as a surrogate for 

17 analyzing impacts of fill material at the LNP site. Development of the mine has the potential to 

18 affect cultural and historic resources. These impacts will be addressed in the Tarmac King 

19 Road Limestone Mine EIS. Since fill for LNP would be a small portion of the material mined at 

20 the Tarmac mine, if that mine was chosen to provide fill, only a portion of the impact of the mine 

21 would be considered directly attributable to the LNP project. 

22 For transmission lines beyond the areas already mentioned, PEF has completed desktop 

23 cultural resources investigations. The transmission-line corridor from the proposed LNP to 

24 Central Florida South substation (commonly call the LCFS) contains one NRHP-eligible site 

25 (8SM128) and two sites having confirmed or potential human remains (8SM10 and 8SM84). 

26 Site 8SM128 is a site with both historic and prehistoric components. According to PEF (2009a), 

27 “These sites will be avoided to the maximum extent practicable during corridor selection and 

28 structure placement as described in ER Subsection 9.4.3. If avoidance of these three resources 

29 is not feasible, then appropriate minimization or mitigation measures will be developed in 

30 coordination with the SHPO.” Once transmission-line rights-of-way within the corridors have 

31 been finalized, PEF has agreed to complete comprehensive Phase I surveys prior to 

32 construction activities (PEF 2009a). In addition, PEF has committed to work in consultation with 

33 the Florida SHPO (PEF 2009b). In addition, FDEP conditions of certification included a 

34 condition in the LNP site certification requiring PEF to conduct surveys of sensitive cultural 

35 resource areas and, if practicable, avoid National Register-eligible sites, or mitigate through 

36 archaeological salvage operations or other methods acceptable to the Florida Division of 

37 
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August 2010 4-107 Draft NUREG-1941 

1 Historical Resources (FDEP 2010a). PEF would also be required to stop work immediately and 

2 notify the Division of Historical Resources if historical or archaeological artifacts are discovered 

3 (FDEP 2010a). 

4 PEF has procedures in place for informing construction managers and workers to stop work if 

5 cultural materials or human remains are inadvertently discovered during construction and to 

6 notify staff within the appropriate Environmental Support Organization (ESO) (PEF 2009a). All 

7 work would be halted while the permitting specialist from within the ESO consults with the 

8 Florida SHPO. Any land-disturbing activity that affects a cultural resource would require a 

9 cultural resource assessment. In addition, if any area proposed for disturbance by construction 

10 is near known cultural resources, the appropriate staff within the ESO should be notified (PEF 

11 2008c). 

12 For the purposes of NHPA Section 106 consultation, based on (1) no known historic properties 

13 within the APEs, (2) the review team’s cultural resource analysis and consultation, (3) the PEF 

14 commitment to follow its procedures if ground-disturbing activities discover historic or cultural 

15 resources, and (4) the PEF consultation with the Florida SHPO that concluded a finding of no 

16 historic properties affected (Florida SHPO 2008b), the review team concludes a finding of no 

17 historic properties affected (36 CFR Section 800.4(d)(1)). 

18 For the purposes of NHPA 106 consultation, the USACE has considered the impacts related to 

19 the installation of the proposed transmission lines and other offsite activities. Because the 

20 cultural resource studies for the transmission lines are not completed, the USACE cannot 

21 provide an official finding of effect conclusion for this portion of the project. PEF has committed 

22 to working in consultation with the Florida SHPO to conduct comprehensive Phase I surveys 

23 prior to construction activities (PEF 2008c). As described above, the State of Florida included a 

24 condition in the LNP site certification regarding cultural resources. 

25 For the purposes of the review team’s NEPA analysis, based on (1) no known significant 

26 cultural resources within the APEs, (2) the review team’s cultural resource analysis and 

27 consultation, (3) PEF’s commitment to follow its procedures should ground-disturbing activities 

28 discover historic or cultural resources, (4) PEF’s consultation with the Florida SHPO that 

29 concluded a finding of no historic properties affected (Florida SHPO 2008a), (5) the LCFS 

30 corridor containing one NRHP-eligible site (8SM128) and two sites with confirmed or potential 

31 human remains (8SM10 and 8SM84), and (6) the undetermined exact location of the 

32 transmission lines which could avoid known cultural resources during the siting process, the 

33 review team concludes that the potential impacts on historic and cultural resources during 

34 construction and preconstruction would be SMALL. If building activities within the transmission35 line corridors result in significant alterations to the known cultural resources, the impact could be 

36 greater. 
Construction Impacts at the Proposed Site 

Draft NUREG-1941 4-108 August 2010 

1 Mitigation may be warranted if an unanticipated discovery or if the known cultural resources 

2 located in the LCFS cannot be avoided. These measures would be determined by PEF in 

3 consultation with the Florida SHPO. Based on the previous analysis and because building of 

4 transmission lines does not require NRC authorization, the NRC staff concludes that the 

5 potential impacts on historic and cultural resources from NRC-authorized construction activities 

6 would be SMALL, and no mitigation beyond the PEF’s commitments would be warranted. 

7 4.7 Meteorological and Air Quality Impacts 

8 Sections 2.9.1 and 2.9.2 describe the meteorological characteristics and air quality at the site. 

9 The primary impacts of building two new units on local meteorology and air quality would be 

10 from dust from land-clearing activities, open burning, emissions from equipment and machinery, 

11 concrete batch plant operations, and emissions from vehicles used to transport workers and 

12 materials to and from the site. 

13 4.7.1 Construction and Preconstruction Activities 

14 Construction and preconstruction activities at proposed LNP Units 1 and 2 would result in 

15 temporary impacts on local air quality as a result of emissions associated with ground-clearing 

16 activities. Similar to any large-scale building project, dust particle emissions would be 

17 generated during ground-clearing, grading, and excavation activities. Fugitive dust particles 

18 would be generated from the movement of machinery and materials, as well as during windy 

19 periods over recently disturbed or cleared areas. The FDEP and EPA have created standards 

20 for fugitive dust emissions. PEF has committed to preparing a dust-control plan before the start 

21 of preconstruction and construction activities, and a number of dust-control measures are 

22 described in its ER (PEF 2009a). These measures include stabilizing ground surfaces with 

23 vegetation or gravel and wetting roadways. 

24 A temporary concrete batch plant would be installed at the site. Emissions from the batch plant 

25 would consist of both particulate matter and exhaust from trucks moving concrete or raw 

26 materials. If a temporary permit is required for the operation of the batch plant, one would be 

27 obtained from the FDEP (PEF 2009a). Fill material used during construction and 

28 preconstruction activities could be obtained from a number of sources, including the Tarmac 

29 King Road Limestone Mine. This particular source of fill is located approximately 2 mi west of 

30 the LNP site and is therefore considered here for context. The mine would be a minor source of 

31 fugitive dust emissions, as described in Florida Air Quality Permit 0750089-001-AC. 

32 Exhaust emissions from vehicles and equipment would also generate smaller amounts of 

33 particulate matter. In addition, these emissions would contain CO, NOx, and VOCs. As 

34 discussed in Section 4.4.1.2 of the ER (PEF 2009a), Levy County is an attainment area for all 

35 criteria pollutants for which NAAQSs have been established (40 CFR 81.310). As a result, a 
Construction Impacts at the Proposed Site 

August 2010 4-109 Draft NUREG-1941 

1 conformity analysis of direct and indirect emissions is not required (58 FR 63214). If activities 

2 include the burning of debris, refuse, or residual construction materials, a permit would be 

3 secured from the State. 

4 Preoperational activities would result in greenhouse gas emissions, principally carbon dioxide 

5 (CO2). Assuming a 7-year construction period and typical construction practices, the review 

6 team estimates that the total construction equipment CO2 emission footprint for building two 

7 nuclear power units at the LNP would be on the order of 70,000 MT, compared to a total United 

8 States annual CO2 emission rate of 6,000,000,000 MT (EPA 2009). Appendix I provides the 

9 details of the review team’s estimate for a reference 1000-MW(e) nuclear power plant. Based 

10 on its assessment of the relatively small construction equipment carbon footprint compared to 

11 the United States annual CO2 emissions, the review team concludes that the atmospheric 

12 impacts of greenhouse gases from construction and preconstruction activities would not be 

13 noticeable, and additional mitigation would not be warranted. 

14 In general, emissions from construction and preconstruction activities (including greenhouse 

15 gas emissions) would vary based on the level and duration of a specific activity, but the overall 

16 impact is expected to be temporary and limited in magnitude. Considering the information 

17 provided by PEF and its commitment to implement a variety of control measures and to “follow 

18 applicable air pollution-control regulations,” the review team concludes that the impacts from 

19 construction and preconstruction activities on air quality at the LNP site would not be noticeable. 

20 4.7.2 Transportation 

21 Construction and preconstruction activities at the LNP site would increase traffic on local roads. 

22 Access to the site is proposed through two driveways on US-19 and a heavy-haul road 

23 intersection crossing CR-40. The northern US-19 driveway is proposed as a “construction only” 

24 driveway, while the southern US-19 driveway is proposed as the main site access upon 

25 completion of construction (Kimley-Horn 2009). During the peak construction period, the overall 

26 workforce would be about 3300 (Kimley-Horn 2009). In addition, up to 500 operations 

27 employees would be trained during the peak of construction. PEF (2009a) estimated that there 

28 would be 2262 vehicles entering and exiting the LNP site daily, and US-19 would operate at an 

29 acceptable level of service during the construction phase of the project. 

30 In addition to traffic on US-19 and CR-40, a proposed blowdown pipeline route located on the 

31 north side of the CFBC would cross the CR-40 and US-19 bridge. After crossing the CFBC, the 

32 route would also cross under an unpaved road and an unpaved bicycle/pedestrian path that 

33 parallel the southern side of the CFBC and are maintained by the Office of Greenways and 

34 Trails. PEF would coordinate with the FDOT and county officials to lessen the impacts of traffic 

35 along on the proposed blowdown pipeline route (PEF 2009a). 
Construction Impacts at the Proposed Site 

Draft NUREG-1941 4-110 August 2010 

1 While air emissions from transportation are unavoidable, PEF would use BMPs related to 

2 construction and preconstruction activities to minimize impacts on the local ambient air quality. 

3 PEF has not identified any measures specifically related to transportation emissions. However, 

4 the ER discusses the following controls and procedures that, in general, would reduce air 

5 emissions: 

6 • Grading would be performed to promote good drainage. 

7 • Ground surfaces would be stabilized as soon as practical to prevent wind erosion. 

8 • Areas that would revert to maintained grounds would be reseeded as soon as 

9 practicable to reduce the potential for fugitive dust generation. 

10 • During dry conditions, bare ground in the disturbed area and along nearby roads would 

11 be wetted to minimize the generation of fugitive dust from vehicle traffic. 

12 • Roadways used to access the LNP site would be wetted to minimize fugitive dust from 

13 traffic or operation of heavy equipment. 

14 • Open or lightly traveled areas would either be paved, covered in hard-packed aggregate, 

15 or vegetated to minimize fugitive dust emissions from traffic and wind erosion. 

16 • Heavily traveled unpaved roads and laydown areas would be stabilized with suitable 

17 materials, such as stone dust, to prevent wind erosion or fugitive dust generation by 

18 heavy equipment. 

19 • Applicable regulations for air-pollution control with regard to open burning and the 

20 operation of fueled vehicles would be followed. 

21 • Where required, permits and operating certificates would be obtained. 

22 • Fuel-burning equipment would be maintained in proper mechanical order to minimize 

23 emissions. 

24 • All reasonable precautions would be implemented to prevent accidental brush or forest 

25 fires. 

26 • A fugitive dust-control plan would be developed and reviewed periodically to assess and 

27 improve the effectiveness of fugitive dust-control measures and practices. 

28 With the implementation of these mitigation measures, the review team concludes that the 

29 impacts on air quality from transportation during construction and preconstruction would be 

30 negligible. 

31 Construction workforce transportation would also result in greenhouse gas emissions, 

32 principally CO2. Assuming a 7-year construction period and a typical workforce, the review 

33 team estimates that the total construction workforce CO2 emission footprint for building two 

34 nuclear power units at the LNP site would be of the order of 300,000 MT. This is compared to a 

35 total United States annual CO2 emission rate of 6,000,000,000 MT (EPA 2009). Appendix I 
Construction Impacts at the Proposed Site 

August 2010 4-111 Draft NUREG-1941 

1 provides the details of the review team estimate for a reference 1000-MW(e) nuclear power 

2 plant. Based on its assessment of the relatively small construction workforce carbon footprint 

3 compared to the United States annual CO2 emissions, the review team concludes that the 

4 atmospheric impacts of greenhouse gases from construction workforce transportation would not 

5 be noticeable, and additional mitigation would not be warranted. 

6 4.7.3 Summary of Meteorological and Air-Quality Impacts 

7 The review team evaluated potential impacts on air quality associated with criteria pollutants 

8 and greenhouse gas emissions from LNP site-development activities during construction and 

9 preconstruction and determined that the impacts would be minimal. On this basis, the review 

10 team concludes that the impacts of LNP site development on air quality from emissions of 

11 criteria pollutants and CO2 emissions during construction and preconstruction would be SMALL 

12 and that no further mitigation would be warranted. Because NRC-authorized construction 

13 activities represent only a portion of the analyzed activities, the NRC staff concludes that the air 

14 quality impacts of NRC-authorized construction activities would also be SMALL. The NRC staff 

15 also concludes that no further mitigation, beyond PEF’s commitments, would be warranted. 

16 4.8 Nonradiological Health Impacts 

17 Nonradiological health impacts on the public and workers from construction- and 

18 preconstruction-related activities include exposure to dust and vehicle exhaust, occupational 

19 injuries, and noise, as well as the transport of materials and personnel to and from the site. The 

20 LNP site is located in a predominantly rural, lightly populated area of Levy County, Florida. 

21 Goethe State Forest is located directly northeast of the site. The towns closest to the site are 

22 Inglis (estimated population for 2006 was 1731, 4.1 mi from the site) and Yankeetown 

23 (estimated population for 2006 was 4564, 8.0 mi from the site) (PEF 2009a). The approximate 

24 population residing within 10 mi of the site was 17,475, based on data from the USCB for 2000 

25 (PEF 2009a). Primary land uses in the vicinity are evergreen, deciduous, and mixed forest; 

26 agriculture; forested wetland; and residential (PEF 2009a). The CREC is located approximately 

27 9.6 mi south of the LNP site. People who are vulnerable to nonradiological health impacts from 

28 construction- and preconstruction-related activities include: construction workers and personnel 

29 working at LNP, people working or living in the vicinity of or adjacent to the site, and transient 

30 populations in the vicinity (i.e., temporary employees, recreational visitors, and tourists). 

31 4.8.1 Public and Occupational Health 

32 This section discusses the impacts of building the proposed LNP Units 1 and 2 on public 

33 nonradiological health and the impacts from site preparation and development on worker 

34 nonradiological health. Section 2.10 provides background information on the affected 

35 environment and nonradiological health at and within the vicinity of the LNP site. 
Construction Impacts at the Proposed Site 

Draft NUREG-1941 4-112 August 2010 

1 4.8.1.1 Public Health 

2 PEF stated that fugitive dust may be generated during land clearing and development activities, 

3 as well as by exhaust from construction equipment (PEF 2009a). Exhaust emissions from 

4 construction equipment are predicted to include particulate matter with an aerodynamic 

5 diameter of 10 microns or less (PM10), NOx, CO, and VOCs. PEF states that the emissions are 

6 likely to be similar to those from other large building projects, and air quality impacts beyond the 

7 site boundary are likely to be minimal owing to the large extent of the site (3105 ac) and long 

8 distances from the locations where the most activities would occur to the site boundaries (PEF 

9 2009a). The nearest accessible area is approximately 1 mi from the disturbance site for 

10 proposed LNP Units 1 and 2, and the nearest residences are 1.6 mi to the northwest and 1.7 mi 

11 to the west-southwest (PEF 2009a). 

12 Operational measures that would be taken to reduce emissions were discussed in 

13 Section 4.7.2. Given the mitigation measures for fugitive dust suppression and vehicle exhaust 

14 emission that would be used and the general public’s distance away from the LNP site, the 

15 review team expects that the impacts on nonradiological public health from construction and 

16 preconstruction air emissions would be negligible. 

17 4.8.1.2 Construction Worker Health 

18 According to the U.S. Bureau of Labor Statistics (BLS), injury rates drop significantly for large 

19 construction projects, such as nuclear power facilities. The reports take into account 

20 occupational injuries and illnesses as total recordable cases, which includes the cases that 

21 result in death, loss of consciousness, days away from work, restricted work activity or job 

22 transfer, or medical treatment beyond first aid. The review team estimated the annual number 

23 of occupational injuries based on U.S. total recordable case rates for utility construction for the 

24 year 2008 (4.1 per 100 full-time workers), and based on the Florida recordable case rate for 

25 utilities employment in 2004 (5.5 per 100 full-time workers), which were the most recent years 

26 that data were available (BLS 2010a, b). The time profile of construction worker employment 

27 specified by PEF (PEF 2009d) indicates that 750, 1000, 1900, 3100, 3300, 2900, 1250, and 

28 100 workers would be employed in each respective year of construction (beginning in 2012). 

29 Based on this profile, the estimated total occupational injuries and illnesses associated with 

30 construction would be between 588 and 789 for the entire construction process, depending on 

31 whether the 2008 national injury rates or 2004 Florida rates are used, respectively. When 

32 interpreting these results, it is especially important to recall that they are gross (total) injury 

33 estimates. If the workers are not employed building the LNP, they would be doing other work or 

34 would be unemployed. As noted above, the injury rate for employment in utility construction is 

35 low compared to most other construction activities. Thus, the estimates developed above are 

36 conservative worst-case estimates of the net impact of LNP construction activities on workplace 

37 injuries. 
Construction Impacts at the Proposed Site 

August 2010 4-113 Draft NUREG-1941 

1 Occupational injury and fatality risks are reduced by strict adherence to NRC and OSHA safety 

2 standards, practices, and procedures. Appropriate State and local statutes also must be 

3 considered when assessing the occupational hazards and health risks associated with 

4 construction. PEF has committed to fully adhering to NRC, OSHA, and State safety standards, 

5 practices, and procedures during any activities related to site preparation/excavation or building 

6 the proposed LNP (PEF 2009i; FDEP 2010a). 

7 Other nonradiological impacts on workers who are clearing land or building the facility discussed 

8 in this section include noise, fugitive dust, and gaseous emissions resulting from site 

9 preparation and site development activities. Mitigation measures discussed in this section for 

10 the public, such as operational controls and practices, would also help limit exposure to 

11 workers. Onsite impacts on workers also would be mitigated through training and use of 

12 personal protective equipment to minimize the risk of potentially harmful exposures. Emergency 

13 first-aid care and regular health and safety monitoring of personnel also could be undertaken. 

14 4.8.1.3 Summary of Public and Construction Worker Health Impacts 

15 Based on mitigation measures identified by PEF in its ER, adherence to permits and 

16 authorizations required by State and local agencies, and the review team’s independent 

17 evaluation, the review team concludes that the nonradiological health impacts on the public and 

18 workers for construction and preconstruction activities would be minimal, and no further 

19 mitigation would be warranted. 

20 4.8.2 Noise Impacts 

21 Development of a nuclear power plant project is similar to development of other large industrial 

22 projects, and it involves many noise-generating activities. Federal regulations governing noise 

23 from activities are generally limited to worker health. Federal regulations governing construction 

24 noise are found in 29 CFR Part 1910 and 40 CFR Part 204. The regulations in 29 CFR 

25 Part 1910 deal with noise exposure in the construction environment, and the regulations in 

26 40 CFR Part 204 generally govern the noise levels of compressors. As with other occupational 

27 injuries, noise-associated adverse impacts on workers would be limited by adherence to the 

28 applicable workplace standards. 

29 The Levy County Noise Ordinance (Levy County Code 50-349) limits sound levels experienced 

30 by offsite receptors due to construction and other industrial activities. For residential, rural, 

31 agricultural, and commercial districts, the maximum allowable noise level at the property line is 

32 65 dBA for the hours of 7:00 a.m. to 10:00 p.m. For industrial districts, the maximum allowable 

33 noise level is 75 dBA at all times. Allowable noise limits are lower during the hours of 

34 10:00 p.m. to 7:00 a.m. in residential areas (55 dBA) and rural districts (60 dBA). 
Construction Impacts at the Proposed Site 

Draft NUREG-1941 4-114 August 2010 

1 To estimate the overall noise impacts of construction and assess compliance with the Levy 

2 County Noise Ordinance, a noise assessment of the LNP site was performed in support of the 

3 LNP’s Site Certification Application to the State of Florida. The closest noise-sensitive receptors 

4 were identified as being the residences located approximately 1.6 mi to the northwest and 

5 1.7 mi to the west-southwest of the center of the project site. Individuals participating in 

6 recreational activities on the Inglis Island Trail in Goethe State Forest might also be affected by 

7 noise resulting from construction and preconstruction activities (PEF 2009a). 

8 The noise assessment, which was based on an ambient background noise measurement 

9 program and a comprehensive noise modeling analysis using the Computer-Aided Noise 

10 Abatement noise model, indicated that noise from equipment used for clearing, excavation, and 

11 building activities may be perceptible at the nearest offsite locations during intense building 

12 activities. However, most offsite noise levels (at the locations of the nearest residences and 

13 sensitive receptors) are predicted to be below the daytime noise limitation of 65 dBA established 

14 by the Levy County Noise Ordinance for residential, rural, and commercial districts during the 

15 hours of 7 a.m. to 10 p.m. (PEF 2009a). 

16 The noise assessment indicated that noises from construction and preconstruction activities 

17 might exceed this level for short periods of time during the most intense noise-generating 

18 activities (such as pile driving). BMPs, including restriction of deliveries and noise-generating 

19 activities to daylight hours and inspection and maintenance of equipment, would be established 

20 and reviewed periodically (PEF 2009a). 

21 According to NUREG-1437 (NRC 1996), noise levels below 60 to 65 dBA are considered to be 

22 of small significance. As discussed, it is unlikely that noise levels would be consistently greater 

23 than 60 dBA at the nearest residence. More recently, the impacts of noise were considered in 

24 NUREG-0586, Supplement 1 (NRC 2002). The criterion for assessing the level of significance 

25 was not expressed in terms of sound levels, but was based on the effect of noise on human 

26 activities and on threatened and endangered species. The criterion in NUREG-0586, 

27 Supplement 1, is stated as follows: 

28 The noise impacts...are considered detectable if sound levels are sufficiently high 

29 to disrupt normal human activities on a regular basis. The noise impacts...are 

30 considered destabilizing if sound levels are sufficiently high that the affected area 

31 is essentially unsuitable for normal human activities, or if the behavior or 

32 breeding of a threatened and endangered species is affected. 

33 Based on the temporary nature of construction and preconstruction activities and the location 

34 and characteristics of the LNP site including its large size and exclusion area, as well as the 

35 distance to the nearest residences, the review team concludes that the noise impacts from 

36 building proposed Units 1 and 2 would be minimal, and further mitigation would not be 

37 warranted. 
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August 2010 4-115 Draft NUREG-1941 

1 4.8.3 Transporting Construction Materials and Personnel to the Proposed Site 

2 This EIS assesses the impact of transporting workers and construction materials to and from the 

3 LNP site from the perspective of three areas of impact: the socioeconomic impacts, the air 

4 quality impacts of dust and particulate matter emitted by vehicle traffic, and potential health 

5 impacts due to additional traffic-related accidents. Human health impacts are addressed in this 

6 section, while the socioeconomic impacts are addressed in Section 4.4.1.3, and air quality 

7 impacts are addressed in Section 4.7.2. The impacts evaluated in this section for two new 

8 nuclear generating units at the LNP site are appropriate for characterizing the alternative sites 

9 discussed in Section 9.3. Alternative sites evaluated in this EIS include Crystal River in Citrus 

10 County, Dixie in Dixie County, Highlands in Highlands and Glades counties, and Putnam in 

11 Putnam County. There is no meaningful differentiation among the proposed and alternative 

12 sites regarding the nonradiological environmental impacts from transporting construction 

13 materials and personnel to the LNP site and alternative sites, and these issues are not 

14 discussed further in Chapter 9. 

15 The general approach used to calculate nonradiological impacts of fuel and waste shipments is 

16 the same as that used for transportation of construction materials and construction personnel to 

17 and from the LNP site and alternative sites. The assumptions made to provide reasonable 

18 estimates of the parameters needed to calculate nonradiological impacts are discussed below. 

19 Construction material requirements are based on information taken from the LNP ER (PEF 

20 2009a, d). PEF estimated that constructing a new Westinghouse Electric Company, LLC 

(Westinghouse) AP1000 pressurized water reactor unit requires up to 61,750 yd3 21 of concrete, 

22 3107 T of structural steel and rebar, 9,000,000 linear ft of cable, 275,000 linear ft of piping, and 

600,000 yd3 23 of fill. 

• The review team assumed that shipment capacities are approximately 13 yd3 24 of 

25 concrete, 11 T of structural steel, and 3280 linear ft of piping and cable per shipment. 

26 The review team assumed these materials would be transported to the site in a levelized 

27 manner (i.e., evenly distributed) over an 8-year period based on the schedule given in 

28 the ER (PEF 2009a). 

29 • The number of construction workers was estimated to peak at 3300 (Kimley-Horn 2009). 

30 This value represents the peak workforce for building two units simultaneously. In 

31 addition, 500 operational workers were estimated to be present at this same time 

32 (Kimley-Horn 2009). A total of 2262 vehicles was estimated to enter and leave the LNP 

33 site daily (Kimley-Horn 2009). Each person was assumed by the review team to travel 

34 to and from the site 250 days per year. 

35 • The review team assumed the average shipping distance for construction materials to be 

36 50 mi one way. 
Construction Impacts at the Proposed Site 

Draft NUREG-1941 4-116 August 2010 

1 • The review team assumed the average commuting distance for construction workers to 

2 be 20 mi one way, based on U.S. Department of Transportation (DOT) data that 

3 estimate the typical commute is 16 mi (DOT 2003). 

4 • Accident, injury, and fatality rates for transporting building materials were taken from 

5 Table 4 in State-Level Accident Rates for Surface Freight Transportation: A 

6 Reexamination (Saricks and Tompkins 1999). Rates for the State of Florida were used 

7 for construction material shipments, typically conducted in heavy-combination trucks. 

8 The data provided by Saricks and Tompkins (1999) are representative of heavy-truck 

9 accident rates and do not specifically address the impacts associated with commuter 

10 traffic (i.e., workers traveling to and from the site). To develop representative commuter11 traffic impacts, Florida-specific accident, injury, and fatality rates for the years 2003 to 

12 2007 (FLHSMV 2007) from the Florida Department of Highway Safety and Motor 

13 Vehicles were used. 

14 • The DOT Federal Motor Carrier Safety Administration evaluated the data underlying the 

15 Saricks and Tompkins (1999) rates, which were taken from the Motor Carrier 

16 Management Information System, and determined the rates were under-reported. 

17 Therefore, the accident, injury, and fatality rates from Saricks and Tompkins (1999) were 

18 adjusted using factors derived from data provided by the University of Michigan 

19 Transportation Research Institute (UMTRI) (UMTRI 2003). The UMTRI data indicate 

20 that accident rates for 1994 to 1996, the same data used by Saricks and Tompkins 

21 (1999), were under-reported by about 39 percent. Injury and fatality rates were under22 reported by 16 percent and 36 percent, respectively. As a result, the accident, injury, 

23 and fatality rates were increased by factors of 1.64, 1.20, and 1.57, respectively, to 

24 account for the under-reporting. These adjustments were applied to the construction 

25 materials, which are transported by heavy-truck shipments similar to those evaluated by 

26 Saricks and Tompkins (1999) but not to commuter traffic accidents. 

27 The estimated nonradiological impacts of transporting construction materials to the proposed 

28 LNP site and transporting construction workers to and from the site are listed in Table 4-15. 

29 The estimates for materials would be doubled for building two units at the proposed LNP site. 

30 Based on Table 4-15, the nonradiological impacts are dominated by transport of construction 

31 workers to and from the LNP site. The total annual construction fatalities related to building the 

32 facility represent about a 3-percent increase above the average 17 traffic fatalities per year that 

33 occurred in Levy County from 2003 to 2007 (FLHSMV 2007). Increases for the alternative sites 

34 were about 2 percent for the Crystal River site in Citrus County, 6 percent for the Dixie site in 

35 Dixie County, 2 to 8 percent for the Highland site in Highland and Glades Counties, and 

36 2 percent for the Putnam site in Putnam County. These increases are negligible relative to the 

37 current traffic fatality risks in the area surrounding the LNP site and alternative sites. 
Construction Impacts at the Proposed Site 

August 2010 4-117 Draft NUREG-1941 

1 Table 4-15. Annual Nonradiological Impacts of Transporting Workers and Materials to and 

2 from the Proposed LNP Site for a Single AP1000 Reactor 

Accidents per Year 

Per Unit 

Injuries per Year 

Per Unit 

Fatalities per Year Per 

Unit 

Workers 2.9 × 101 2.5 × 101 3.8 × 101

Materials 

 Concrete 1.4 × 102 1.2 × 103 1.1 × 102

 Rebar; Structural Steel 8.2 × 104 7.2 × 105 6.3 × 104

 Cable 8.0 × 103 7.0 × 104 6.1 × 103

 Piping 2.4 × 104 2.2 × 105 1.9 × 104

 Fill 1.3 × 101 1.2 × 102 1.0 × 101

Total – Materials 1.6 × 101 1.4 × 102 1.2 × 101

Total – Construction 2.9 × 101 2.5 × 101 5.0 × 101

3 Based on information provided by PEF, the review team’s independent evaluation, and 

4 considering the number of shipments of construction materials and workers that would be 

5 transported to the LNP and alternative sites, the review team concludes that the nonradiological 

6 health impacts of construction and preconstruction activities from transporting building materials 

7 and personnel to the LNP site and alternative sites would be negligible, and no further mitigation 

8 would be warranted. 

9 4.8.4 Summary of Nonradiological Health Impacts 

10 As part of its evaluation on nonradiological health impacts, the review team considered the 

11 mitigation measures identified by PEF in its ER, responses to information requests, and relevant 

12 permits and authorizations required by State and local agencies for building LNP Units 1 and 2. 

13 The review team evaluated nonradiological impacts on public health and construction workers 

14 from fugitive dust, occupational injuries, noise, and transport of materials and personnel to and 

15 from the LNP site. No significant impacts related to the nonradiological health of the public or 

16 workers were identified during the course of this review. Based on information provided by PEF 

17 and the review team’s independent evaluation, the review team concludes that the 

18 nonradiological health impacts of construction and preconstruction activities associated with the 

19 proposed LNP Units 1 and 2 would be SMALL, and no further mitigation would be warranted. 

20 Based on the preceding analysis and because NRC-authorized construction activities represent 

21 only a portion of the analyzed activities, the review team concludes that the nonradiological 

22 health impacts of NRC-authorized construction activities would be SMALL. The NRC staff also 

23 concludes that no mitigation, beyond the PEF’s commitments, would be warranted. 
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Draft NUREG-1941 4-118 August 2010 

1 4.9 Radiation Exposure to Construction Workers 

2 The sources of radiation exposure for construction workers at LNP would include direct radiation 

3 exposure, exposure from discharges of liquid radioactive waste, and exposure from gaseous 

4 radioactive effluents after LNP Unit 1 becomes operational. The impacts of this exposure are 

5 described in the following sections and summarized in Section 4.9.5. For purposes of this 

6 discussion, construction workers are assumed to be members of the public, so the dose 

7 estimates are compared to the dose limits for the public, pursuant to 10 CFR Part 20 Subpart D. 

8 PEF plans to receive nuclear fuel and start up Unit 1 prior to completion of Unit 2 (PEF 2009a). 

9 Once proposed LNP Unit 1 is operational, gaseous and liquid radioactive materials would be 

10 released and there would be radioactive waste onsite. Construction workers on proposed LNP 

11 Unit 2 would be exposed to radiation from LNP Unit 1. CREC Unit 3 is located 9.6 mi from the 

12 LNP site and therefore would not be a source of radiation exposure for construction workers at 

13 the LNP site. 

14 The following sections address the calculated exposure to the LNP Unit 2 construction worker 

15 associated with direct radiation, gaseous effluents, and liquid effluents from LNP Unit 1. 

16 4.9.1 Direct Radiation Exposures 

17 In the ER (Section 4.5.2), PEF identified proposed LNP Unit 1 as a potential source of direct 

18 radiation exposure to proposed LNP Unit 2 construction workers (PEF 2009a). The NRC staff 

19 did not identify any additional sources of direct radiation during the December 2008 site audit or 

20 during document reviews. 

21 According to Section 12.4.2.1 of the Westinghouse AP 1000 Design Control Document (DCD) 

22 (Westinghouse 2008), refueling water would be stored inside the containment instead of in an 

23 outside storage tank, as at other facilities, so it would not contribute significantly to external 

24 radiation levels at the proposed LNP Unit 1 fence line. PEF stated that direct radiation exposure 

25 to construction workers beyond the proposed LNP Unit 1 fence line from the containment 

26 building and other facility buildings would be negligible. NRC staff reviewed the PEF approach 

27 and doses to construction workers and concluded they were appropriate. 

28 4.9.2 Radiation Exposures from Gaseous Effluents 

29 PEF calculated doses to construction workers at proposed LNP Unit 2 from LNP Unit 1 operation 

30 using expected annual airborne effluent releases. Using GASPAR II (Strenge et al. 1987), PEF 

31 estimated total body dose of 2.7 mrem/yr. This dose was adjusted for worker occupancy 

32 assumed to be 2080 hours annually (PEF 2009a). The NRC staff performed confirmatory dose 

33 calculations using the information contained in the PEF ER and 2 years of meteorological data. 
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August 2010 4-119 Draft NUREG-1941 

1 4.9.3 Radiation Exposures from Liquid Effluents 

2 Liquid effluents would be transported away from LNP Unit 1 in blowdown piping to a discharge 

3 structure located more than 9.6 mi away in the southwest direction. As such, potential exposure 

4 to liquid effluents would be a negligible contribution to proposed LNP Unit 2 construction worker 

5 dose. 

6 4.9.4 Total Dose to Site Preparation Workers 

7 PEF estimated a total body dose to a LNP Unit 2 construction worker from all pathways to be 

8 2.7 mrem/yr, assuming a 2080 hr/yr occupancy and that the direct radiation and liquid effluent 

9 pathway contributions are negligible. This dose is less than the 100-mrem annual dose limit to 

10 an individual member of the public found in 10 CFR 20.1301. 

11 4.9.5 Summary of Radiological Health Impacts 

12 The NRC staff concludes that the estimate of doses to construction workers during the building 

13 of the proposed Units 1 and 2 is well within NRC annual exposure limits (i.e., 100 mrem) 

14 designed to protect the public health. Based on information provided by PEF and the NRC 

15 staff’s independent evaluation, the NRC staff concludes that the radiological health impacts on 

16 construction workers for proposed LNP Units 1 and 2 would be SMALL, and no further 

17 mitigation would be warranted. Radiation exposure from all NRC-licensed activities, including 

18 operation of LNP Units 1 and 2, is regulated by the NRC. Therefore, NRC staff concludes the 

19 radiological health impacts for NRC-authorized construction activities would be SMALL, and no 

20 further mitigation would be warranted 

21 4.10 Nonradioactive Waste Impacts 

22 This section describes the environmental impacts that could result from the generation, 

23 handling, and disposal of nonradioactive waste during building activities for LNP Units 1 and 2. 

24 As discussed in Section 3.4.4, the types of nonradioactive waste that would be generated, 

25 handled, and disposed of during building activities include cleared vegetation, building material 

26 debris, municipal waste, spoils, stormwater runoff, sanitary waste, dust, and other air emissions. 

27 The assessment of potential impacts resulting from these types of wastes is presented in the 

28 following sections. 

29 4.10.1 Impacts on Land 

30 Vegetation removed from areas requiring clearing would be handled using a combination of 

31 chipping, spreading, and stockpiling for decomposition onsite or within the limits of the corridor; 

32 by burning onsite or within the limits of the corridor; and by offsite disposal in an approved 

33 disposal facility. A temporary storage area for the stockpiling of vegetative waste material would 
Construction Impacts at the Proposed Site 

Draft NUREG-1941 4-120 August 2010 

1 be provided for materials that would not be disposed of onsite. The selection of options for 

2 individual areas of the proposed project would depend on landowner requirements, agency 

3 permitting conditions, and relative costs. No vegetative waste would be disposed of in wetland 

4 areas. 

5 The areas requiring clearing and grubbing would include the area of the power plant, adjacent 

6 facilities, and access roads; the 150-ft-wide corridor for the trench for the six 54-in.-diameter 

7 intake and discharge pipelines, an adjacent building road, and excavated trench spoils; and the 

8 corridor for the 50-ft-wide heavy-haul road and associated drainage swales. In these areas, 

9 vegetation would be cleared to ground level, and the vegetative layer and organic topsoils would 

10 be removed. Topsoil would be stockpiled along the corridors or in designated areas and reused 

11 to restore temporarily disturbed areas (PEF 2009i). 

12 Within the transmission-line corridors, only vegetation taller than low-growth shrubs would be 

13 removed except as required for towers and access roads (PEF 2009i). This vegetative material 

14 would be ground up and spread in the corridor, unless specific landowner restrictions require 

15 them to be removed and disposed of offsite. PEF does not expect to perform any open burning 

16 within the transmission-line corridors. If any areas to be cleared have significant tree cover, the 

17 clearing contractor would be encouraged to consider harvesting the usable trees for wood or 

18 wood pulp. The quantities of vegetative waste have not yet been estimated in part because the 

19 exact alignments within the proposed corridors have not been determined. Therefore, the 

20 actual vegetative cover of the alignment is unknown. 

21 Most of the plant equipment would be produced offsite and delivered in modular units, thereby 

22 reducing the generation of onsite waste. Building would generate small quantities of waste, 

23 such as scrap wood, wallboard, plastics, paper, and metal, which would be recycled or disposed 

24 in a local landfill appropriate for handling building debris. Municipal trash generated by the 

25 workforce during building activities may include food waste, glass, metals, cloth, plastics, and 

26 paper. Trash would be collected in local designated trash receptacles, transferred to onsite 

27 dumpsters, and disposed of in an offsite permitted landfill (PEF 2009i). 

28 The slurry trench for the proposed diaphragm wall is expected to be excavated in panels using 

29 mechanical or hydraulic clamshell grabs or hydromills, as opposed to continuous trenching, 

30 thereby minimizing slurry requirements and allowing greater slurry reuse. Excess slurry from 

31 the building of the diaphragm wall and excess asphalt from building roads would be recycled or 

32 disposed of in accordance with all applicable Federal, State and local requirements. Waste 

33 concrete would be crushed and used onsite for road aggregate or removed from the site and 

34 disposed of by the building contractor (PEF 2009i). 

35 Engineering projections of the soil cut-and-fill balance indicate that the proposed project would 

require approximately 1,000,000 yd3 36 of additional clean fill to reach design grades. Therefore, 
Construction Impacts at the Proposed Site 

August 2010 4-121 Draft NUREG-1941 

1 no clean excavation spoils are expected to require disposition offsite. Little or no organic soil is 

2 expected to require disposition offsite (PEF 2009i). 

3 Based on the proposed practices for minimizing the generation of solid waste and the plans to 

4 manage solid wastes in compliance with all applicable Federal, State and local requirements 

5 and standards, the review team expects that impacts on land from nonradioactive solid wastes 

6 generated during the building of LNP Units 1 and 2 would be minimal, and no further mitigation 

7 would be warranted. 

8 4.10.2 Impacts on Water 

9 Building activities would generate liquid wastes from the sanitary wastewater-treatment system 

10 and from stormwater runoff. 

11 During building activities, portable toilets would be supplied and serviced by a licensed 

12 sanitation contractor. The portable toilets would be pumped on a regular basis and the waste 

13 would be trucked to a municipal wastewater-treatment facility. The provision of portable 

14 restrooms for building sites is governed by Chapter 64E-6.0101 of the Florida Administrative 

15 Code (Fla. Admin. Code 64E-6.0101). There would be no onsite discharges from the portable 

16 toilets. 

17 The proposed sanitary waste-treatment plant would consist of two package sewage-treatment 

18 plant units that would support the sanitary-wastewater requirements of the building workforce. 

19 The two plants would be designed to support up to 3500 people per day during building 

20 activities. The sewage-treatment plants would each have a capacity of 35,000 gpd using the 

contact stabilization process.(a) 21 Each plant would include an individual 12,000-gal clarifier tank, 

22 while a common 17,000-gal surge tank and a common 30,000-gal sludge-holding tank would 

23 serve both plants (PEF 2009a). 

24 In accordance with Florida law, any discharges during building activities would need to comply 

25 with all applicable provisions of NPDES Permit No. FL0633275-IW1S/NP upon final issueance 

26 (FDEP 2010a). Sanitary wastewater would be treated to the levels stipulated in the NPDES 

27 permit before being combined with the cooling-water system blowdown for discharge to the 

28 CREC discharge canal (PEF 2009a). 

29 PEF would use the Generic Permit for Stormwater Discharge from Large and Small 

30 Construction Activities administered by the FDEP for stormwater discharges during building 

31 activities. The application process for coverage under the generic permit requires that PEF 

32 

 

(a) In the contact stabilization process, activated sludge is added to the wastewater influent, which then 

passes through a clarifier. Clarifier effluent undergoes additional aeration in a stabilization tank. 
Construction Impacts at the Proposed Site 

Draft NUREG-1941 4-122 August 2010 

1 prepare a SWPPP and submit a Notice of Intent to the FDEP NPDES Stormwater Notices 

2 Center (PEF 2009a). Section 4.2.3.1 discusses the management of stormwater and the 

3 SWPPP. 

4 Based on the proposed practices for managing liquid wastes in compliance with all applicable 

5 Federal, State, and local requirements and standards, the review team expects that impacts on 

6 water from nonradioactive liquid wastes generated during building activities would be minimal, 

7 and no further mitigation would be warranted. 

8 4.10.3 Impacts on Air 

9 Building activities would cause impacts on air quality by the generation of dust, the burning of 

10 stripped vegetation, and by combustion of fuel in vehicles and equipment. Air quality impacts 

11 from building activities are discussed in detail in Section 4.7.1. 

12 Building activities at the LNP site would generate dust from earthmoving activities and from the 

13 travel of vehicles and equipment on unpaved roads. Once cleared, exposed land areas may 

14 also generate fugitive dust as a result of wind erosion. Such activity would occur far from the 

15 site boundaries to minimize offsite impacts. 

16 If vegetation from land clearing were burned, additional particulate emissions would be 

17 generated. Burning would take place only if approved by the appropriate agency. No burning 

18 would occur if the FDEP or the Division of Forestry were to issue a temporary ban on burning 

19 due to air pollution or fire-safety conditions. 

20 The large mass of concrete required for the building foundations and other structures would 

21 require the installation and operation of a temporary concrete batch plant. Activities at the plant 

22 associated with the movement of aggregates and cement would generate dust. Mitigation 

23 measures, such as the use of dust-suppression water sprays on aggregate stockpiles, would 

24 minimize this dust generation. Because the concrete batch plant would be located far from the 

25 site boundaries, no discernible impacts are expected at offsite locations. 

26 The operation of diesel-powered heavy equipment would generate additional particulate 

27 emissions, primarily PM10 and smaller, as well as the gaseous combustion byproducts SO2, 

28 NOx, and CO. These emissions are expected to be consistent with emissions from other 

29 building projects of this size, and there should be no significant impacts on air quality at offsite 

30 locations during the building period. Traffic caused by workers commuting to and from the LNP 

31 site would also produce vehicle emissions. 

32 Along the transmission-line corridors, low ground cover would be left intact, minimizing areas of 

33 open soil and subsequent dust generation. PEF does not expect to perform any open burning 

34 within the transmission-line corridors. 
Construction Impacts at the Proposed Site 

August 2010 4-123 Draft NUREG-1941 

1 In general, emissions from building activities (including greenhouse gas emissions) would vary 

2 based on the level and duration of a specific activity, but the overall impact is expected to be 

3 temporary and limited in magnitude. During building, PEF would implement emission controls, 

4 mitigation measures, and air quality monitoring. The review team expects that impacts on air 

5 from nonradioactive airborne wastes generated during building activities would be minimal, and 

6 no further mitigation would be warranted. 

7 4.10.4 Summary of Nonradioactive Waste Impacts 

8 Solid, liquid, and gaseous wastes generated when building LNP Units 1 and 2 would be handled 

9 according to county, State, and Federal regulations. Solid waste would be recycled; disposed of 

10 in existing, permitted landfills; or, in the case of vegetative waste only, chipped and spread 

11 onsite or burned in accordance with applicable regulations. 

12 Sanitary wastes would be removed to an existing licensed sewage-treatment facility or 

13 discharged locally after being treated to the levels stipulated in the NPDES permit. A SWPPP 

14 would specify the mitigation measures to be put in place to manage stormwater runoff. 

15 To avoid any noticeable, offsite air quality impacts, BMPs to control dust and minimize vehicle 

16 emissions would be expected. 

17 Based on information provided by PEF and the review team’s independent evaluation, the 

18 review team concludes that nonradioactive waste impacts on land, water, and air would be 

19 SMALL and that additional mitigation would not be warranted. Because NRC-authorized 

20 construction activities represent only a portion of the analyzed activities, the NRC staff 

21 concludes that the nonradioactive waste impacts of NRC-authorized construction activities also 

22 would be SMALL and that no further mitigation would be warranted. 

23 4.11 Measures and Controls to Limit Adverse Impacts During 

24 Construction Activities 

25 In its evaluation of environmental impacts during building activities for the proposed LNP Units 1 

26 and 2, the review team relied on PEF’s compliance with the following measures and controls 

27 that would limit adverse environmental impacts: 

28 • compliance with applicable Federal, State, and local laws, ordinances, and regulations 

29 intended to prevent or minimize adverse environmental impacts, 

30 • compliance with applicable requirements of permits or licenses required for building the 

31 new units (e.g., USACE Section 404 permit and the NPDES permit), 

32 • compliance with existing CREC processes and/or procedures applicable to proposed 

33 LNP Units 1 and 2 construction environmental compliance activities for the LNP site, 
Construction Impacts at the Proposed Site 

Draft NUREG-1941 4-124 August 2010 

1 • incorporation of environmental requirements into construction contracts, and 

2 • identification of environmental resources and potential impacts during the development 

3 of the ER and the COL process. 

4 Table 4-16 on the following pages, which is the review team’s adaptation from PEF’s 

5 Table 4.6-1 (PEF 2009a), summarizes the measures and controls proposed by PEF to limit 

6 adverse impacts during building of proposed Units 1 and 2 at the LNP site. 
August 2010 4-125 Draft NUREG-1941 

Construction Impacts at the Proposed Site 

Table 4-16. Summary of Measures and Controls Proposed by PEF to Limit Adverse Impacts During Construction of 1 

Proposed Units 1 and 2 2 

Impact Category Planned Mitigation and Controls

Land-Use Impacts 

The Site and Vicinity 

On June 2, 2008, PEF submitted a Site Certification Application to the Florida Department of Environmental Protection (FDEP) (PEF 2008c) seeking State approval for building and operating LNP Units 1 and 2. On August 11, 2009, the Florida Siting Board unanimously approved the project.Entrix submitted a Wetland Mitigation Plan to FDEP on behalf of PEF (Entrix 2010). The plan is intended to demonstrate the availability of ample mitigation opportunities to achieve wetland compensation, which is required by both the Clean Water Act and Florida law. Acreage temporarily disturbed by construction would revert to open grassy areas after construction is finished, which is still a permanent conversion from pine plantations, forested wetlands, and mixed forests. To minimize impacts on surrounding land, the heavy-haul road would be collocated with the transmission-line corridor and the makeup-water and blowdown pipeline corridor. The location of the proposed heavy-haul road was selected by PEF because it is the shortest direct route to the LNP site from the cooling-water intake structure (CWIS), and it is slightly higher in elevation and contains fewer wetland areas than other potential locations that were considered (PEF 2008c). PEF has indicated that it would lessen the impact of construction and preconstruction activities by using mitigation measures such as erosion control, controlled access roads, and restricted construction zones. Stormwater runoff from LNP corridors would be controlled by a stormwater-drainage system. Stormwater collected in the ponds would be drained through emergency spillways, or it could be pumped to the cooling-tower blowdown basin if necessary.

3 
Draft NUREG-1941 4-126 August 2010 

Construction Impacts at the Proposed Site Table 4-16. (contd) Impact Category Planned Mitigation and Controls Transmission Corridors and Offsite Areas Transmission-line siting in Florida is regulated under the Florida Power Plant Siting Act (29 Fla. Stat. 403), and Fla. Admin. Code 62-17. Because transmission-line corridors would pass through a number of undisturbed lands, including wetlands, PEF has identified several measures that it would take to mitigate the impacts of construction. Upland areas would be cleared and then covered with a chipping material. Corridors that pass through wetlands would be cleared, although vegetation and trees would be cut back to avoid clearing where possible. Trees that are cut down would have their stumps and root systems left intact where possible. Land in the corridors after construction has been completed would be maintained in a herbaceous state. Vegetation 25 ft wide forming deep foliage screens with mature heights not exceeding 12 ft would be left intact where the corridor crosses navigable waterways, if practicable. Water-Related Impacts Hydrologic Alterations New drainage ditches and other features such as sediment filters and detention ponds would be used to accommodate surface-water runoff from altered drainage areas and the newly constructed impervious 

areas. Some wetlands would be filled. Building will occur in the 100-year floodplain. Placement of the blowdown pipeline would cross the Cross Florida Barge Canal (CFBC). Building of the barge slip would occur within the CFBC. Appropriate erosion control measures would be taken on all drainage features and wetlands to prevent turbid water, soil deposition, vegetation removal, etc. from occurring within those areas or downstream areas through the approved stormwater pollution prevention plan (SWPPP). A wetland compensation plan would be used. If noticeable loss in floodplain capacity results from building activities, a floodplain compensation plan would be used. Best management practices (BMPs) would be used to isolate building areas within the CFBC to prevent sediment discharge to the waters. 

Water-Use Impacts PEF would develop an environmental monitoring plan to ensure that the impacts on groundwater levels 

and quality and any related impacts on wetlands are adequately monitored. If adverse impacts are observed, PEF would be required to implement a mitigation strategy. PEF is required to prepare an alternative water-supply plan. This plan identifies other potential sources of freshwater that could be used to meet LNP requirements. 
August 2010 4-127 Draft NUREG-1941 

Construction Impacts at the Proposed Site 

Table 4-16. (contd)

Impact Category Planned Mitigation and Controls

WaterQuality Impacts Develop and implement a construction SWPPP and spill response plan. Adhere to applicable regulations and permitting requirements found in the National Pollutant Discharge 

Elimination System (NPDES) permit. Implement BMPs to prevent the movement of pollutants (including sediments) into wetlands and waterbodies via stormwater runoff and discharges from building activity areas within the CFBC. BMPs would include the use of erosion control measures such as silt fences and detention ponds to prevent sedimentation and turbid water discharge. Use of vegetated land buffers between waterbodies and the building activity site would minimize sedimentation impacts. PEF would comply with Federal, State, and local laws, ordinances, and regulations intended to prevent or minimize adverse environmental effects (for example, solid waste management, erosion and sediment control, air emissions, noise control, stormwater management, spill response and cleanup, and hazardous waste management. 

Ecological Impacts

Terrestrial Ecosystems

Vegetation removal would be limited to only those areas needed for development-related activities. Temporarily disturbed sites would be restored in a timely manner. Most (75 percent) of the LNP site would remain undeveloped, providing a vegetated buffer around the centrally located LNP facilities. PEF’s proposed wetland mitigation plan calls for ceasing commercial forest management over approximately 1549 ac of undeveloped areas remaining on the LNP site and part of a property owned by PEF directly south of the LNP site. Pine plantations and other disturbed habitats would be rehabilitated through a series of vegetation management and restorative processes to reestablish plant communities more functionally similar to native upland and wetland habitats. Restoration of these lands would help to mitigate the effects of fragmentation by creating a more contiguous native landscape on lands highly altered by forest management. As restored habitats again become available for use by wildlife, the higher-quality habitat provided by the restored communities would allow for an increase in wildlife diversity and species population levels, helping compensate for wildlife losses during construction and preconstruction. Fencing that could restrict movement by medium- and large-sized wildlife would be limited to areas close to LNP facilities to provide for security or industrial safety. Fencing would not be built around the LNP property line, thereby allowing unimpeded movement by wildlife between undeveloped areas onsite and adjacent offsite habitats. 
Draft NUREG-1941 4-128 August 2010 

Construction Impacts at the Proposed Site Table 4-16. (contd) Impact Category Planned Mitigation and Controls Wildlife displacement in adjacent habitats due to noise should be temporary in nature and primarily limited to daylight hours. Wildlife may return to undisturbed habitats upon completion of development. Over 90 percent of the new transmission lines would be collocated with existing PEF transmission lines. This practice would reduce the potential for bird collisions with structures and lines by limiting the number of rights-of-way that birds would need to cross. As a condition of certification, PEF would be required to develop an Avian Protection Plan for the transmission lines that would include measures to reduce potential collision impacts by birds. To comply with U.S. Army Corps of Engineers (USACE) and FDEP regulatory requirements, PEF would minimize impacts on wetlands and waterbodies during LNP site development, while siting transmission- lines. Because the final transmission-line rights-of-way would be narrow (100 to 220 ft wide) and collocated with existing transmission lines over about 90 percent of their range, the actual extent of upland and wetland clearing for the transmission lines would be greatly minimized. Measures would be taken prior to the dewatering and excavation of each proposed nuclear island to 

prevent significant drawdown to the surficial aquifer system that supports adjacent wetlands. An impervious reinforced diaphragm wall would be installed around the perimeter of each excavation, and the underlying bedrock would be sealed by drilling and pressure grouting to isolate and seal the dewatering areas, and minimize inflow into the excavations. Inflow and stormwater from within the excavations would be intermittently pumped and discharged to an infiltration basin. Monitoring of adjacent surface-water and groundwater levels would be conducted to ensure that dewatering impacts are minimized. If any detrimental impact on water levels supporting adjacent wetlands is detected, additional mitigative measures such as drilling and grouting, sheeting, or re-design of the recharge basins would be implemented. Unavoidable wetland impacts would be mitigated in compliance with Federal and State permitting processes. PEF has prepared a mitigation plan that would compensate for the loss or impairment of functions to all wetlands affected by development on the LNP site and the associated offsite facilities. PEF has committed to providing at least as many Florida Uniform Mitigation Assessment Methodology (UMAM) functional lift units as the actual LNP project losses. A condition of certification by the FDEP would require protocol surveys for all listed species (except plants) that may occur on the LNP site and associated offsite facilities prior to land “clearing and construction”. This condition of State certification also requires the applicant to consult with the FFWCC if listed species are identified during predevelopment surveys or if listed species are encountered during 
August 2010 4-129 Draft NUREG-1941 

Construction Impacts at the Proposed Site 

Table 4-16. (contd)

Impact Category Planned Mitigation and Controls

development to determine the need for appropriate mitigation. If listed species are detected and impacts cannot be avoided, appropriate mitigation could be required on a case-by-case basis. Under wetland mitigation planning, several hundred acres of low-value pine plantations and degraded wetlands would be rehabilitated and restored to native upland and wetland plant communities. The higher-quality habitat provided by these restored communities would likely be beneficial to many listed species. 

Aquatic Ecosystems Erosion and runoff control mitigation practices would be used to prevent siltation of preserved ponds 

onsite. Stormwater-management basins and cessation of forest plantation activities on the site would create improved freshwater aquatic habitat. Construction for both the barge-unloading facility and the intake structure would occur in upland areas behind an earth bank that separates construction activities from the CFBC until excavation is complete. Steel sheet piling would be installed at the barge slip and in a cofferdam for intake structure construction. Piles would be installed from land using a pile hammer. Turbidity barriers and erosion control measures would be installed in the canal during activities associated with sheet-pile installation to control impacts on water quality. Residual water from dredging activities would be tested for compliance with NPDES and Florida standards for surface-water quality before being returned to the CFBC. Construction of intake and discharge piping over the Inglis Lock bypass channel along an existing bridge would follow BMPs associated with stream-crossing regulations associated with minimization of sedimentation and bank erosion. PEF would site the new 500- to 230- and 65-kV transmission lines in accordance with PPSA and Fla. Admin. Code 62-17. PEF procedures for implementation include consultation with the FWS and an evaluation of impacts on special habitats and threatened and endangered species. All work would be conducted in accordance with Federal and State permitting requirements for maintaining water quality and protecting natural resources, such as maintenance of a 15 ft or greater buffer of natural vegetation for construction near waterbodies. PEF plans to leave a 25-ft buffer of existing vegetation with mature heights not exceeding 12 ft at locations where the corridor crosses a navigable waterway. Permits required include a USACE Section 10 – Rivers and Harbors Act Permit, National Marine 
Draft NUREG-1941 4-130 August 2010 

Construction Impacts at the Proposed Site Table 4-16. (contd) Impact Category Planned Mitigation and Controls Fisheries Service (NMFS) authorization under the Magnuson-Stevens Fishery Conservation and Management Act, FDEP Environmental Resources Permit, FDEP and Southwest Water Management District dewatering permit, and FDEP NPDES construction stormwater permit. PEF would comply with the Standard Manatee Conditions for In-Water Work (FDEP 2009b) for construction activities in the CFBC to prevent impacts on manatees in the vicinity of construction activities. These conditions include halting all construction-related activities if manatees are spotted within a 50-ft radius of the activity. A wildlife spotter is required during all construction-related activities. PEF plans to perform construction-related monitoring in the CFBC associated with construction of the CWIS and with the discharge piping placement. During construction activities, a biologist would be present to visually monitor for threatened and endangered species that may appear in the CFBC or CREC discharge areas. Socioeconomic Impacts

Social and Economic Impacts

To mitigate traffic impacts, PEF could develop and implement a site-development traffic-management plan that would include such measures as turn-lane installation where necessary, establishing a centralized parking area with shuttle service, encouraging carpools, and staggering shifts. Other methods to mitigate potential impacts include (1) avoiding routes that could adversely affect sensitive areas (e.g., housing, hospitals, schools, retirement communities, businesses) to the extent possible, and (2) restricting activities and delivery times to daylight hours. PEF would communication regularly with local government and planning officials to give them ample time to plan for the impact of the site-development-related population influx on housing. Efforts to mitigate potential housing shortages would be market-driven (provided by the normal reaction of housing construction to local demand and supply conditions) over time. Site-development employment would peak after build-up of several years. This would allow time for construction of new housing as well as for newly arriving in-migrating workers to locate into areas with greater housing availability. Temporary housing could be constructed as needed. PEF would maintain communication with local government officials so that police, emergency response, and fire-protection services could be coordinated, planned, and focused on the areas of highest priority, given that funding for expansion of capacity that would be provided through the increased tax revenues 
August 2010 4-131 Draft NUREG-1941 

Construction Impacts at the Proposed Site 

Table 4-16. (contd)

Impact Category Planned Mitigation and Controls

from the development project would occur only after the units begin operation and would be limited to Levy County. PEF would maintain communication with local school officials so that school capacity expansion could be coordinated, planned, and focused on the areas in which shortages might occur. Short-term solutions to school crowding could be implemented by adding modular classrooms and hiring additional teachers at existing schools. Within the framework of Florida’s school equalization mechanisms, funding for additional resources would be provided through the increased tax revenues from the sitedevelopment project. In addition, PEF would coordinate with local and regional training institutions to increase the capacity of local residents to obtain employment in site-development-related activities. 

Environmental Justice

Analysis of potential health effects, housing availability and public services and transportation in Levy, Citrus, and Marion Counties determined that the probability of minority and low-income populations absorbing a disproportionate impact through increased rental rates and housing costs or impacts on local public services is low. Because of this, specific control efforts – for example, rent controls – would not be necessary. 

Historic and Cultural Properties 

Take appropriate actions as required by site procedures following discovery of potential historic or archaeological resources and the Florida State site-certification process. PEF has agreed to complete comprehensive Phase I surveys prior to construction activities, once transmission-line corridors within the rights-of-way have been finalized (PEF 2009a). The transmission-line corridor from the proposed LNP to Central Florida South substation contains one site (8SM128) eligible for listing in the National Register of Historic Places (NRHP) and two sites having confirmed or potential human remains (8SM10 and 8SM84). Site 8SM128 is a site with both historic and prehistoric components. According to PEF (2009a), “These sites will be avoided to the maximum extent practicable during [right-of-way] selection and structure placement as described in ER Subsection 9.4.3. If avoidance of these three resources is not feasible, then appropriate minimization or mitigation measures will be developed in coordination with the SHPO.” 
Draft NUREG-1941 4-132 August 2010 

Construction Impacts at the Proposed Site Table 4-16. (contd) Impact Category Planned Mitigation and Controls Air Quality Fugitive dust particles would be generated by the movement of machinery and materials as well as during windy periods over recently disturbed or cleared areas. The FDEP and the U.S. Environmental Protection Agency (EPA) have standards for fugitive dust emissions. PEF has committed to preparing a dust-control plan before the start of construction, and a number of dust-control measures are described in its ER (PEF 2009a). These measures include stabilizing ground surfaces with vegetation or gravel and wetting roadways and construction areas. A temporary concrete batch plant would be installed at the site. Emissions from the batch plant would consist of particulate matter and exhaust from trucks moving concrete or raw materials. If a temporary permit is required for the operation of the batch plant, one would be obtained from the FDEP (PEF 2009a). If construction activities include the burning of debris, refuse, or residual construction materials, a permit would be secured from the State. 

While air emissions from transportation are unavoidable, PEF would use BMPs related to the construction activities to minimize impacts on the local ambient air quality. PEF has not identified any measures specifically related to transportation emissions; however, the Environmental Report (ER) (PEF 2009a) discusses the following controls and procedures that, in general, would reduce constructionrelated air emissions: 

• Grading would be performed to promote good drainage. • Ground surfaces would be stabilized as soon as practical to prevent wind erosion. • Areas that would revert to maintained grounds would be reseeded as soon as practicable to reduce 

the potential for fugitive dust generation. 

• During dry conditions, bare ground in the construction area and along nearby construction roads 

would be wetted to minimize the generation of fugitive dust from vehicle traffic. 

• Roadways used to access the proposed LNP site would be wetted to minimize fugitive dust from 

traffic or heavy equipment operation. 

• Open or lightly traveled areas would either be paved, covered in hard-packed aggregate, or 

vegetated to minimize fugitive dust emissions from traffic and wind erosion. 

• Heavily traveled unpaved construction roads and laydown areas would be stabilized with suitable 
August 2010 4-133 Draft NUREG-1941 

Construction Impacts at the Proposed Site 

Table 4-16. (contd)

Impact Category Planned Mitigation and Controls

• materials such as stone dust to prevent wind erosion or fugitive dust generation by heavy equipment. • Applicable air pollution-control regulations with regard to open burning and the operation of fueled 

vehicles would be followed. 

• Where required, permits and operating certificates would be obtained. • Fuel-burning construction equipment would be maintained in proper mechanical order to minimize 

emissions. 

• All reasonable precautions would be implemented to prevent accidental brush or forest fires. 

• A fugitive dust-control plan would be developed and reviewed periodically to assess and improve the 

effectiveness of fugitive dust-control measures and practices. 

PEF stated that all applicable Federal, State, and local emission requirements would be adhered to as they relate to open burning or the operation of fuel-burning equipment in Section 4.4.1.2 of the ER (PEF 2009a). The appropriate Federal, State, and local permits and operating certificates would be obtained as required. 

Nonradiological Health Impacts 

PEF states that it would adhere to all NRC, OSHA, and State safety standards, practices, and procedures during building activities (PEF 2009i). PEF states that a safety and medical program would be provided for construction workers and that all construction contractors and site staff would be required to comply with and Federal, State, and County regulations governing site safety, fire, noise, security policies, safe work practices (FDEP 2010a). Operational controls would be used to reduce dust and vehicular air emissions (PEF 2008a). To mitigate potential transportation fatalities, PEF could develop and implement a site-development traffic-management plan (as mentioned in Social and Economic Impacts above). These actions would help minimize or prevent injury, illness, and death. 

Radiation Exposure to Construction Workers

Doses to construction workers would be maintained below NRC public dose limits (10 CFR Part 20). 
Draft NUREG-1941 4-134 August 2010 

Construction Impacts at the Proposed Site Table 4-16. (contd) Impact Category Planned Mitigation and Controls Nonradioactive Waste Solid, liquid, and gaseous wastes generated when building LNP Units 1 and 2 would be handled according to county, State, and Federal regulations. Solid waste would be recycled, disposed of in existing, permitted landfills or, in the case of vegetative waste only, chipped and spread onsite, or burned in accordance with applicable regulations. Sanitary wastes would be removed to an existing licensed sewage-treatment facility or discharged locally after being treated to the levels stipulated in the NPDES permit. A SWPPP would specify the mitigation measures to be put in place to manage stormwater runoff. BMPs to control dust and to minimize vehicle emissions would be expected to avoid any noticeable, offsite, air quality impacts. 
Construction Impacts at the Proposed Site 

August 2010 4-135 Draft NUREG-1941 

1 4.12 Summary of Construction and Preconstruction Impacts 

2 The Impact levels determined by the review team in the previous sections are summarized in 

3 Table 4-17. The impact levels for NRC-authorized construction are denoted in the table as 

4 being SMALL, MODERATE, or LARGE as a measure of their expected adverse environmental 

5 impacts, if any. Impact levels for the combined preconstruction and construction activities are 

6 similarly noted. Socioeconomic categories for which the impacts are likely to be beneficial are 

7 noted as such in the Impact Level columns. 

8 

9 Table 4-17. Summary of Construction and Preconstruction Impacts for Proposed Units 1 and 2 

Category Comments

NRC-Authorized 

Construction 

Impact Level 

Construction 

and 

Preconstruction 

Impact Level 

Land-Use Impacts 

 Site In Chapter 4.0 of the ER, PEF 

estimated that 95 to 100 percent of 

the land-use impacts would be the 

result of preconstruction activities 

such as clearing, grading, building 

roads, excavation, and erection of 

support buildings (PEF 2009a). 

These land-use impacts would 

noticeably alter the existing land 

uses on the site, but would not 

destabilize the resource. 

SMALL MODERATE 

 Transmission 

 Lines and Offsite 

 Areas 

NRC’s LWA rule specifically 

indicates that transmission lines and 

other offsite activities are not 

included in the definition of 

construction. Land-use impacts from 

placement of new transmission lines 

would noticeably alter the existing 

land uses, but would not be 

destabilizing. 

No impact MODERATE 

Water-Related Impacts 

Water Use – 

Surface Water 

Construction and preconstruction 

impacts on surface-water use would 

be negligible. 

SMALL SMALL 

 
Construction Impacts at the Proposed Site 

Draft NUREG-1941 4-136 August 2010 

1 

Table 4-17. (contd)

Category Comments

NRC-Authorized 

Construction 

Impact Level 

Construction 

and 

Preconstruction 

Impact Level 

Water Use – 

Groundwater 

Construction and preconstruction 

impacts on groundwater use would 

be negligible. 

SMALL SMALL 

Water Quality – 

Surface Water 

Construction and preconstruction 

impacts on surface-water quality 

would be negligible. 

SMALL SMALL 

Water Quality – 

Groundwater 

Construction and preconstruction 

impacts on groundwater quality 

would be negligible. 

SMALL SMALL 

Ecological Impacts 

 Terrestrial 

 Ecosystems 

Permanent cover type (habitat) 

losses would total about 627 ac on 

the LNP site and roughly 2008 ac for 

the associated offsite facilities. 

Temporary habitat losses are 

estimated at up to 400 ac for the 

LNP site (including losses of up to 

250 ac that may be incurred to 

compensate for LNP site 

encroachments into the 100-year 

floodplain) and 30 ac for the 

associated offsite facilities. These 

habitat losses include permanent 

impacts on approximately 683 ac of 

wetlands (319 ac on the LNP site 

and roughly 364 ac for the 

associated offsite facilities), and 

temporary impacts on another 90 ac 

of wetlands (84 ac on the LNP site 

and 6 ac for the associated offsite 

facilities). As many as 32 listed 

wildlife species (9 Federally listed 

and 32 State listed) and 76 listed 

plant species (13 Federally listed and 

76 State listed) could be affected by 

the proposed LNP project, 

SMALL MODERATE 
Construction Impacts at the Proposed Site 

August 2010 4-137 Draft NUREG-1941 

Table 4-17. (contd)

Category Comments

NRC-Authorized 

Construction 

Impact Level 

Construction 

and 

Preconstruction 

Impact Level 

particularly along the transmission 

line. 

 Aquatic 

 Ecosystems

Construction and preconstruction 

activities would have minimal impact 

on aquatic ecological resources and 

habitat. 

SMALL SMALL 

Socioeconomic Impacts

Physical Impacts Physical impacts of building activities 

on workers, onsite and offsite 

buildings, and the general public 

would be minimal. Traffic-control 

and -management measures would 

protect any local roads during site 

development. Impacts from 

transmission lines and corridors 

could be MODERATE 

SMALL SMALL to 

MODERATE (if 

transmission lines 

are considered) 

Demography The population relocating to the 

region for the site-development 

activities likely would be SMALL 

relative to the existing population 

base. 

SMALL SMALL 

Economic Impacts 

to Community 

Impact of site development would be 

beneficial to local economies. In 

Levy County beneficial impacts 

would likely be MODERATE, while 

impacts elsewhere would be SMALL. 

For taxes, SMALL and beneficial 

impacts would occur throughout the 

region. 

SMALL 

(beneficial) 

SMALL to 

MODERATE 

(beneficial) 
Construction Impacts at the Proposed Site 

Draft NUREG-1941 4-138 August 2010 

Table 4-17. (contd)

Category Comments

NRC-Authorized 

Construction 

Impact Level 

Construction 

and 

Preconstruction 

Impact Level 

Infrastructure and 

Community 

Services 

Some public services in Levy and 

Marion counties are at capacity; 

consequently any temporary influx of 

workers and their families resulting 

from site development at the Levy 

site could have MODERATE adverse 

impacts. Some increases will be 

necessary in the number of fireprotection, emergency, and law 

enforcement personnel. Impact on 

education would be MODERATE in 

Levy and Marion Counties and 

SMALL in the region. Impact on 

transportation would be MODERATE 

in Levy County and SMALL 

elsewhere. 

SMALL to 

MODERATE 

SMALL to 

MODERATE 

Environmental Justice 

Impacts 

There would be no disproportionate 

and adverse impacts on minorities or 

low-income populations from any 

potential pathways or practices of 

these populations. 

SMALL SMALL 

Historic and Cultural 

Resource Impacts 

Based on PEF procedures and 

commitments to follow those 

procedures, if historical and cultural 

resources are discovered, the 

impacts would be SMALL. Also 

based on PEF commitments to 

conduct transmission line surveys, 

the impacts would be SMALL, but 

could be greater. 

SMALL SMALL 

Meteorology and Air 

Quality Impacts 

Emissions of criteria pollutants would 

be temporary and limited and carbon 

footprint of construction workforce 

would not be noticeable. 

SMALL SMALL 
Construction Impacts at the Proposed Site 

August 2010 4-139 Draft NUREG-1941 

Table 4-17. (contd)

Category Comments

NRC-Authorized 

Construction 

Impact Level 

Construction 

and 

Preconstruction 

Impact Level 

Nonradiological Health 

Impacts 

Emissions of dust and air pollutants 

would be limited by operational 

controls; noise impacts would comply 

with Federal, State and County 

standards. Worker health and safety 

would be ensured by compliance 

with NRC, OSHA, and State 

standards. Transportation impacts 

would be minimal. 

SMALL SMALL 

Radiological Health 

Impacts 

Doses to construction workers would 

be maintained below NRC public 

dose limits (10 CFR Part 20). 

SMALL SMALL 

Nonradioactive Waste Impacts on water, land, and air from 

the generation of nonradioactive 

waste would be minimal. 

SMALL SMALL 

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31 9_Part_C-r.pdf. 
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28 17&_geoContext=01000US%7C04000US12%7C05000US12017&_street=&_county=Levy&_cit

29 yTown=Levy&_state=04000US12&_zip=&_lang=en&_sse=on&ActiveGeoDiv=geoSelect&_useE

30 V=&pctxt=fph&pgsl=050&_submenuId=factsheet_1&ds_name=ACS_2007_3YR_SAFF&_ci_nbr

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Construction Impacts at the Proposed Site 

Draft NUREG-1941 4-148 August 2010 

1 05000US12017&_geoContext=01000US%7C04000US12%7C05000US12075&_street=&_coun

2 ty=Citrus&_cityTown=Citrus&_state=04000US12&_zip=&_lang=en&_sse=on&ActiveGeoDiv=ge

3 oSelect&_useEV=&pctxt=fph&pgsl=010&_submenuId=factsheet_1&ds_name=ACS_2007_3YR

4 _SAFF&_ci_nbr=null&qr_name=null®=null%3Anull&_keyword=&_industry=. Accession No. 

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8 http://www.factfinder.census.gov/servlet/ACSSAFFFacts?_event=&geo_id=05000US12083&_g

9 eoContext=01000US%7C04000US12%7C05000US12083&_street=&_county=marion&_cityTo

10 wn=marion&_state=04000US12&_zip=&_lang=en&_sse=on&ActiveGeoDiv=geoSelect&_useEV

11 =&pctxt=fph&pgsl=050&_submenuId=factsheet_1&ds_name=DEC_2000_SAFF&_ci_nbr=null&

12 qr_name=null®=null%3Anull&_keyword=&_industry=. Accession No. ML101960361. 

13 U.S. Department of Transportation (DOT). 2003. “From Home to Work, the Average Commute 

14 is 26.4 Minutes.” Omnistats 3(4). Accession No. ML100621425. 

15 U.S. Environmental Protection Agency (EPA). 2009. Global Greenhouse Gas Data. Accessed 

16 January 22, 2010 at http://www.epa.gov/climatechange/emissions/globalghg.html. Accession 

17 No. ML100221499. 

18 U.S. Fish and Wildlife Service (FWS). 2003. Recovery Plan for the Red-Cockaded 

19 Woodpecker (Picoides borealis). Second Revision, Atlanta, Georgia. 

20 U.S. Fish and Wildlife Service (FWS). 2004. Standard Protection Measures for the Eastern 

21 Indigo Snake. Accessed August 5, 2009 at 

22 http://www.fws.gov/northflorida/IndigoSnakes/20040212_gd_EIS_Standard_Protection_Measur

23 es.pdf. Accession No. ML101960348. 

24 U.S. Fish and Wildlife Service (FWS). 2007. National Bald Eagle Management Guidelines. 

25 Washington, D.C. Available at 

26 http://www.fws.gov/pacific/eagle/NationalBaldEagleManagementGuidelines.pdf. Accession No. 

27 ML101960349. 

28 U.S. Fish and Wildlife Service (FWS). 2009a. Florida County Index of Listed Species – North 

29 Florida Ecological Services Office - Levy, Citrus, Marion, Sumter, Lake, Hernando, Pinellas, and 

30 Hillsborough Counties. Accessed January 22, 2009 at 

31 http://www.fws.gov/northflorida/gotocty.htm. Accession No. ML101930613. 

32 U.S. Fish and Wildlife Service (FWS). 2009b. Federally Listed & Candidate Species in Polk 

33 County, Florida – South Florida Ecological Field Office. Accessed January 22, 2009 at 
Construction Impacts at the Proposed Site 

August 2010 4-149 Draft NUREG-1941 

1 http://www.fws.gov/verobeach/images/pdflibrary/Polk%20County2.pdf. Accession No. 

2 ML101930598. 

3 U.S. Fish and Wildlife Service (FWS). 2009c. Florida Wood Stork Colonies Core Foraging 

4 Areas. Accessed January 22, 2009 at 

5 http://www.fws.gov/northflorida/WoodStorks/Documents/110107-WOST-Nest-Colonies-Forag6 Areas-w-buffers.pdf. Accession No. ML101960355. 

7 U.S. Fish and Wildlife Service (FWS). 2009d. Migratory Birds & Habitat Programs. Accessed 

8 October 8, 2008 at http://www.fws.gov/pacific/migratorybirds/mbta.htm. Accession No. 

9 ML101960350. 

10 U.S. Fish and Wildlife Service (FWS). 2009e. Letter from Dave L. Hankla, FWS, to Gregory 

11 Hatchett, NRC, dated February 9, 2009, regarding Response to Scoping. Accession No. 

12 ML090720063. 

13 U.S. Fish and Wildlife Service (FWS). 2010a. Atlantic Flyway. Accessed May 12, 2010 at 

14 http://www.pacificflyway.gov/Documents/Atlantic_map.pdf. Accession No. ML101930596. 

15 U.S. Fish and Wildlife Service (FWS). 2010b. Florida Salt Marsh Vole Species Account. 

16 Accessed May 19, 2010 at http://www.fws.gov/northflorida/Species-Accounts/Saltmarsh-Vole17 2005.htm. Accession No. ML101960354. 

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

19 for License Renewal of Nuclear Plants. NUREG-1437. Washington, D.C. 

20 U.S. Nuclear Regulatory Commission (NRC). 1999. Generic Environmental Impact Statement 

21 for License Renewal of Nuclear Plants. NUREG-1437, Vol.1, Addendum 1, Washington, D.C. 

22 U.S. Nuclear Regulatory Commission (NRC). 2000. Environmental Standard Review Plan – 

23 Standard Review Plans for Environmental Reviews for Nuclear Power Plants. NUREG-1555, 

24 Vol. 1, Washington, D.C. Includes 2007 revisions. 

25 U.S. Nuclear Regulatory Commission (NRC). 2002. Final Generic Environmental Impact 

26 Statement on Decommissioning of Nuclear Facilities. NUREG-0586, Supplement 1, Vols. 1 and 

27 2, Washington, D.C. 

28 U.S. Nuclear Regulatory Commission (NRC). 2009. Socioeconomic Field Notes for 

29 August 20-21, 2007 and December 2-3, 2008 Visits to Levy County and Surrounding 

30 Communities. Accession No. ML091290001. 
Construction Impacts at the Proposed Site 

Draft NUREG-1941 4-150 August 2010 

1 Westinghouse Electric Company LLC (Westinghouse). 2008. AP1000 Design Control 

2 Document. APP-GW-GL-700, Revision17, Pittsburgh, Pennsylvania. Accession No. 

3 ML0832308.
August 2010 5-1 Draft NUREG-1941 

1 5.0 Operational Impacts at the Proposed Site 

2 This chapter examines environmental issues associated with operation of proposed Units 1 and 

3 2 at the Levy Nuclear Plant (LNP) site for an initial 40-year period as described by the applicant, 

4 Progress Energy Florida, Inc. (PEF). As part of its application for combined construction 

5 permits and operating licenses (COLs), PEF submitted an Environmental Report (ER) that 

6 discussed the environmental impacts of station operation (PEF 2009a). The NRC staff, its 

7 contractors’ staff, and the U.S. Army Corps of Engineers (USACE) staff (hereafter referred to as 

8 the “review team”) independently evaluated information presented in PEF’s Environmental 

9 Report (ER) (PEF 2009a) and supplemental documents, PEF’s responses to NRC Requests for 

10 Additional Information (RAIs), PEF’s Site Certification Application submitted to the Florida 

11 Department of Environmental Protection (FDEP) (PEF 2008a), the FDEP review of the 

12 proposed project (FDEP 2009a), USACE permitting documentation (Entrix 2010), as well as 

13 other government and independent sources. 

14 This chapter is divided into 14 sections. Sections 5.1 through 5.12 discuss the potential 

15 operational impacts on land use, water, terrestrial and aquatic ecosystems, socioeconomics, 

16 environmental justice, historic and cultural resources, meteorology and air quality, 

17 nonradiological and radiological health effects, nonradioactive waste, postulated accidents, and 

18 applicable measures and controls that would limit the adverse impacts of station operation 

19 during the 40-year operating period. In accordance with Title 10 of the Code of Federal 

20 Regulations (CFR) Part 51, impacts have been analyzed and a significance level of potential 

21 adverse impacts (i.e., SMALL, MODERATE, or LARGE) has been assigned by the review team 

22 to each impact category. In the area of socioeconomics related to taxes, the impacts may be 

23 considered beneficial and are stated as such. The review team’s determination of significance 

24 levels is based on the assumption that the mitigation measures identified in the ER or activities 

25 planned by various state and county governments, such as infrastructure upgrades, as 

26 discussed throughout this chapter, are implemented. Failure to implement these upgrades 

27 might result in a change in significance level. Possible mitigation of adverse impacts is also 

28 presented, where appropriate. A summary of these impacts is presented in Section 5.13. The 

29 references cited in this chapter are listed in Section 5.14. 

30 5.1 Land-Use Impacts 

31 This section contains information about land-use impacts associated with operation of proposed 

32 Units 1 and 2 at the LNP site. Section 5.1.1 discusses land-use impacts at the site, in the 

33 vicinity, in the region, and in offsite areas. Section 5.1.2 discusses land-use impacts with 

34 respect to offsite transmission-line corridors. 
Operational Impacts at the Proposed Site 

Draft NUREG-1941 5-2 August 2010 

1 5.1.1 The Site, Vicinity, Region, and Offsite Areas 

2 Operational impacts are discussed for the LNP site and offsite areas within the vicinity of the 

3 site (i.e., within a 6-mi radius), and within the 50-mi region. Onsite land-use impacts from 

4 operation of proposed Units 1 and 2 are expected to be minimal because minimal additional 

5 land would be affected other than those lands disturbed during building of the plant. As 

6 described in Section 5.3.1.1, some onsite plants could suffer leaf damage due to salt drift from 

7 the two mechanical draft cooling towers, but no adverse impacts on vegetation are predicted for 

8 offsite lands in the vicinity. 

9 Approximately 1280 ac of land in the vicinity of the LNP site would be affected by project-related 

10 support activities (PEF 2009c). PEF anticipates that most of these lands would be returned to 

11 preconstruction use during operation, although the heavy-haul and site access roads, barge 

12 slip, and makeup-water pump house would remain in use. Stormwater controls described as 

13 best management practices (BMPs) in Section 4.2.1 of this environmental impact statement 

14 (EIS) would be maintained during operations to minimize erosion and sedimentation in the 

15 offsite areas. Therefore, the review team concludes that the impacts of operations on other 

16 offsite areas, apart from the transmission-line corridors, would be minor, and additional 

17 mitigation would not be warranted. 

18 5.1.2 Transmission-Line Corridors 

19 Most land-use impacts associated with transmission lines would occur during the building of the 

20 new units. Land-use impacts during operations would be associated with corridor maintenance 

21 activities for actions such as vegetation management, tower repairs, and habitat maintenance. 

22 PEF would maintain transmission lines and corridors in accordance with its maintenance plan 

23 described in Section 3.4.2.7 and as required in the FDEP’s Conditions of Certification (FDEP 

24 2010). Maintenance practices are designed to be both preventative and corrective. PEF would 

25 conduct annual inspections of transmission-line corridors using both ground and aerial methods. 

26 The exact nature of maintenance activities would depend upon the location, type of terrain, and 

27 surrounding environment. Maintenance activities would also be adjusted to manage site28 specific vegetation and habitat, with special accommodations made for endangered or 

29 threatened species (PEF 2009a). 

30 Where a transmission-line corridor passes through agricultural lands, PEF would maintain a 

31 corridor-use program that considers requests for multiple uses. This would include agricultural 

32 operations, controlled landscaping, or other activities that do not disrupt PEF’s use of the 

33 corridor for maintenance and operation of the transmission line. Transmission-line corridors 

34 adjacent to, or in the proximity of, existing corridors generally would allow multiple uses 

35 consistent with those currently allowed. 
Operational Impacts at the Proposed Site 

August 2010 5-3 Draft NUREG-1941 

1 No ground-disturbing activities are planned to occur during the maintenance of transmission 

2 lines constructed to support the operation of proposed LNP Units 1 and 2. Because PEF 

3 provides easements to allow agricultural activities under its transmission lines, and because 

4 many of the transmission lines would be collocated with existing transmission lines, the review 

5 team concludes that the land-use impacts associated with power transmission in support of 

6 plant operation would be minor, and additional mitigation would not be warranted. 

7 5.1.3 Summary of Land-Use Impacts 

8 Because minimal additional land would be affected other than that disturbed during building of 

9 the plant, onsite and offsite land-use impacts from operation of proposed Units 1 and 2 are 

10 expected to be minimal. Transmission-line maintenance activities are expected to have only 

11 minor land-use impacts during operations. Based on information provided by PEF and the 

12 review team’s own independent review, the review team concludes that land-use impacts of 

13 operations would be SMALL. 

14 5.2 Water-Related Impacts 

15 This section discusses water-related impacts on the surrounding environment from operation of 

16 proposed LNP Units 1 and 2. Details of the operational modes and cooling-water systems 

17 associated with operation of the proposed units can be found in Section 3.2.2.2 of this EIS. 

18 Managing water resources requires understanding and balancing the tradeoffs between various, 

19 often conflicting, objectives. At the site of the proposed LNP Units 1 and 2, these objectives 

20 include navigation, recreation, visual aesthetics, a fishery, and a variety of beneficial 

21 consumptive water uses. The responsibility for any work in, over, or under navigable waters of 

22 the United States is delegated to the USACE. The FDEP is responsible for protecting and 

23 restoring the quality of Florida water, air, and land resources, and the Florida Department of 

24 Community Affairs is responsible for determination of project consistency with Florida’s Coastal 

25 Zone Management Plan. 

26 Water-use and water-quality impacts involved with operation of a nuclear plant are similar to the 

27 impacts associated with any large thermoelectric power generation facility. Accordingly, PEF 

28 must obtain the same water-related permits and certifications as any other large industrial 

29 facility. These include the following: 

30 Clean Water Act Section 401 Certification. This certification is issued by the FDEP as part 

31 of Florida’s Power Plant Siting Act (PPSA) Certification (29 Fla. Stat. 403) and ensures that 

32 the project does not conflict with State water-quality standards. This certification must be 

33 obtained before the NRC could issue a COL to PEF. 

34 
Operational Impacts at the Proposed Site 

Draft NUREG-1941 5-4 August 2010 

1 Clean Water Act Section 402(p) National Pollutant Discharge Elimination System (NPDES) 

2 Discharge Permit. This permit would regulate limits of pollutants in liquid discharges to 

3 surface water. The U.S. Environmental Protection Agency (EPA) has delegated the 

4 authority for administering the NPDES program in Florida to the FDEP. The NPDES permits 

5 are part of the PPSA certification. A stormwater pollution prevention plan (SWPPP) would 

6 be required. 

7 Water-Use Permit. Consumptive use of surface water or groundwater would require a 

8 permit from the FDEP or the water-management district. 

9 5.2.1 Hydrological Alterations 

10 Hydrologic alterations during the operation of proposed LNP Units 1 and 2 are expected to be 

11 limited to the following activities: 

12 alteration of the flow pattern in the CFBC because of diversion of makeup water for normal 

13 plant operations 

14 alteration of the discharge plume in the Gulf of Mexico at the mouth of the Crystal River 

15 Energy Complex (CREC) discharge canal due to addition of the LNP discharge 

16 alteration of wetlands and surface water bodies near the LNP site because of deposition of 

17 salt carried with drift from cooling towers 

18 Makeup water needed for cooling the reactors for proposed LNP Units 1 and 2 under normal 

19 operational mode would be supplied from the Gulf of Mexico via the CFBC using a new CWIS. 

20 The blowdown from the Units 1 and 2 cooling towers and other treated wastes would be 

21 discharged through a new discharge pipeline routed from the LNP facility into the existing CREC 

22 discharge canal and, eventually, to the Gulf of Mexico. Groundwater from onsite water-supply 

23 wells completed in the Upper Floridan aquifer would be used to supply general plant operations, 

24 including making up water lost through service-water cooling tower drift and evaporation, potable 

25 water supply, raw water to the demineralizer, fire protection, and media filter backwash (PEF 

26 2009a). 

27 Because of cooling water withdrawal from the CFBC at the CWIS, the flow patterns in the canal 

28 would change. The CFBC is connected to the Gulf of Mexico and is subject to tidal exchanges 

29 of water. There is occasional discharge of freshwater over the Inglis Dam spillway during flood 

30 events. Groundwater springs also contribute some flow to the Old Withlacoochee River below 

31 the Inglis Dam and to the CFBC below the Inglis Lock. Water withdrawn by the CWIS would 

32 capture the spring flows into the CFBC and also induce a net flow from the Gulf of Mexico into 

33 the canal. These surface water exchanges are described below. 

34 Because of drift from the cooling towers, salt deposition would occur near the LNP site (PEF 

35 2009a). The deposited salt may be dissolved in runoff following precipitation events and is 
Operational Impacts at the Proposed Site 

August 2010 5-5 Draft NUREG-1941 

1 subsequently carried off to nearby wetlands and surface water bodies. Section 5.3.1.1 

2 describes this analysis and the associated impacts in more detail. 

3 As discussed in Section 2.3.1.2, because the original groundwater model developed as a 

4 requirement of the Florida Site Certification Application under-predicted hydraulic heads in the 

5 vicinity of the LNP site, the staff requested that PEF recalibrate the model using both site6 specific and regional head data. This recalibrated model resulted in predictions of increased 

7 drawdown and demonstrated that uncertainty in hydraulic property values in the vicinity of the 

8 proposed LNP wellfield can significantly influence assessment of wetlands impacts. Results 

9 from these predictive simulations using the recalibrated model indicate that annual average LNP 

10 groundwater usage from the Upper Floridan aquifer will, after 60 years of operation, result in 

11 surficial aquifer drawdowns of as much as 2 ft in areas where wetlands are present. In addition, 

12 the lateral extent of the 0.5-ft drawdown contour extends up to 3 mi from the pumping well 

13 locations (Figure 5-1). The predicted maximum drawdown affecting wetlands (less than 2.5 ft) 

14 is less than 31 percent of the normal seasonal variability (as much as 8 ft) observed in 

15 groundwater levels in the vicinity of the LNP site (see discussion of potentiometric surfaces in 

16 Section 2.3.1.2). 

17 The FDEP conditions of certification require PEF to develop an environmental monitoring plan, 

18 which includes a hydraulic testing program during drilling and installation of the proposed water19 supply wells to obtain site-specific hydraulic property estimates and determine whether the 

20 wellfield can meet groundwater-usage requirements without significantly affecting water levels in 

21 the surficial aquifer. The conditions of certification require that during operation of the LNP 

22 wellfield, PEF must limit drawdowns in the surficial aquifer to levels that ensure no adverse 

23 impacts on wetlands. 

24 5.2.2 Water-Use Impacts 

25 A description of water-use impacts on surface water and groundwater is presented in the 

26 following sections. The water resource usage by proposed LNP Units 1 and 2 operations is 

27 limited to diverting water from the CFBC for makeup-water needs during normal operations and 

28 pumping groundwater for general plant operations, including service-water tower drift and 

29 evaporation, potable water supply, raw water to the demineralizer, fire protection, and media 

30 filter backwash. 

31 5.2.2.1 Surface Water 

32 Waters obtained from the Gulf of Mexico and spring flow into the CFBC would be used as the 

33 source of makeup water used during normal plant operations. As stated in Section 3.4.2.1, LNP 

34 Units 1 and 2 would withdraw a maximum of 84,780 gpm (190 cfs) from the CFBC and 

35 discharge 57,923 gpm (129 cfs) of blowdown from the cooling system to the CREC discharge 

36 canal. Because the Gulf is virtually an unlimited source of water supply compared to the LNP 

37 Units 1 and 2 makeup-water requirements, the review team determined that the use of water 
Operational Impacts at the Proposed Site

Draft NUREG-1941 5-6 August 2010 1 Figure 5-1. Simulated Incremental Surficial Aquifer System (SAS) Drawdown Associated with LNP Operations 2 (PEF 2010a) 3 4 
Operational Impacts at the Proposed Site 

August 2010 5-7 Draft NUREG-1941 

1 from the Gulf would have essentially no impact on it. Therefore, the impact on surface water 

2 resources due to LNP use during operations is expected to be SMALL and further mitigation 

3 measures would not be warranted. 

4 5.2.2.2 Groundwater 

5 Groundwater from onsite water supply wells completed in the Upper Floridan aquifer will be 

6 used to supply general plant operations, including service-water cooling, potable-water supply, 

7 raw water to the demineralizer, fire protection, and media filter backwash (PEF 2009a). PEF 

8 has estimated that plant operations would require an average total withdrawal of 1.58 Mgd of 

9 groundwater from the Floridan aquifer and a potential maximum daily withdrawal of 5.8 Mgd 

10 (PEF 2009c). 

11 PEF developed a local-scale groundwater flow model as a requirement of the LNP Site 

12 Certification Application to the State of Florida. This model, which was a local refinement of the 

13 Southwest Florida Water Management District’s (SWFWMD) District-Wide Regulation Model, 

14 Version 2 (DWRM2) regional groundwater flow model, was used to simulate both LNP and 

15 cumulative groundwater-usage impacts (see Figure 2-12). SWFWMD staff provided technical 

16 guidance and peer review on development of the local-scale model and, once all identified 

17 technical deficiencies were resolved, issued a completeness determination that recommended 

18 authorizing the average and maximum daily usage values described (i.e., 1.58 and 5.8 Mgd, 

19 respectively), provided that State of Florida Conditions of Certification are met (FDEP 2010). As 

20 discussed in Section 2.3.1.2, this model was subsequently recalibrated to improve model fit in 

21 the vicinity of the LNP site. 

22 PEF tested a number of wellfield locations and configurations using the model to evaluate 

23 potential drawdown impacts throughout the model domain. Based on this analysis, PEF 

24 determined that siting the wellfield in the southern portion of the proposed LNP property, where 

25 regional- and/or local-scale transmissivity is greatest, would reduce drawdown levels in both the 

26 Upper Floridan and surficial aquifers compared to siting wells in other feasible locations. Using 

27 this wellfield configuration, PEF performed predictive simulations of aquifer drawdown response 

28 to an annual average wellfield production rate of 1.58 Mgd (PEF 2009c). 

29 Results from the predictive simulations indicate that annual average LNP groundwater usage 

30 from the Upper Floridan aquifer is minor relative to the overall model water balance (Figure 5-2). 

31 As indicated, average LNP operational usage (1.58 Mgd) represents only a small percentage 

32 (0.8 percent) of the total water flux (208 Mgd) through the model domain. At this withdrawal 

33 rate, the LNP wellfield is predicted to decrease the surficial and Upper Floridan aquifer 

34 discharge to surface waterbodies within the model domain by approximately 0.4 Mgd, or about 2 

35 percent of the total simulated groundwater discharge to rivers and lakes. These simulated 

36 impacts on Lake Rousseau and the lower Withlacoochee River, which is designated as an 

37 Outstanding Florida Water, are minor relative to the 37-year recorded average daily discharge 
Operational Impacts at the Proposed Site 

Draft NUREG-1941 5-8 August 2010 

1 

2 Figure 5-2. Local-Scale Groundwater Model Water Balance (PEF 2010a) 

3 
Operational Impacts at the Proposed Site 

August 2010 5-9 Draft NUREG-1941 

1 of 687 Mgd through the bypass channel to the lower Withlacoochee River. In addition, the 

2 groundwater model predicts that discharges to the two largest springs in the vicinity of the 

3 proposed LNP site, Big King and Little King Springs, would decrease by approximately 

4 0.05 Mgd (35 gpm) or about 1 percent of their total simulated flux (PEF 2010a). 

5 PEF predictive simulations indicate that operation of the LNP wellfield is not expected to 

6 adversely affect adjacent permitted users of the Upper Floridan aquifer. The model predicts 

7 less than 1 ft of additional drawdown response at the closest Upper Floridan aquifer user under 

8 annual average total LNP usage conditions of 1.58 Mgd. Under maximum daily usage 

9 conditions (5.8 Mgd) for a duration of 1 week, the model predicts that increased drawdown will 

10 not extend to the closest Upper Floridan aquifer well (i.e., permitted user). 

11 Because LNP operational groundwater usage is minor relative to the overall model water 

12 balance, the staff concludes that operational groundwater-use impacts would be SMALL, and 

13 mitigation beyond the FDEP conditions of certification would not be warranted. 

14 5.2.3 Water-Quality Impacts 

15 This section discusses the impacts on the quality of water resources from the operation of 

16 proposed LNP Units 1 and 2. Surface-water impacts include thermal, chemical, and radiological 

17 wastes and physical changes in the Gulf of Mexico resulting from effluents discharged by the 

18 plant. Impacts on groundwater quality from saltwater intrusion are also assessed. 

19 5.2.3.1 Surface Water 

20 A conceptualization of the existing CFBC-Old Withlacoochee River (OWR) system is shown in 

21 Figure 5-3. The flow components that contribute to the hydrology of this system are the 

22 incoming and outgoing tides from the Gulf of Mexico, freshwater spring inflow into the CFBC 

23 near the base of the Inglis Dam and just below the Inglis Lock, some leakage of Lake Rousseau 

24 from the Inglis Lock, and periodic spillway discharge from the Inglis Dam. 

25 Based on the U.S. Geological Survey (USGS) streamflow records, the minimum, mean, and 

26 maximum daily discharges at the Inglis Dam are 70, 424, and 6030 cfs, respectively (USGS 

27 2009). The discharge at the Inglis Dam exceeds the mean discharge approximately 26 percent 

28 of the time. 

29 The Cedar Key tide gauge is the nearest tide gauge and therefore its observations are used as 

30 representative of those at the mouth of the CFBC. The mean diurnal range at the Cedar Key, 

31 Florida, tidal gauge is 2.83 ft. Over a tidal cycle of approximately 12.5-hour duration (assuming 

32 starting the CFBC level at mean low water, rising to mean high water, and falling back to mean 

33 low water), the average flow into and out of the CFBC during the cycle can be approximated as 

34 (0.5 × (230 ft + 150 ft) × 2.83 ft × 7.0 mi × 5280 ft/mi) ÷ (0.5 × 12.5 hr × 3600 s/hr), or 883 cfs. 
Operational Impacts at the Proposed Site 

Draft NUREG-1941 5-10 August 2010 

1 

2 Figure 5-3. Conceptualization of Flow Within the CFBC-OWR System Under Existing 

3 Conditions (figure is not to scale) 

4 The velocity for this average flow rate would be 0.39 fps or 4.6 in./s. The salinity at the 

5 confluence of the CFBC and the OWR depends on the freshwater discharge into the CFBC from 

6 the springs and any water released over the spillway of the Inglis Dam. Under current 

7 conditions, the CFBC starts to experience elevated salinity as a result of incoming tidal waters 

8 when the combined freshwater discharge from the Inglis Dam and spring inflow is smaller than 

9 883 cfs, which occurs approximately 86 percent of the time. 

10 Due to the operation of the proposed LNP intake, a net inflow to the CFBC from the Gulf of 

11 Mexico would occur (Figure 5-4). The net inflow into the CFBC has the potential to change the 

12 existing water quality in both the CFBC and the OWR. During operation of LNP Units 1 and 2, 

13 the CFBC-OWR system would be subject to the following fluxes: (1) a net intake of 122 Mgd 

14 (190 cfs) for normal plant operations, (2) discharge of leaked freshwater from the Inglis Lock 

15 and freshwater spring inflow just downstream of the Inglis Lock (estimated to be 50 cfs by PEF), 

16 and (3) discharge of freshwater from the Lake Rousseau spillway that enters the CFBC via the 

17 OWR. Freshwater is discharged from the Lake Rousseau spillway during flood events and, 

18 therefore, is intermittent. During low flow conditions (i.e., no discharge from Lake Rousseau 

19 spillway), the USGS estimated a seepage of freshwater into the OWR below the Inglis Dam of 
Operational Impacts at the Proposed Site 

August 2010 5-11 Draft NUREG-1941 

1 

2 Figure 5-4. Conceptualization of Flow Within the CFBC-OWR System During Low Flows 

3 Ignoring Tidal Effects from the Gulf of Mexico (figure is not to scale) 

4 70 cfs (USGS 2009). Figure 5-4 above shows the conceptualization of the CFBC-OWR system 

5 during low flows, ignoring any tidal effects from the Gulf of Mexico. 

6 During low flows and ignoring the tidal cycle, an additional 70 cfs of inflow from the Gulf of 

7 Mexico would be needed to sustain the plant makeup-water intake of 190 cfs. In this scenario, 

8 the maximum flow within the CFBC would occur between the proposed LNP intake and the 

9 confluence of the OWR with CFBC. In this reach, the flow would be 140 cfs. The cross section 

10 of the CFBC has a top width of 230 ft, a bottom width of 150 ft, and an average depth of 12 ft. 

11 The corresponding maximum velocity induced by the operation of the proposed LNP intake 

12 would be 0.06 fps, or less than 1 in./s. The maximum velocity induced by the proposed LNP 

13 intake at the proposed intake location would be essentially unnoticeable. The salinity 

14 corresponding to seawater, 35 psu, would prevail under the low-flow condition from the mouth of 

15 the CFBC up to its confluence with the OWR. Assuming well-mixed conditions, the average 

16 salinity in the reach from the confluence of the CFBC and the OWR to the proposed LNP intake 

17 would be approximately 15 psu (weighted average of approximately 35 psu contributed by the 
Operational Impacts at the Proposed Site 

Draft NUREG-1941 5-12 August 2010 

1 70 cfs inflow from the Gulf of Mexico and approximately 0 psu of the 70 cfs freshwater 

2 discharge from the OWR). 

3 During operations of LNP units, the CFBC would start to experience elevated salinity as a result 

4 of incoming tidal waters when the combined freshwater discharge from the Inglis Dam and 

5 spring inflow is smaller than 1073 cfs, which would occur approximately 89 percent of the time. 

6 Currently, the CFBC experiences elevated salinity approximately 86 percent of the time. The 

7 CFBC-OWR system, during a tidal cycle with a mean diurnal range that may occur during low 

8 flow conditions, currently experiences seawater inflow that is more than 4.6 times the proposed 

9 LNP makeup-water withdrawal. The increment in velocity within the CFBC due to the operation 

10 of the LNP intake would be less than one-sixth of the average velocity of the incoming tidal 

11 waters during low-flow conditions. 

12 The review team concludes that, for the reasons stated above, the additional LNP makeup13 water withdrawal would not significantly alter the existing condition in the CFBC, and the impact 

14 on water quality of the CFBC due to operation of the LNP intake is expected to be minimal. 

15 The OWR currently has a minimum discharge of approximately 70 cfs into the CFBC. This 

16 minimum discharge would not change due to operation of the proposed LNP units. The salinity 

17 within the OWR is controlled by the freshwater discharges from Lake Rousseau and the spring 

18 flow below Inglis Dam. Water-quality sampling performed by PEF on August 27, 2008 shows 

19 that during periods of high discharges from Lake Rousseau, the whole OWR can essentially 

20 become a body of freshwater (PEF 2009c; CH2M Hill 2009b). The mean daily discharge in the 

21 OWR below Lake Rousseau on August 27, 2008 was 1000 cfs (USGS 2009). The 

22 measurements performed by PEF at three locations in the OWR showed that depth-averaged 

23 salinities were 0.35 parts per thousand (ppt) near the confluence of the OWR with the CFBC, 

24 0.34 ppt mid-way between the confluence of the OWR with the CFBC and Inglis Dam, and 0.34 

25 ppt in the OWR just below Inglis Dam. The applicant also measured salinity at the three 

26 locations in the OWR on June 26, 2008. The depth-averaged salinity values at the same three 

27 locations were 4.38, 0.15, and 0.14 ppt with a corresponding mean daily discharge of 141 cfs 

28 (USGS 2009). The applicant reported that the saltwater intrusion into the OWR occurs in the 

29 form of a salinity wedge along the bottom of the profile with bottom salinity of 12.25 ppt on June 

30 26, 2008 at the confluence of the OWR with the CFBC. The applicant also concluded that the 

31 salinity in the OWR just below the Inglis Dam remains less than 1 psu at all times. 

32 Salinity measurements performed by PEF at four locations in the CFBC during October 18, 

33 2007 and September 15, 2008, show a mean depth-averaged salinity of approximately 12 psu 

34 at the confluence of the OWR with the CFBC (PEF 2009c; CH2M Hill 2009b). 

35 PEF performed a simplified analysis of salinity transport from the CFBC into the OWR during 

36 steady-state flow conditions (PEF 2009c; CH2M Hill 2009b). The analysis assumed that under 

37 steady-state conditions, tidal fluctuations would average to a net flow of zero, and the advective 
Operational Impacts at the Proposed Site 

August 2010 5-13 Draft NUREG-1941 

1 transport of salinity out of the OWR would be balanced by the diffusive transport into the OWR 

2 from the CFBC. PEF estimated the salinity at the upstream end of a reach using a finite 

3 difference form of the salt balance equation (Ficsher et al. 1979). The equation predicts the 

4 salinity at the upstream end of the reach using known flow velocity through the reach, salinity at 

5 the downstream end of the reach, length of the reach, and the longitudinal dispersion 

6 coefficient. Salinity at the upstream end of the reach becomes closer in value to that at the 

7 downstream end with decreasing velocity of flow and with an increasing dispersion coefficient. 

8 Because measurement of the dispersion coefficient is not available for the OWR, PEF used 

observed salinity data to estimate a value of about 35 m2

/s (377 ft2 9 /s) assuming a 70 cfs flow in 

the OWR and a value of 50 m2

/s (538 ft2 10 /s) assuming a 100 cfs flow in the OWR. Experimental 

11 measurements of longitudinal dispersion coefficients in natural channels in the USA vary over a 

wide range, from 2 to 1500 m2

/s (22 to 16000 ft2 12 /s) (Kashefipour and Falconer 2002). 

13 Kashefipour and Falconer (2002) developed an empirical relationship using measurements that 

14 were shown to perform reasonably well. In the developed empirical relationship, dispersion 

15 coefficient is proportional to depth of flow and square of velocity and inversely proportional to 

16 shear velocity. Assuming a depth of 2 m (6.6 ft) and a width of 20 m (66 ft), the review team 

17 determined that the flow velocity in the OWR would be approximately 0.06 m/s (0.2 ft/s) at a 

18 discharge of 70 cfs. The review team used these values of depth, width, and velocity in the 

19 empirical relationship developed by Kashefipour and Falconer (2002). The shear velocity was 

20 assumed to be 0.1 m/s (0.33 ft/s), consistent with observed data presented by Kashefipour and 

21 Falconer (2002). The review team-estimated longitudinal dispersion coefficient for the OWR is 

0.8 m2

/s (8.2 ft2 22 /s), which is significantly smaller than the values estimated by PEF using 

23 observed OWR salinity and flow data. Because salinity “transports” more quickly upstream with 

24 increasing values of the longitudinal dispersion coefficient, the review team determined that 

25 PEF’s estimation of salinity upstream in the OWR from the CFBC is conservative. 

26 PEF estimated that at discharges of 70, 100, and 150 cfs through the OWR the salinity at the 

27 upstream end of the OWR or downstream of Inglis Dam would increase 1.2, 0.4, and 0.1 psu 

28 respectively, from existing conditions (PEF 2009c; CH2M Hill 2009b). Because the value of the 

29 longitudinal dispersion coefficient used by PEF is conservative, the review team determined that 

30 the upper reaches of the OWR would only experience minor increases in salinity. 

31 Because of the operation of the proposed LNP discharge, the flow in the CREC discharge canal 

32 would increase from 1985.9 Mgd (CREC Units 1-5 discharge) to 2073.4 Mgd (CREC Units 1–5 

33 plus LNP Units 1 and 2 discharge). The flow increase is approximately 4.4 percent greater than 

34 the existing discharge. The review team independently used the Finite Volume Coastal Ocean 

35 Model (FVCOM) (MEDM 2010; Chen et al. 2003, 2004) to estimate the properties of the 

36 discharge plume in the Gulf of Mexico. Table 5-1 lists the four configurations that resulted in 

37 eight simulated scenarios, one each for summer and winter conditions for each configuration. 

38 Configuration 1 serves as the baseline condition with only CREC Units 1 through 5 discharging 
Operational Impacts at the Proposed Site 

Draft NUREG-1941 5-14 August 2010 

1 to the Gulf via the CREC discharge canal. Configuration 2 added the LNP Units 1 and 2 

2 discharges to the CREC discharge canal. Configuration 3 added the effects of the planned 

3 uprate to CREC Unit 3. Configuration 4 addressed the effects of a potential shutdown of CREC 

4 Units 1 and 2 once LNP Units 1 and 2 start operating. 

5 Table 5-1. Thermal Plume Scenarios Simulated by the Review Team 

Configuration 

Discharge (Mgd) Salinity (psu) 

Discharge Temperature 

(Ambient Temperature) 

Summer Winter Summer Winter Summer Winter 

1. CREC Units 

1-5 

1985.9 1985.9 35.8 35.8 96.5°F or 

35.83°C 

(86°F or 

30.0°C) 

96.5°F or 

35.83°C 

(58°F or 

14.4°C) 

2. CREC Units 

1-5 plus 

LNP Units 1 

and 2 

2073.4 2073.4 36.5 36.5 96.4°F or 

35.78°C 

(86°F or 

30.0°C) 

96.4°F or 

35.78°C 

(58°F or 

14.4°C) 

3. CREC Units 

1-5 with 

CREC Unit 3 

uprate plus 

LNP Units 1 

and 2 

1948 1686 35.9 35.9 96.5°F or 

35.83°C 

(86°F or 

30.0°C) 

96.4°F or 

35.78°C 

(58°F or 

14.4°C) 

4. CREC Units 

3-5 with 

CREC Unit 3 

uprate plus 

LNP Units 1 

and 2 

1030 1052 36.6 36.6 96.4°F or 

35.78°C 

(86°F or 

30.0°C) 

96.4°F or 

35.78°C 

(58°F or 

14.4°C) 

Sources: PEF 2008e, 2009g, 2010b. 

6 Bathymetry data used in model simulations were provided by PEF and the review team 

7 supplemented those data by using NOAA nautical charts and bathymetry data developed by 

8 USACE and the University of North Carolina (UNC 2010). Ambient salinity was assumed to be 

9 35 psu and discharge salinities were calculated based on one cycle of concentration for once10 through cooling discharge (CREC Units 1-3) and 1.5 cycles of concentration for closed-loop 

11 cooling discharges (CREC Units 4 and 5 and LNP Units 1 and 2). Ambient water temperatures 

12 were obtained from the NOAA tide gauge at Cedar Key. 
Operational Impacts at the Proposed Site 

August 2010 5-15 Draft NUREG-1941 

1 Based on these simulations, the review team estimated the discharge plume temperature and 

2 salinity. The incremental impact of the addition of LNP Units 1 and 2 was estimated by maps of 

3 changes in water temperature and salinity. The maps show the changes from the baseline by 

4 subtracting the simulated plume property of Configuration 1 from that of Configuration 2. The 

5 maximum change in water temperature within the simulated plume was significantly smaller 

6 than 0.5°C in summer and slightly greater than 0.5°C in winter. The surface area where the 

7 Configuration 2 plume showed an increase in water temperature of 0.5°C or larger in winter was 

38 km2

 (15 mi2 8 ) in size. The discharge temperature during winter was set to the NPDES9 permitted maximum during the review team’s simulations. However, the discharge 

10 temperatures would be significantly smaller than the NPDES-permitted maximum in winter 

11 because the cooling water withdrawn from the Gulf of Mexico would also be cooler. Therefore, 

12 the incremental increase in plume temperature during winter estimated by the review team’s 

13 simulations is a bounding estimate. Because the incremental increase in plume temperatures in 

14 the Gulf would be significantly smaller than 0.5°C in summer and is bounded by 0.5°C in winter, 

15 the review team concluded that the impact on plume temperature in the Gulf from operation of 

16 LNP Units 1 and 2 would be minimal. 

17 The maximum change in salinity within the simulated plume was less than 0.8 psu in both 

18 summer and winter. The ambient salinity in the Gulf was assumed to be 35 psu. The review 

19 team concluded that the impact on plume salinity in the Gulf from operation of LNP Units 1 and 

20 2 would also be minimal. Because the impact of operation of LNP Units 1 and 2 on water 

21 temperature and salinity in the Gulf near the discharge point would be minimal, the review team 

22 concluded that the impact of operation of LNP Units 1 and 2 on water quality in the Gulf would 

23 be minor. 

24 A SWPPP and an erosion and sedimentation control plan, similar to those used at other large 

25 industrial facilities, would be in place during the operation of proposed LNP Units 1 and 2. 

26 During operation of Units 1 and 2, stormwater runoff from the LNP site would be routed through 

27 a series of drainage ditches to three stormwater detention ponds. The ponds would be 

28 designed to retain the volume of 25-year, 24-hour precipitation. The ponds would also be 

29 designed to drain within 5 days. Excess water from the precipitation events may be used to 

30 supply the cooling-tower basins and be partially discharged with the blowdown. For 

31 precipitation events exceeding the design storm, the detention ponds may overflow. The 

32 overflowing water would be spread out by spreader swales and run off to surrounding land as 

33 sheet flow. The overflowing water may partially infiltrate into the ground or discharge to Spring 

34 Run Creek from the northern portion of the site, to the Gulf of Mexico from the central portion of 

35 the site, and to the Withlacoochee River from a small southern portion of the site. These runoff 

36 contributions from the LNP site would be a small fraction of the three respective watersheds. 

37 Therefore, the impact on water quality from stormwater runoff is expected to be minor. 
Operational Impacts at the Proposed Site 

Draft NUREG-1941 5-16 August 2010 

1 Based on the reviews and analyses described above, the review team determined the impact of 

2 operating LNP Units 1 and 2 on surface water quality of the CFBC, OWR, lower Withlacoochee 

3 River, and other nearby streams would be SMALL and mitigation beyond the FDEP conditions 

4 of certification would not be warranted. 

5 5.2.3.2 Groundwater 

6 Groundwater withdrawals from the Upper Floridan aquifer have the potential to lower 

7 potentiometric surfaces and induce saltwater intrusion. However, due to the relatively small 

8 amount of groundwater usage for proposed LNP operations compared to the overall 

9 groundwater system water balance, and the relatively small drawdowns (less than 2.5 ft) at the 

10 wells and progressively less farther away from the wells) predicted for the LNP wellfield (PEF 

11 2009d), lateral saltwater intrusion from the CFBC is unlikely. Simulation results indicate that 

12 groundwater will continue to discharge to the CFBC (although at a somewhat reduced rate) 

13 rather than the canal acting as a recharge boundary for the groundwater system. The potential 

14 for vertical migration of saline waters from deeper Floridan aquifer intervals also exists at the 

15 site, although a low-permeability carbonate rock sequence (middle confining unit) that separates 

16 the Upper and Lower Floridan aquifers should act to limit vertical migration. A wellfield water17 quality monitoring program would be instituted to detect any detrimental impacts, and wellfield 

18 operations would be managed to mitigate any significant decreases in water quality. Under 

19 these geohydrologic and operational conditions, the staff concludes that operational 

20 groundwater-quality impacts would be SMALL, and mitigation beyond the FDEP conditions of 

21 certification would not be warranted. 

22 5.2.4 Water Monitoring 

23 Section 6.3 of the ER (PEF 2009a) describes the hydrologic monitoring program that will be 

24 used to control potential adverse impacts of LNP operations on surface water and groundwater 

25 and identifies alternatives or engineering measures that could be implemented to reduce these 

26 impacts. Because this section primarily describes PEF’s plans for future monitoring, its 

27 language is based closely on PEF’s description of the monitoring program in the ER. 

28 Because there are no freshwater streams on the LNP site, no operational monitoring of streams 

29 is necessary. The operations of LNP Units 1 and 2 would not affect the nearby Withlacoochee 

30 River, Waccasassa River, Spring Run, and Lake Rousseau. Water level data collected by 

31 USGS at the Inglis Dam would continue and be used to provide information regarding lake 

32 levels during operations of LNP Units 1 and 2. Quarterly preoperational monitoring of water 

33 level and bathymetry (water depth) of the CFBC at Stations 1-3 (see Figure 2-13) would start 

34 one year before LNP Units 1 and 2 begin operations. Daily water level measurements in the 

35 CFBC would also be carried out one year before LNP Units 1 and 2 start operating. Operational 

36 monitoring of the water level and bathymetry of the CFBC canal would occur monthly during the 

37 first two years after either unit begins operation, bimonthly for years 3 through 5, and quarterly 
Operational Impacts at the Proposed Site 

August 2010 5-17 Draft NUREG-1941 

1 after that. CFBC water level monitoring would continue at quarterly intervals during operations. 

2 Quarterly monitoring starting one year before LNP Units 1 and 2 become operational will be 

3 performed at CREC stations 1-4 (see Figure 2-14). Monthly monitoring at CREC stations 1-4 

4 would continue during the first two years after either unit begins operation, bimonthly for years 3 

5 through 5, and quarterly after that. 

6 Most pre-application monitoring wells are located within the footprint of the proposed LNP 

7 construction area and would need to be decommissioned before construction activities begin. 

8 Hydrologic measurements in four pre-application monitoring wells located outside the 

9 construction area (MW-1S, MW-2S, MW-3S, and MW-4S) would continue throughout the 

10 construction, preoperational, and operational phases of the project. In addition, PEF proposes 

11 to install 43 additional monitoring wells during the preoperational phase of the project. 

12 The groundwater monitoring efforts can be grouped by functional intent as follows: reactor area 

13 monitoring to establish background conditions and document changes in the immediate vicinity 

14 of the reactors, peripheral sentinel well monitoring to establish background conditions and 

15 document changes up- and down-gradient of the reactor units, and wellfield sentinel well 

16 monitoring to establish background conditions and document changes due to pumping of raw 

17 water from groundwater aquifers. Water levels in wells surrounding the reactor units would be 

18 monitored using automated pressure transducers to assess the impacts of surface alterations, 

19 drainage ditches, and water-retention ponds. Water levels in peripheral shallow and/or deep 

20 monitoring wells would be monitored monthly using manual water-level indicator measurements. 

21 Water levels in the wellfield sentinel wells would be monitored using automated pressure 

22 transducers to assess wellfield impacts. 

23 Section 6.6 of the ER (PEF 2009a) describes the chemical monitoring program. The objective 

24 of chemical monitoring is to identify changes in water quality that may result from LNP 

25 operations. The chemical monitoring efforts can be grouped by the same functional intent as 

26 that described for the groundwater monitoring effort. Groundwater chemistry would be 

27 monitored quarterly in the four pre-application monitoring wells located outside the construction 

28 area (MW-1S, MW-2S, MW-3S, and MW-4S) and a total of 43 new monitoring wells installed 

29 immediately following construction activities and prior to plant operations. The frequency of 

30 groundwater chemistry monitoring would be monthly for the first year after initiation of plant 

31 operations and quarterly thereafter. The need for modifications to the monitoring program 

32 (e.g., sampling locations and frequency, analyte list, and analytical methods) would be routinely 

33 evaluated throughout the construction and preoperational monitoring programs. Sampling and 

34 analysis requirements for operational monitoring are currently planned to be the same as those 

35 specified for pre-application monitoring in ER Section 2.3.3.2 (PEF 2009a). 
Operational Impacts at the Proposed Site 

Draft NUREG-1941 5-18 August 2010 

1 5.3 Ecology 

2 This section describes the potential impacts on ecological resources from the operation of two 

3 new reactor units at the LNP site, as well as the operation of the associated offsite facilities, 

4 including new transmission lines. The operational impacts for terrestrial and wetland 

5 ecosystems are discussed in Section 5.3.1, and aquatic ecosystems impacts are addressed in 

6 Section 5.3.2. Evaluation of potential impacts on terrestrial and aquatic biota from radiological 

7 sources is discussed in Section 5.9. 

8 5.3.1 Terrestrial and Wetland Impacts Related to Operations 

9 Most impacts on terrestrial habitats and species related to the operation of proposed LNP 

10 Units 1 and 2 are expected to result from cooling-system operations, groundwater pumping, and 

11 the operation and maintenance of the transmission lines. Operation of the cooling system can 

12 result in local deposition of dissolved solids (commonly referred to as salt deposition); increased 

13 local fogging, precipitation, or icing; increased local noise levels; a risk of avian mortality caused 

14 by collision with tall structures; and hydrological changes to habitats adjoining the source 

15 waterbody. Groundwater withdrawals to support other plant operations (no groundwater would 

16 be withdrawn for the cooling system) may affect water levels in wetlands on and around the 

17 LNP site. Increased traffic and night-time lighting associated with operation may affect wildlife. 

18 These operational impacts are discussed further in Section 5.3.1.1. 

19 Operation and maintenance of the transmission system may affect terrestrial species through 

20 collision mortality and electrocution, electromagnetic fields (EMFs), and vegetation maintenance 

21 in transmission-line corridors. Impacts of the transmission lines on terrestrial resources are 

22 discussed in Section 5.3.1.2. The potential effect of these operational impacts on important 

23 species and their habitats, including Federally and State-listed species, is addressed in Section 

24 5.3.1.3. 

25 As described in Chapter 3, the cooling system proposed for LNP Units 1 and 2 includes a series 

26 of mechanical draft cooling towers that would draw makeup water for cooling from the CFBC. 

27 This water would be mostly derived from shallow, nearshore waters of the Gulf of Mexico (PEF 

28 2009a). The heat would be transferred to the atmosphere in the form of water vapor and drift. 

29 Vapor plumes and drift, including salts and other solutes in the drift, have the potential to affect 

30 crops, ornamental vegetation, and native plants. Water withdrawals would increase salinity 

31 levels in the CFBC and thereby alter shoreline habitat along the CFBC, including tidal marshes 

32 near the entrance of the CFBC to the Gulf of Mexico. In addition, bird collisions are possible 

33 with mechanical draft cooling towers and other tall structures, and wildlife can be affected by 

34 noise generated by the operation of cooling towers. 
Operational Impacts at the Proposed Site 

August 2010 5-19 Draft NUREG-1941 

1 Groundwater from water supply wells located immediately south of the LNP site would be used 

2 to meet general plant operations. PEF (2009a) estimates that general facility uses would 

3 require normal daily withdrawal of about 1.58 Mgd of freshwater from the underlying Floridan 

4 aquifer. Since the surficial aquifer that supports local wetlands is hydrologically connected to 

5 the Floridan aquifer system, groundwater withdrawal from the Floridan aquifer system could 

6 affect wetlands on and around the LNP site. 

7 Electric transmission systems have the potential to affect terrestrial ecological resources 

8 through corridor maintenance, bird collisions with transmission lines, and EMFs. Approximately 

9 180 mi of new transmission lines (500 kV and 230 kV) would be required to incorporate power 

10 generated by the LNP into the Florida electric grid system. However, more than 90 percent of 

11 the new transmission lines would be collocated with existing PEF transmission lines (PEF 

12 2009e). 

13 5.3.1.1 Terrestrial Resources – Site and Vicinity 

14 Impacts on the LNP site and vicinity from the proposed operation of two new units are described 

15 in this section. Vapor plumes and drift associated with the operation of two proposed 

16 mechanical draft cooling towers may affect vegetation such as native plant communities, 

17 managed tree farms, crops, and ornamental vegetation. Water-quality changes resulting from 

18 the withdrawal of cooling water from the CFBC could alter shoreline vegetation along the CFBC. 

19 Groundwater pumping to support general plant operations could affect hydrology that supports 

20 nearby wetlands. Bird collisions and noise-related impacts are possible with mechanical draft 

21 cooling towers and other facility structures. Increased traffic and nighttime lights associated 

22 with operation may also affect wildlife populations. 

23 Impacts of Cooling-Tower Operations 

24 Aspects of cooling tower operation recognized as potentially affecting crops, ornamental 

25 vegetation, and native plants include cooling-tower drift, icing, fogging, or increased humidity 

(NRC 1996, 1999a 26 ). No row crop agricultural land exists on or adjacent to the LNP site. 

27 However, forests (including managed and unmanaged forestland) and wetlands occur on and 

28 around the LNP site, and small areas identified as cropland and/or pastureland (FLUCFCS 210) 

29 and low-density residential (FLUCFCS 110) are situated near the LNP site. 

30 A mechanical draft cooling tower associated with each proposed unit would be used to remove 

31 excess heat from the circulating-water system (CWS) by transferring it to the atmosphere. 

32 Through the process of evaporation, total dissolved solids (TDS) in the CWS are concentrated. 

33 A small percentage of the water in the CWS would unavoidably be released into the atmosphere 

 

a

 NUREG-1437 was originally issued in 1996. Addendum 1 to NUREG-1437 was issued in 1999. 

Hereafter, all references to NUREG-1437 include NUREG-1437 and its Addendum 1. 
Operational Impacts at the Proposed Site 

Draft NUREG-1941 5-20 August 2010 

1 as fine droplets (i.e., cooling-tower drift) containing elevated levels of TDS that can be deposited 

2 on nearby vegetation. Drift eliminators to be installed by PEF on the cooling towers are 

3 effective in reducing drift droplets to less than 0.1 percent of the drift loss expected without the 

4 eliminator (Young and Ciammaichella 2008). Operation of the CWS for the proposed LNP 

5 project would be based on 1.5 cycles of concentration, which means the TDS in the makeup 

6 water would be concentrated approximately 1.5 times before being released (PEF 2009e). 

7 CWS water losses from drift are minor in comparison to evaporation and blowdown discharge 

8 losses (PEF 2009a). When both mechanical draft cooling towers are operating under normal 

9 conditions, the maximum drift rate reported by PEF (2009a) for the proposed LNP is estimated 

10 to be 5.32 gpm. 

11 Depending upon the source of makeup water, the TDS concentration in cooling tower drift can 

12 contain high levels of salts that damage exposed vegetation. Vegetation stress can be caused 

13 by drift with high levels of TDS deposition, either directly by deposition onto foliage or indirectly 

14 from the accumulation in soil (NRC 1996, 2000b). Makeup water would be brackish seawater 

15 drawn up the CFBC from shallow nearshore waters of the Gulf of Mexico. The concentration of 

16 TDS in the makeup water is expected to be around 25 ppt under normal operating conditions 

17 (PEF 2009a). PEF modeled the maximum predicted monthly average deposition rates for TDS 

18 using meteorological data from 2001 through 2005 (PEF 2009a). The maximum predicted 

19 onsite deposition during normal plant operation is predicted to be 10.75 kg/ha/mo of total solids, 

20 as determined from the 2004 meteorological data year. Isopleth maps showing modeled salt 

21 deposition in different meteorological data years are available in the ER (PEF 2009a). The 

22 maximum predicted offsite deposition rate would be 6.83 kg/ha/mo of total solids at the property 

23 boundary west of the cooling towers, as determined from the 2002 meteorological data year. 

24 Offsite deposition rates would decrease significantly with increasing distance from the proposed 

25 plant site, approaching one-third of the maximum offsite rate at 3280 ft from the site boundary 

26 (PEF 2009a). 

27 NRC guidance for predicting the effects of salt drift deposition on plants indicates thresholds for 

28 visible leaf damage in the range of 10 to 20 kg/ha/mo during the growing season (NRC 2000a). 

29 A literature review discussing the responses of individual plant species to salt deposition is 

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

31 (NRC 1996). Using a TDS deposition rate of 10 kg/ha/mo as a threshold limit above which 

32 adverse impacts on vegetation could occur, salt-drift modeling suggests that some vegetation 

33 on the LNP site could suffer leaf damage from salt drift in some years. As noted above, the 

34 maximum predicted onsite monthly salt deposition rate was 10.75 kg/ha/mo when modeled 

35 using the 2004 meteorological data year. This slightly exceeds the lower end (10 kg/ha/mo) of 

36 the range of salt deposition rates reported to cause visible leaf injury on vegetation. However, 

37 the maximum predicted onsite deposition rates for the 2001, 2002, 2003 and 2005 

38 meteorological data years were below the threshold limit for leaf damage (PEF 2009e). Highest 

39 monthly average salt deposition rates are predicted to occur between March and September 
Operational Impacts at the Proposed Site 

August 2010 5-21 Draft NUREG-1941 

1 (PEF 2009c). No adverse impacts on vegetation are predicted for lands outside of the LNP site 

2 because the maximum predicted monthly salt deposition rates for the 2001 through 2005 

3 meteorological data years were all below the threshold limit for offsite lands (PEF 2009e). As 

4 noted above, the maximum predicted offsite rate was 6.83 kg/ha/mo for the 2002 meteorological 

5 data year. 

6 Adverse impacts on vegetation from soil salinization are not expected to be an issue on or near 

7 the LNP site because sufficient rainfall would be received to leach salts from the predominantly 

8 sandy soil profile. Average annual precipitation for the region that includes the LNP site is 

9 approximately 53 in./yr (see Section 2.3.1.1 of the EIS); total rainfall recorded over a 1-year 

10 period (February 1, 2007 through January 31, 2008) at the LNP meteorological monitoring 

11 station was 43.0 in. (PEF 2009a). Potential soil salinization problems at energy facilities are 

12 generally limited to arid regions with lower rainfall (NRC 1996). 

13 A variety of factors can influence plant response to salt drift, including species variability, plant 

14 phenology, duration and frequency of exposure, particle size, and chemical composition, as well 

15 as photoperiod, temperature, precipitation, and relative humidity during and after exposure 

16 (Simini and Leone 1982; McCune 1991). Onsite impacts from salt drift during LNP operation 

17 likely would be limited to vegetation close to the cooling towers (within 3280 ft), primarily in an 

18 area encompassing a northeast to southwest diagonal through the proposed cooling towers 

19 (PEF 2009e). This corresponds with the prevailing wind direction observed at the LNP site in 

20 2007, and that recorded at Tampa, Florida (see Section 2.9.1.1 of this EIS). Much of the 

21 vegetation that could be affected by salt drift would be maintained and/or mowed vegetation 

22 around planned facilities. However, forested wetlands (FLUCFCS 617, 621 & 630), and pine 

23 plantation (FLUCFCS 441 & 629), much of which may be restored to native communities under 

24 the wetland mitigation plan (see Section 4.3.1.7), also lie near the proposed cooling towers. 

25 The potential for salt-drift impact on vegetation is expected to be moderated by the frequent 

26 rainfall the LNP site receives for much of the year (see Section 2.9.1.4), which would wash salt 

27 from the leaves and limit the duration of exposure. Precipitation in the region is particularly high 

28 during the summer months (4.3 – 9.8 in., June through September), although averages in other 

29 months usually exceed 2 in. (see Section 2.3.1.1 of the EIS). Considering that the maximum 

30 predicted monthly salt deposition rates for LNP operation did not exceed the threshold above 

31 which vegetation damage is generally noted in 4 of the 5 meteorological data years modeled 

32 (PEF 2009e), and that average precipitation levels range between 3.2 and 9.8 in. during months 

33 when highest deposition is predicted to occur, impact on vegetation from salt drift is expected to 

34 be minor, infrequent, and limited to the LNP site. 

35 Results of a 14-year salt-drift monitoring study completed at the nearby CREC also support a 

36 conclusion that potential impacts on vegetative communities on the LNP site would be minor 

37 (PEF 2009a, e, f, h). CREC shares many of the same plant communities as the LNP site and 

38 vicinity, including coniferous plantations (FLUCFCS 441), wetland swamps (mixed wetland 
Operational Impacts at the Proposed Site 

Draft NUREG-1941 5-22 August 2010 

1 hardwoods – FLUCFCS 617, cypress – FLUCFCS 621, wetland forested mixed – FLUCFCS 

2 630), and freshwater marshes (FLUCFCS 641). As a part of the CREC monitoring, vegetation 

3 was assessed monthly and quarterly for plant damage that could be attributed to salt-induced 

4 injury (e.g., browned leaf curl, marginal or tip necrosis, or shoot dieback). Salt deposition 

5 (sodium and chloride) was measured monthly using modified bulk precipitation collectors and 

6 periodically from samples of standing water. Deposition of salt on plant foliage was periodically 

7 measured, and aerial infrared photography was examined annually within a 1-mi radius of the 

8 CREC cooling towers for evidence of large-scale vegetation changes that could be attributable 

9 to salt-drift effects. Monitoring revealed increased salt deposition at the CREC during some 

10 months, with mean monthly salt concentrations generally encompassing a range (e.g., 1.7 

11 kg/ha/mo to 19.8 kg/ha/mo in 1993 and 1994) (PEF 2009f) that includes the maximum predicted 

12 monthly salt deposition rates modeled for the LNP project. Minor vegetation damage to 

13 individual plants attributed to salt drift (e.g., chlorotic leaves or needles, leaf hypertrophy, tip or 

14 margin damage, or small or deformed leaves) was occasionally observed (PEF 2009e, f, h). 

15 Species common to both the CREC and the LNP site where salt drift damage to individual 

16 plants was noted include red maple, live oak, sweetgum, wax myrtle, Dahoon holly and grape 

17 vine, among several others. Although minor visible leaf damage was observed on individual 

18 plants, broadly visible damage to plant communities was not evident on and around the CREC 

19 that could be attributed to operation of the CREC cooling towers (PEF 2009e). Based on these 

20 findings, FDEP terminated the requirement for salt-drift monitoring at the CREC in 1996 (PEF 

21 2009a, e). 

22 Increased fogging and relative humidity near cooling towers have not been reported to affect 

23 native vegetation (NRC 1996). Ice-induced damage to native vegetation can occur but is rare, 

24 minor, and localized near cooling towers (NRC 1996), even in areas that experience longer and 

25 more frequent freezes than north Florida. Local climatological statistics for Tampa (located 

26 78 mi south of the LNP site) indicate that freezing temperatures occur, on average, about 

27 2 days per year along the west-central coast of Florida, generally in December, January (peak 

28 number), and February (NOAA 2010). Modeling of ground-level fogging and icing for the LNP 

29 site indicates no predicted instances of ground-level fogging or icing beyond 3280 ft from the 

30 nearest cooling-tower bank (PEF 2009a). Although ground-level fogging and icing may extend 

31 off the LNP site, no conservation lands in the site vicinity (e.g., the Goethe State Forest or 

32 Marjorie Harris Carr Cross-Florida Greenway) would be affected. Based on these data, impacts 

33 on surrounding vegetation from increased humidity and ground-level fogging or icing would be 

34 minimal. 

35 A potential exists for cooling tower drift to increase the salinity of surface water in wetlands on 

36 the LNP site. Surface water is seasonally present within cypress domes and other freshwater 

37 swamps and wetlands on the LNP site, with water present year round in portions of some 

38 wetlands in some years. No baseline salinity measurements are available for LNP surface 

39 waters, but based on the dominant vegetation present, these waters are assumed to be fresh 
Operational Impacts at the Proposed Site 

August 2010 5-23 Draft NUREG-1941 

1 (i.e., salinities of less than 1 ppt). Using PEF’s (2009a) maximum onsite salt drift deposition 

2 estimate of 10.75 kg/ha/mo and assuming the deposition is subjected to the lowest mean 

3 monthly precipitation of 1.62 inches as determined for the region (see Section 2.3.1.1), the 

4 review team estimated a conservative runoff salinity concentration of 0.026 ppt during cooling 

5 tower operation. Although evapotranspiration would contribute to the loss of (and thus increase 

6 in potential salt concentrations in) surface waters on the site, abundant precipitation (on the 

7 order of 53 in./yr) in the region would result in a dilution greater than that assumed above, and 

8 therefore the concentration estimated above is conservative. The potential for long-term 

9 concentration of salt in surface waters is expected to be limited by a significantly high exchange 

10 of water between the surface and groundwater systems, which occurs because of the lack of a 

11 confining geologic formation between the aquifer systems at the LNP site (see below and 

12 Section 2.3.1.2 for further discussion on groundwater conditions). Considering the very low 

13 additional contribution to surface water salinity from cooling tower drift and the low likelihood for 

14 substantial concentration of salts in surface waters, cooling tower drift is not expected to impair 

15 freshwater ecosystems on the LNP site. 

16 Impacts on Wetlands from Stormwater Runoff and Groundwater Withdrawal 

17 After site preparation and development are complete, numerous wetlands would remain in 

18 undeveloped areas on the LNP site (Figure 4-2). These wetlands would not be affected by 

19 stormwater runoff from impervious surfaces. Stormwater from the newly developed facilities 

20 would be collected through a stormwater-drainage system and directed into three stormwater21 retention and/or infiltration ponds for treatment rather than into nearby wetlands (PEF 2009a). 

22 Stormwater runoff from roadways would be managed using a series of roadside swales. These 

23 unlined retention/detention facilities would allow for aquifer recharge of stormwater via 

24 infiltration. However, these and other wetlands on surrounding lands could be affected by 

25 groundwater withdrawals to support general facility operations. 

26 Groundwater from water-supply wells located immediately south of the LNP site would be used 

27 to supply general plant operations, including service-water cooling, potable water supply, raw 

28 water to the demineralizer, fire protection, and media filter backwash (PEF 2009a). 

29 Groundwater in this portion of west-central Florida occurs in a surficial aquifer composed of 

30 unconsolidated sediments (primarily sands), and in an underlying carbonate rock aquifer known 

31 as the Floridan aquifer system. No confining geologic formation exists between these aquifer 

32 systems at the LNP site (i.e., they are hydraulically connected), and the surficial aquifer 

33 provides substantial recharge to the Floridan aquifer. The well field site was chosen to reduce 

34 drawdown levels in both the Upper Floridan and surficial aquifers compared to siting wells in 

35 other feasible locations. Although karst terrain (i.e., areas where underlying carbonate rock 

36 near the surface has been subjected to dissolution by downward infiltrating rainfall) is a problem 

37 in many areas of Florida, conditions near the LNP site (e.g., regional transmissivity values; few 

38 sinkholes) do not suggest well developed karst (see Section 2.3.1.2 of the EIS). Nevertheless, 

39 the cypress dome wetlands on site may represent karst development and likely provide for 
Operational Impacts at the Proposed Site 

Draft NUREG-1941 5-24 August 2010 

1 preferential recharge between the surface and groundwater (PEF 2009a). PEF (2009a) 

2 estimates that general facility uses would require normal daily withdrawal of about 1.58 Mgd of 

3 freshwater from the underlying Floridan aquifer. Because the surficial aquifer that supports local 

4 wetlands is hydrologically connected to the Floridan aquifer system in this area, groundwater 

5 withdrawal from the Floridan aquifer system could affect wetlands on and around the LNP site. 

6 Groundwater resources at the LNP are discussed in detail in Section 2.3.1.2. 

7 PEF developed a local-scale groundwater model as a requirement of the facility’s Site 

8 Certification Application to the State of Florida. The model, which is a submodel of the 

9 SWFWMD’s DWRM2 regional groundwater flow model, was used to simulate both LNP and 

10 cumulative groundwater usage (PEF 2009g). Groundwater simulations using the DWRM2 

11 model indicated a potential drawdown impact on the surficial aquifer on the order of 0.4 to 0.5 ft 

12 (4.8 to 6 in.) in areas immediately adjacent to wellheads over 60 years of groundwater pumping 

13 (Figure 5-5). The review team requested that PEF recalibrate the model using site-specific and 

14 regional hydraulic head data to improve the model’s goodness of fit. A detailed description of 

15 this model and the recalibration process is provided by PEF in a response to requests for 

16 additional information (PEF 2009d). Predictive simulations using the recalibrated model indicate 

17 that annual average LNP groundwater usage from the Upper Floridan aquifer would, over 60 

18 years of operation, result in surficial aquifer drawdowns of as much as 2.5 ft in areas near the 

19 wellheads, with a drawdown of 0.5 ft extending up to 3 mi from the wellheads (Figure 5-5). This 

20 groundwater drawdown zone would encompass about half of the LNP site and substantial 

21 offsite areas, including many acres of wetlands. See Sections 2.3.1.2 and 5.2.1 for further detail 

22 about the groundwater models and projected impacts on groundwater resources. 

23 The recalibrated groundwater model for the LNP project predicts increased drawdown to the 

24 surficial aquifer from groundwater pumping over 60 years of operation. A review of the effects 

25 of groundwater drawdown on isolated wetlands in Florida suggests that extended drawdowns 

26 from 0.6 ft to 1 ft can result in substantial changes to vegetation composition and structure, and 

27 that a 1-ft decline can adversely affect seasonally and semi-permanently flooded wetlands 

28 (Mortellaro et al. 1995). Table 5-2 presents a breakdown by FLUCFCS cover classes of 

29 wetlands that lie within groundwater drawdown zones exceeding 0.5-ft. To maintain 

30 consistency, and because of difficulty in rectifying the boundaries for delineated wetlands on the 

31 LNP site with adjacent undelineated wetlands, this analysis is based solely upon SWFWMD 

32 map files dated 2007, and thus represents an index to potential wetland drawdown impacts. 

33 Using the recalibrated groundwater model, up to 2092.9 ac of wetlands could be adversely 

34 affected over 60 years of groundwater pumping to support the LNP project, with 563.4 ac 

35 occurring within groundwater drawdown zones that exceed 1 ft. No wetlands would lie within 

36 groundwater drawdown zones exceeding 0.5-ft under the original DWRM2 model prepared by 

37 PEF. 
August 2010 5-25 Draft NUREG-1941

Operational Impacts at the Proposed Site 1 Figure 5-5. Simulated Groundwater Drawdown from Operational Pumping (1.58 Mgd at Year 60) Relative to 2 Wetlands on the Well-Field Site (original DWRM2 model and the recalibrated model) 3 
Operational Impacts at the Proposed Site 

August 2010 5-26 Draft NUREG-1941 

1 Table 5-2. Potential Wetland Impacts by FLUCFCS Cover Types for Simulated Groundwater 

2 Drawdown (1.58 Mgd at Year 60) Using the Recalibrated Groundwater Model 

Wetland Cover Type 

FLUCFCS 

Code(a)

Surficial Aquifer 

Drawdown Contour Area (acres)(b)

Cypress 621 2 ft+ 6.7 

Wetland Forested Mixed 630 2 ft+ 11.8 

Freshwater Marshes 641 2 ft+ 17.0 

2+ ft Subtotal 35.5 

Cypress 621 1.5 ft to 2 ft 70.2 

Wetland Forested Mixed 630 1.5 ft to 2 ft 63.4 

Freshwater Marshes 641 1.5 ft to 2 ft 18.6 

Wet Prairies 643 1.5 ft to 2 ft 2.6 

1.5 – 2 ft Subtotal 154.8 

Cypress 621 1 ft to 1.5 ft 230.0 

Wetland Forested Mixed 630 1 ft to 1.5 ft 105.1 

Freshwater Marshes 641 1 ft to 1.5 ft 34.1 

Wet Prairies 643 1 ft to 1.5 ft 2.0 

Emergent Aquatic Vegetation 644 1 ft to 1.5 ft 1.9 

1 – 1.5 ft Subtotal 373.1 

Streams and Lake Swamps 

(Bottomland) 

615 0.5 ft to 1 ft 

2.2 

Cypress 621 0.5 ft to 1 ft 710.4 

Wetland Forested Mixed 630 0.5 ft to 1 ft 466.0 

Freshwater Marshes 641 0.5 ft to 1 ft 332.5 

Wet Prairies 643 0.5 ft to 1 ft 7.5 

Emergent Aquatic Vegetation 644 0.5 ft to 1 ft 7.2 

Intermittent Ponds 653 0.5 ft to 1 ft 3.7 

0.5 – 1 ft Subtotal 1529.5 

Total Area 2092.9 

Sources: PEF 2009a; SWFWMD 2007; Overlay of recalibrated groundwater model onto LNP FLUCFCS vicinity map 

(PEF 2009k) prepared by PNNL in April 2010. 

(a) FLUCFCS = Florida Land Use, Cover and Forms Classification System (FDOT 1999). 

(b) For consistency and because of difficulty in rectifying the boundaries of LNP-delineated wetlands with adjacent 

undelineated wetlands, potential wetland drawdown impacts are based upon FLUCFCS cover classes as derived 

solely from SWFWMD (2007) mapping. 

3 Groundwater models provide an objective means of predicting the effects of water withdrawal 

4 on groundwater resources, which, in turn, can be used to infer potential wetland impacts from 
Operational Impacts at the Proposed Site 

August 2010 5-27 Draft NUREG-1941 

1 groundwater pumping. Nevertheless, groundwater models are subject to many limitations and 

2 their results should be viewed with a degree of uncertainty. For example, the uncertainty in 

3 hydraulic property values at the proposed LNP wellfield demonstrates how differences in model 

4 values can substantially influence the assessment of wetlands impacts (i.e., the original Levy 

5 DWRM2 groundwater model compared to the recalibrated groundwater model). 

6 Because of this uncertainty, and to ensure that the proposed use of groundwater for the LNP 

7 project does not cause adverse impacts on wetlands and surface waters, the State of Florida 

8 imposed the following conditions in the final site certification issued under the PPSA (FDEP 

9 (2010), to which PEF has committed: 

10 Aquifer Performance Testing (APT) Plan that includes hydraulic testing during drilling and 

11 construction of the proposed water-supply wells to obtain site-specific hydraulic property 

12 estimates and determine whether the wellfield can meet groundwater usage impacts without 

13 significantly affecting water levels in the surficial aquifer. 

14 Alternative Water Supply Plan to investigate the feasibility of developing alternative water 

15 supply projects to offset groundwater use. 

16 Environmental Monitoring Plan (based on the SWFWMD Wetland Assessment Procedure) 

17 to assess the relative biological and physical condition of surface waters and wetlands in 

18 areas potentially affected by groundwater withdrawals. 

19 In accordance with SWFWMD’s review criteria, groundwater withdrawal cannot cause 

20 unacceptable adverse impacts on wetlands or other surface waters. The SWFWMD 

21 performance review standards applicable to the Environmental Monitoring Plan, upon which 

22 potential impacts on wetlands would be judged, include the following (as summarized from PEF 

23 2009h): 

24 Wet season water levels shall not deviate from their normal range; 

25 Wetland hydroperiods shall not deviate from their normal range and duration to the extent 

26 that wetlands plant species composition and community zonation are adversely affected; 

27 Wetland habitat functions, such as providing cover, breeding, and feeding areas for obligate 

28 and facultative wetland animals, shall be temporally and spatially maintained and not 

29 adversely affected as a result of withdrawals; and 

30 Habitat for threatened or endangered species shall not be altered to the extent that use by 

31 those species is impaired. 

32 Considering the uncertainty associated with existing groundwater modeling for the LNP site, 

33 operational impacts from groundwater withdrawal to wetlands on and around the LNP site could 

34 affect the hydrological and hence ecological properties of wetlands within a localized area (see 

35 Table 5-2 and Figure 5-5). However, if adverse environmental impacts on wetlands and surface 
Operational Impacts at the Proposed Site 

August 2010 5-28 Draft NUREG-1941 

1 waters are predicted or detected through wellfield APT, revised groundwater modeling, or 

2 environmental monitoring of wetlands, PEF would be required either to mitigate the adverse 

3 impacts or implement an approved alternative water-supply project (FDEP 2010). 

4 If PEF chooses to address any wetland impacts from groundwater withdrawal by mitigation 

5 rather than implementing an alternative water-supply project, it is unlikely that these hydrological 

6 alterations would contribute to an increased risk of wildfire in the LNP vicinity. Groundwater 

7 drawdown exceeding 0.5 ft that could adversely affect wetlands would be localized, and limited 

8 to a total area (upland as well as wetland) of about 7344 ac based upon the recalibrated 

9 groundwater model (Figure 5-5). Furthermore, the fire risk in parts of the surrounding area 

10 would be reduced through the restoration of a more natural fire regime, as proposed under the 

11 wetland mitigation plan for the LNP project (Entrix 2010). These controlled burns would act to 

12 reduce fuel loads in upland and wetland areas on and around the LNP site. If wildfires 

13 unexpectedly occur around the LNP project, rapid fire response would be expected, drawing 

14 from both onsite (LNP) and offsite fire-protection resources. 

15 Bird Collisions with Cooling Towers and Structures 

16 Avian mortality can result from collision with tall structures at nuclear power plants. Typically, 

17 the cooling tower and meteorological tower are the structures posing the greatest risk (NRC 

18 1996). Two banks of mechanical draft cooling towers (each 1190 ft long, 97 ft wide, and 56 ft 

19 high) are proposed for the LNP, one for each generating unit (LNP Units 1 and 2) (PEF 2009a). 

20 With a height of only 56 ft, bird collision mortality would be substantially less likely than with the 

21 natural draft cooling towers present at many other power plant sites that can approach 500 ft in 

22 height. It is also possible that noise generated by the cooling towers may act to limit the 

23 potential for avian collision with these structures. In a review of bird collisions with cooling 

24 towers at nuclear plants, the NRC (1996) determined that avian mortality was negligible for 

25 mechanical draft cooling towers. The meteorological tower, a 198-ft high guyed, open lattice 

26 structure (PEF 2009a), could also represent a low-risk collision hazard for birds. The 

27 meteorological tower is located about 0.9 mi west-southwest of the proposed locations of LNP 

28 Units 1 and 2 and has been in operation since February 2007. Data available for 

29 communication towers indicate that tall towers more than 1000 ft in height pose the greatest 

30 collision risk for birds (Manville 2005). Published accounts of bird strikes and kills at shorter 

31 towers are limited, but assumed to occur less frequently. At 225 ft in height, the containment 

32 buildings represent the tallest structures proposed for the LNP site (PEF 2009a) and may 

33 constitute a low-risk collision hazard for birds. 

34 Even if collisions occur with LNP structures, thriving bird populations can usually withstand the 

35 losses without threat to their existence (EPRI 1993). The NRC has previously concluded that 

36 avian collisions are unlikely to pose a biologically significant source of mortality because only a 

37 small fraction of total bird mortality has been attributed to collision with nuclear power plant 

38 structures (NRC 1996). Therefore, mortality from birds colliding with structures, including the 
Operational Impacts at the Proposed Site 

August 2010 5-29 Draft NUREG-1941 

1 cooling towers, containment buildings, and the meteorological tower, is expected to be 

2 undetectable at a population level for common bird species. Impacts on populations of less 

3 common bird species however, may be more substantial. Nonetheless, because none of the 

4 potentially affected bird species are endemic to the LNP vicinity, it is unlikely that the collision 

5 impacts would pose a risk to the overall survival of any avian species, including the less 

6 common species. 

7 Bat mortality from collisions with LNP structures, such as the cooling towers, containment 

8 buildings, and the meteorological tower, is also expected to be undetectable at a population 

9 level. Except for bat mortality associated with wind turbines at wind energy facilities, bat 

10 collisions with tall man-made structures are rarely reported (Cryan and Barclay 2009; Erickson 

11 et al. 2002; Evans-Ogden 1996). 

12 Noise Impacts of Operation 

13 The dominant sources of noise likely to affect wildlife during normal operation of the proposed 

14 LNP would be the mechanical draft cooling towers and the main transformers. Other plant 

15 equipment capable of generating relatively high noise levels would be located within buildings or 

16 noise-attenuating structures. Outdoor noise levels on the LNP site are predicted to range from 

17 90 dBA near the loudest equipment to 65 dBA in areas more distant from major noise sources 

18 (CH2M Hill 2008). Noise modeling predicts no perceptible, or perhaps very slight increases in 

19 noise from LNP operations at the site boundary (CH2M Hill 2008). Except in areas immediately 

20 adjacent to major noise sources, expected noise levels would be below the 80- to 85-dB 

21 threshold at which birds and red foxes (a surrogate for small and medium-sized mammals) are 

22 startled or frightened (Golden et al. 1980). Large expanses of available habitat would remain on 

23 and around the LNP site into which mobile wildlife species could seek refuge if disturbed. Some 

24 resident wildlife could be expected to habituate to higher noise levels that typically produce 

25 startle responses. 

26 Wildlife may also be affected by noise “masking” important sounds to which the animal would 

27 typically react if heard (e.g., the approach of a predator). Noise masking is, perhaps, a more 

28 serious concern than sounds that induce a behavioral (startle) response and cause the animal 

29 to flee from the sound source (Dooling 2002). Some level of noise masking is likely to occur on 

30 the LNP site, particularly at frequencies above 2 or 3 kHz. The loss of individuals due to this 

31 phenomenon would be localized and should have minimal impact on overall population health. 

32 Noise from plant operation would be partially attenuated by surrounding forest cover, and noise 

33 impacts off the LNP site are expected to be minimal to negligible. 

34 CFBC Shoreline Habitat

35 Water pumped from the CFBC would be used as makeup water to replenish water lost by the 

36 LNP CWS to evaporation, blowdown, and drift. The LNP makeup-water pump house would be 
Operational Impacts at the Proposed Site 

August 2010 5-30 Draft NUREG-1941 

1 located approximately 6.9 mi from the Gulf of Mexico on the north side of the CFBC. Because 

2 the Gulf of Mexico essentially represents an unlimited source of water even during drought 

3 conditions, withdrawal is predicted to have a negligible effect on water levels in the CFBC (PEF 

4 2009a). However, it is anticipated that higher-salinity water from the estuarine portions of the 

5 nearshore Gulf of Mexico would be slowly drawn up the CFBC toward the intake structure 

6 during operations. These water-quality changes could result in minor changes to shoreline 

7 vegetation along the CFBC, perhaps causing establishment of brackish water vegetation in 

8 some areas presently supporting freshwater vegetation. 

9 The review team examined shoreline vegetation along the CFBC in December 2008 as part of 

10 the site audit for the LNP project. Currently, emergent vegetation is sparse along the excavated 

11 rocky shoreline of the CFBC upstream (east) of the U.S. Highway 19 (US-19) bridge. 

12 Downstream (west) from the bridge where the rocky shoreline is less pronounced, cordgrass 

13 (Spartina spp.) and other salt-marsh species slowly increase in density toward the Gulf of 

14 Mexico. The projected increase in salinity during operation could expand the distribution and 

15 density of salt-marsh species such as cordgrasses within the narrow emergent zone of the 

16 CFBC. The salinity increases within the CFBC should have no effect on upland vegetation 

17 growing on the slopes above the CFBC channel because the CFBC does not serve as a source 

18 of water for these species. Consequently, the potential effects on terrestrial habitats from the 

19 withdrawal of water from the CFBC would be negligible. 

20 The CFBC provides foraging habitat for many species of birds, including bald eagles, ospreys, 

21 herons, gulls, and waterfowl, as well as resting habitat for waterfowl and other water birds. 

22 Sampling in the upper reach of the CFBC near the proposed cooling-water intake structure 

23 (CWIS) has revealed a biologically depauperate environment with relatively poor water quality 

24 (PEF 2009a). However, once the CWIS is operational, the upper reach near the intake would 

25 experience increased salinity concentrations and dissolved oxygen levels. The resulting overall 

26 improvement in water quality due to increased dissolved oxygen levels may support a greater 

27 diversity and abundance of marine and estuarine aquatic life including benthic invertebrates, 

28 fish, and crustaceans that serve as food sources for wildlife (PEF 2009a). These improvements 

29 in water quality and biodiversity may possibly be beneficial to wildlife that forages in the upper 

30 reach of the CFBC. 

31 Impacts of Increased Vehicle Traffic 

32 Increased traffic associated with operation of proposed LNP Units 1 and 2 may result in 

33 increased wildlife mortality from vehicle-wildlife collisions. An estimated 773 workers employed 

34 to operate proposed Units 1 and 2 would access the site the first year both units are operational 

35 (PEF 2009a). During periodic refueling outages planned for every 18 months, an additional 800 

36 workers would be onsite for about 25 to 30 days (Kimley-Horn 2009). The operations workforce 

37 would access the site primarily via US-19, a four-lane divided highway. The additional traffic on 

38 highways and rural roads in the project vicinity would contribute to an incremental increase in 
Operational Impacts at the Proposed Site 

August 2010 5-31 Draft NUREG-1941 

1 traffic-related wildlife mortalities. Local wildlife populations could suffer declines if road-kill rates 

2 were to exceed the rates of reproduction and immigration. Although road-kills occur frequently, 

3 they generally have minimal impact on most wildlife populations (Forman and Alexander 1998). 

4 Consequently, the review team concludes that these impacts would not be detectable beyond 

5 the local vicinity and would not destabilize regional wildlife populations. 

6 Light Pollution During Facility Operation 

7 Light pollution during facility operation could affect wildlife residing on or migrating through the 

8 LNP site. Research has shown that artificial nighttime lighting can alter behaviors, foraging 

9 areas, and breeding cycles of a wide variety of wildlife, including insects, turtles, frogs, birds, 

10 and bats (Chepesuik 2009). The behavior of night-migrating songbirds can be disrupted by 

11 nighttime lighting systems, particularly during inclement weather. Night-migrating birds navigate 

12 using a combination of light from the moon and stars, as well as geomagnetic signals from the 

13 earth (Able 1980). Light pollution can obscure these natural visual cues, and red light 

14 commonly used on towers and other tall structures may interfere with the birds’ abilities to track 

15 geomagnetic cues. Possible mitigation measures could include the use of lower-wattage lights, 

16 hooded or down-turned lights, and turning unnecessary lights off at night to minimize potential 

17 impacts on wildlife. If appropriate mitigation measures are taken, the impacts from light 

18 pollution on wildlife would be expected to be minimal. 

19 5.3.1.2 Terrestrial Resources – Associated Offsite Facilities 

20 Approximately 180 mi of new transmission lines spanning 148 mi of corridor (multiple lines in 

21 some corridors) would be required to incorporate the power generated by the proposed LNP 

22 project into the Florida electrical grid system (Golder Associates 2008; CH2M Hill 2009a). PEF 

23 expects to acquire a 220-ft-wide right-of-way for the proposed 500-kV transmission lines and a 

24 100-ft-wide right-of-way for the proposed 230-kV transmission lines. More than 90 percent of 

25 the new transmission lines proposed for the LNP project would be collocated with existing PEF 

26 transmission lines (PEF 2009e). Site-preparation and site-development impacts on terrestrial 

27 resources resulting from this action are discussed in Section 4.3 of the EIS. Impacts related to 

28 maintenance and operation of the new transmission lines are discussed as follows. Unless 

29 specifically noted, these operational impacts would be similar for transmission lines up to the 

30 first substations and lines extending beyond the first substations. 

31 Impacts from Transmission-Line Maintenance 

32 The primary transmission-line corridor maintenance activity that may affect terrestrial resources 

33 is vegetation control. Transmission-line rights-of-way must be kept clear of woody growth 

34 through maintenance practices that prevent it from becoming a safety hazard or potentially 

35 interrupting service. The collocation of new transmission lines with existing PEF lines would 

36 minimize the area of new land that would need to be cleared of vegetation and subsequently 
Operational Impacts at the Proposed Site 

August 2010 5-32 Draft NUREG-1941 

1 maintained for the proposed LNP project. In areas where new corridors are required to 

2 accommodate the transmission lines, established maintenance procedures for power 

3 transmission systems would be followed to control vegetation, with a goal of maintaining a 

4 sustainable groundcover of low-growing, non-woody species (PEF 2009f). The vegetation 

5 management practices within rights-of-way owned by PEF are summarized from Golder 

6 Associates (2008) and PEF (2009a, f). These management practices may differ on rights-of7 way where PEF is granted an easement by the landowner. 

8 Maintenance needs within transmission-line corridors would be identified using regular ground 

9 patrols and periodic helicopter overflights. Vegetation maintenance within the corridors would 

10 include mechanical and chemical control methods appropriate for the location, terrain, and 

11 vegetation or habitat present. Mechanical methods of vegetation control may consist of hand 

12 clearing, mowing, pruning, and tree removal. Pruning would be performed along corridor edges 

13 to remove any overhanging branches in the right-of-way. Danger trees (any dead, diseased, 

14 damaged, or leaning trees that could interfere with or endanger the transmission lines and 

15 related facilities) would be removed on an as-needed basis. Chemical methods of vegetation 

16 control include the use of herbicides registered by the EPA and approved by the State of 

17 Florida. Herbicide use would be in accordance with manufacturer specifications and carried out 

18 by licensed applicators. 

19 Vegetation management within wetlands would follow the same restrictive vegetation-clearing 

20 practices described in Section 4.3.1.2. These practices include hand clearing with chain saws 

21 or use of low-ground pressure shear or rotary machines to reduce soil compaction and limit 

22 vegetation damage. Vegetation management within wetlands under transmission lines would 

23 be intended to encourage herbaceous and low-growing woody vegetation that does not exceed 

24 12 ft in height at maturity. Whenever maintenance is required in wetlands and other 

25 environmentally sensitive areas not served by access roads or fill pads, temporary matting 

26 would be used as necessary to minimize damage to wetland soils. 

27 These vegetation-maintenance practices could result in mortality to less mobile animals, such 

28 as reptiles, amphibians, and small mammals that are unable to escape mowers, vehicles, and 

29 other equipment. If vegetation maintenance occurs during the spring and/or early summer 

30 nesting period, ground-nesting bird nests could be disturbed or damaged. Noise and human 

31 presence may temporarily displace wildlife from the corridors until disturbing activities are 

32 completed. In general, these impacts are considered to be minor. Maintenance of early 

33 successional habitat and habitat edge (i.e., forest and/or clearing interface environments) within 

34 transmission-line corridors would be beneficial to wildlife favoring these habitats. Species 

35 expected to benefit include the white-tailed deer (Odocoileus virginianus), eastern cottontail 

36 rabbit (Sylvilagus floridanus), red-tailed hawk (Buteo jamaicensis), northern bobwhite (Colinus 

37 virginianus), northern cardinal (Cardinalis cardinalis), eastern meadowlark (Sturnella magna), 

38 and the gopher tortoise (Gopherus polyphemus), among others. The brown-headed cowbird 
Operational Impacts at the Proposed Site 

August 2010 5-33 Draft NUREG-1941 

1 (Molothrus ater), a bird species that thrives along forest edges and parasitizes songbird nests 

2 (Cornell 2008), may also increase its presence due to corridor maintenance. This could lead to 

3 a decline in reproductive success of host songbird populations on and around the corridors. 

4 Typical line-maintenance operations that could affect terrestrial resources may include insulator 

5 replacements, conductor repairs, shield wire repairs, grounding, and other activities associated 

6 with structures, conductors, and foundations (PEF 2009a, Golder Associates 2008). Noise and 

7 disturbance associated with these activities could result in minor, temporary impacts on wildlife 

8 near the transmission-line corridors. Only vehicular traffic necessary for routine PEF 

9 maintenance activities would be allowed within the corridors (PEF 2009a). Locked gates would 

10 be provided where transmission-line access roads intersect fenced property. 

11 The impact of transmission-line corridor maintenance on wildlife and habitats, including 

12 wetlands, was evaluated by the NRC and found to be of small significance at operating nuclear 

13 power plants with associated transmission-line corridors of variable widths (NRC 1996). PEF 

14 would limit the extent of new transmission-line corridors requiring maintenance through 

15 collocation with existing corridors and has procedures in place that would minimize adverse 

16 impacts on wildlife and wetlands. Consequently, the review team concludes that potential 

17 effects on terrestrial ecology from maintenance practices within the new transmission-line 

18 corridors would be minor, and mitigation beyond the use of standard BMPs and the 

19 implementation of the wetland mitigation plan (see Section 4.3.1.7) would not be warranted. 

20 Avian Mortality Impacts from Power Transmission 

21 Transmission-line structures, conductors, and guy wires pose a potential avian collision hazard 

22 for resident birds that live in the vicinity of the transmission lines and for migratory birds that 

23 may pass through these areas. A branch of the Eastern Atlantic Flyway that crosses Florida 

24 intercepts portions of the proposed transmission lines (FWS 2010, Birdnatuare.com 2009). 

25 Potential LNP transmission-line structures include single steel pole or tubular steel H-frame 

26 designs supported on engineered foundations. Typical structure heights range from 60 to 195 ft 

27 with typical span lengths between structures of 300 to 1500 ft (PEF 2009a; Golder Associates 

28 2008). The transmission structures normally carry a single circuit line consisting of three 

29 phases of triple-bundled aluminum conductors, steel reinforced, and two shield wires. Phase 

30 spacing is typically 34 ft. Because these higher voltage transmission structures require longer 

31 insulator strings and greater conductor clearances, avian electrocutions rarely occur (Harness 

32 1996). 

33 Transmission-line strikes are one of many human-caused sources of avian mortality in the 

34 United States (FWS 2002). Generally, collision mortality appears to represent only a small 

35 fraction of total avian mortality, and the NRC (1996) has concluded that bird collisions with 

36 transmission lines at existing U.S. nuclear power plants are of small significance, including 

37 transmission-line corridors with variable numbers of transmission lines. Because more than 
Operational Impacts at the Proposed Site 

August 2010 5-34 Draft NUREG-1941 

1 90 percent of the new transmission lines proposed for the LNP project would be collocated with 

2 existing PEF transmission lines, either immediately adjacent to existing rights-of-way or within 

3 existing rights-of-way, few new rights-of-way would present new hazards for bird collisions. The 

4 greatest risk for avian collision is likely to occur for heavy, less agile birds, such as waterfowl 

5 and large wading birds (NRC 1996). The greatest concentrations of waterfowl and wading birds 

6 are expected to occur near streams, large lakes, wetlands, and known roost sites. New 

7 transmission lines near Lake Rousseau and crossing the CFBC and the remnant reach of the 

8 Withlacoochee River could pose a higher risk potential for these species. Raptors, such as red9 shouldered hawks (Buteo lineatus) and red-tailed hawks, have the potential to occur along most 

10 portions of transmission lines, where they would likely hunt for prey. Osprey (Pandion 

11 haliaetus) and bald eagles (Haliaeetus leucocephalus) are prevalent near the coast and around 

12 most large waterbodies that provide a reliable source of fish as prey. These large raptors may 

13 also be susceptible to collision hazards, particularly juvenile raptors that have recently fledged. 

14 A condition of certification by the FDEP (2010) would require PEF to prepare an Avian 

15 Protection Plan in coordination with the Florida Fish and Wildlife Conservation Commission 

16 (FFWCC) and the U.S. Fish and Wildlife Service (FWS). The plan would seek to reduce the 

17 operational risk to birds posed by the LNP transmission lines and other electric utility facilities, 

18 with the goal of reducing avian mortality. The specific mitigation measures to be included in the 

19 plan would be developed concurrently with final design of the transmission lines and siting of the 

20 structure locations. Pursuant to PPSA, the final rights-of-way for the transmission lines are 

21 determined through a post-certification process. 

22 The addition of new transmission lines and corridors may lead to an incremental increase in 

23 number of bird collisions during LNP operation. However, it would not be expected to cause a 

24 measurable reduction in bird populations. Consequently, the review team concludes that 

25 potential for impacts on birds due to collision with transmission lines for the proposed LNP 

26 project would be minimal, and additional mitigation beyond the Avian Protection Plan would not 

27 be warranted. 

28 Impacts of Electromagnetic Fields on Flora and Fauna 

29 EMFs are unlike many other agents that have an adverse impact (e.g., toxic chemicals, ionizing 

30 radiation) in that dramatic acute effects cannot be demonstrated and long-term effects, if they 

31 exist, are subtle (NRC 1996). As discussed in the Generic Environmental Impact Statement 

32 (GEIS) for license renewal (NRC 1996), a careful review of biological and physical studies of 

33 EMFs did not reveal consistent evidence linking harmful effects with field exposures. Operating 

34 power transmission lines in the United States produce EMFs of nonionizing radiation at 60 Hz, 

35 which is considered to be an extremely low frequency (ELF) EMF. The transmission lines 

36 connected to the proposed reactors would be 500 kV and 230 kV. The EMFs produced by 

37 operating transmission lines up to 1100 kV have not been reported to have any biologically or 

38 economically significant impacts on plants, wildlife, agricultural crops, or livestock (Lee et al. 
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1 1989; Miller 1983). Minor damage to plant foliage and buds can occur near strong electric 

2 fields, caused by heating of the leaf tips and margins. Damage does not appear within the main 

3 stem and root systems of the plants and would not significantly affect growth (NRC 1996). 

4 The conclusion presented in the GEIS for license renewal (NRC 1996) was that the impacts of 

5 EMFs on terrestrial flora and fauna were of minimal significance at operating nuclear power 

6 plants, including transmission systems with variable numbers of transmission lines. Since 1997, 

7 more than a dozen studies have been published examining cancer in animals exposed to EMFs 

8 for all or most of their lives (Moulder 2003). These studies have found no evidence that EMFs 

9 cause any specific types of cancer in rats or mice (Moulder 2003). Therefore, the review team 

10 concludes that the increased EMF impact on fauna posed by the operation of new 500-kV and 

11 230-kV transmission lines proposed for the LNP project would be negligible, and additional 

12 mitigation would not be warranted. 

13 5.3.1.3 Impacts on Important Terrestrial Species and Habitats 

14 This section describes the potential impacts on important terrestrial species, as defined by NRC 

15 in NUREG 1555 (NRC 2000a), including Federally listed or proposed threatened and 

16 endangered species; State-listed species; and other ecologically important species and habitats 

17 resulting from operation of the proposed LNP and associated offsite facilities, including 

18 transmission lines. No designated or proposed critical habitat for Federally listed terrestrial 

19 species occurs in counties supporting the LNP site or corridors for the associated offsite 

20 facilities. Unless specifically noted, operational impacts on important terrestrial species 

21 described for the associated offsite facilities would be similar for transmission lines up to and 

22 including lines extending beyond the first substations. 

23 Federally and State-Listed Terrestrial Species 

24 LNP Site

25 As many as 16 Federal and/or State-listed animals at times may occur on the LNP site (Table 2-

26 8). Based on wildlife reconnaissance surveys, life-history information, known threatened and 

27 endangered species locations, and information provided by PEF in its ER and responses to 

28 Requests for Additional Information (RAIs), only very limited use of the LNP site is expected by 

29 Federally and State-listed terrestrial species. Species known to use wetland habitats (e.g., 

30 American alligator [Alligator mississippiensis], wood stork [Mycteria americana], State-listed 

31 wading birds, and Florida black bear [Ursus americanus floridanus]) have been noted or are 

32 suspected to use the site occasionally. The State-listed gopher tortoise is documented for the 

33 site, and species commensal with the gopher tortoise (Florida gopher frog [Rana capito], Florida 

34 mouse [Podomys floridanus], eastern indigo snake [Drymarchon corais couperi], and Florida 

35 pine snake [Pituophis melanoleucus mugitus]) may occur there as well. Prior conversion of 

36 upland habitats to pine plantation has degraded habitat for species associated with mature 
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1 forest (red-cockaded woodpecker [Picoides borealis]) and native xeric uplands (e.g., Florida 

2 scrub jay [Aphelocoma coerulescens], Sherman’s fox squirrel [Sciurus niger shermani], and 

3 Florida burrowing owl [Athene cunicularia floridana]), but these species are known from the 

4 project vicinity. A condition of State certification by the FDEP (2010) would require protocol 

5 surveys for all State-listed species that may occur on the LNP site prior to land “clearing and 

6 construction”. This would provide more clarity on use of the LNP site by these species. 

7 Impacts on Federally and State-listed species from operation of the proposed LNP are expected 

8 to be relatively minor. The likelihood of avian collision with the mechanical draft cooling towers 

9 and other tall structures is expected to be minimal. Cooling-tower drift, fogging, and icing are 

10 expected to have little impact on habitats and should not affect listed species. Increased noise 

11 levels near the cooling towers, as well as increased human activity and traffic, may cause these 

12 wildlife species to avoid habitats immediately adjacent to proposed LNP Units 1 and 2. 

13 However, some level of habituation to these disturbances would likely occur. If permanent 

14 displacement of listed wildlife into adjacent habitats occurred, competition for finite resources 

15 could result in small declines in the local populations. Expected improvements to water quality 

16 and biodiversity in the upper reach of the CFBC would likely be beneficial to state listed wading 

17 birds that may forage there. Restoration and enhancement of several hundred acres of low18 ecological-value pine plantations are proposed under the wetland mitigation plan for the LNP 

19 project (see Section 4.3.1.7). As explained in Section 4.3.1.7, commercial forest management 

20 would cease over parts of the site and many pine plantations and other disturbed habitats would 

21 be restored to plant communities functionally similar to native upland and wetland habitats that 

22 were present prior to logging. These actions are expected to be highly beneficial to most listed 

23 wildlife affected by the proposed LNP and could provide compensation for many potential 

24 impacts realized from operation of the LNP and associated offsite facilities. Consequently, 

25 operational impacts on Federally and State-listed species are expected to be minor. 

26 PEF would be required to comply with all applicable laws, regulations, and permitting 

27 requirements and would use good engineering practices to minimize potential impacts on listed 

28 species. If operational impacts on state-listed wildlife cannot be avoided, the applicant would be 

29 required to coordinate with the FFWCC on the need for appropriate mitigation as stipulated 

30 under the FDEP (2010) conditions of certification. A biological assessment has been prepared 

31 by the review team to address impacts on Federally listed species that may use the LNP site. 

32 The biological assessment is provided in Appendix F. PEF would be obligated to implement 

33 any mitigation required through this process. 

34 No Federally listed plant species are known to occur in Levy County (Table 2-8). Consequently, 

35 it is unlikely that Federally listed plants would be affected by operation of facilities on the LNP 

36 site. As many as 49 State-listed plants could possibly occur on the LNP site, based upon 

37 distribution records and habitat preferences. Florida law does not regulate the removal of State38 listed plants for development or other land alterations on privately owned land. Furthermore, 
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1 the LNP project would be exempt from restrictions on native flora disturbances during clearing 

2 under (8)(c) of Florida Statutes 581.185 (Hildebrandt 2010). No targeted surveys for individual 

3 State-listed plants have been conducted on the LNP site. However, extensive pedestrian 

4 surveys were conducted by biologists between September 2006 and November 2008, in 

5 conjunction with habitat mapping and wetland delineation efforts (PEF 2009g). No State-listed 

6 plants were observed during these surveys (PEF 2009a). Decades of forest management have 

7 reduced habitat suitability for State-listed plant species on the LNP site, especially those 

8 species found on native upland habitats. In the unlikely event that State-listed plants are 

9 present, drift, fogging, and icing resulting from cooling-tower operation could have an adverse 

10 but minimal impact. However, restoration and enhancement of several hundred acres of low11 value pine plantations and degraded wetlands as proposed under the wetland mitigation plan for 

12 the LNP project may provide improved habitat conditions for many State-listed plants. 

13 Listed species that use wetland habitats on the LNP site could be affected by hydrological 

14 impacts on wetlands caused by groundwater withdrawal. Although the extent of potential 

15 impacts is uncertain, monitoring to identify adverse environmental impacts caused by 

16 groundwater withdrawal is stipulated under the State-imposed conditions of certification (FDEP 

17 2010). PEF would be required to mitigate the adverse impacts or implement an approved 

18 alternative water-supply project that would not impact wetlands (FDEP 2010). 

19 Associated Offsite Facilities

20 As many as 32 Federal and/or State-listed animals at times may occur on or near the 

21 associated offsite facilities, including transmission lines (Table 2-8). Limited reconnaissance 

22 surveys (PEF 2009a, e; Golder Associates 2008) and Florida Natural Areas Inventory (FNAI) 

23 (PEF 2008a) and FFWCC (2009a) database searches of the corridors have verified the 

24 presence of listed species, such as Florida scrub jays, eastern indigo snakes, gopher tortoises, 

25 American alligators, Sherman’s fox squirrels, wood storks, and State-listed wading birds, and 

26 potentially suitable habitat was identified for other listed species. A condition of certification by 

27 the FDEP (2010) would require protocol surveys for all State-listed animals that may occur 

28 along the final rights-of-way for linear facilities before land clearing begins. These surveys 

29 would provide more clarity on use of the associated offsite facilities by Federally and State-listed 

30 species. 

31 Federally and State-listed animals that occupy the associated offsite facilities would be subject 

32 to many of the same impacts described in Section 5.3.1.2. Periodic vegetation control along the 

33 transmission lines represents the operational activity with the most potential to affect listed 

34 species. Noise, equipment, and human presence during occasional maintenance activities 

35 would constitute an infrequent, but reoccurring, impact on these species. Highly mobile animals 

36 should be able to disperse or seek cover when disturbing activities occur. However, more 

37 sedentary animals, such the gopher tortoise and juvenile birds, could be susceptible to injury or 

38 mortality if active during mowing and other vegetation-clearing activities. Periodic mowing of the 
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August 2010 5-38 Draft NUREG-1941 

1 upland portions of the corridors would maintain these areas in an early successional state that 

2 should benefit species known to favor herbaceous habitats or forest edges, such as the gopher 

3 tortoise, Sherman’s fox squirrel, and Florida burrowing owl. Maintenance of wetlands in an 

4 emergent and scrub-shrub state could benefit some State-listed wading birds by retaining open, 

5 shallow water habitat preferred for feeding. However, transmission-line structures, conductors, 

6 and guy wires all pose a potential collision hazard for listed birds that occupy or cross the 

7 transmission-line corridors. The Avian Protection Plan PEF is required to prepare as a condition 

8 of State certification by the FDEP (2010) would help minimize the potential for avian 

9 transmission-line mortality. Studies reviewed by NRC (1996) on the impacts of EMFs on 

10 terrestrial resources indicate the proposed 500-kV and 230-kV transmission lines should pose 

11 no adverse impact on Federally and State-listed species that use the transmission-line 

12 corridors. 

13 Based on distribution records and habitat preferences, as many as 76 listed plant species 

14 (13 Federally listed and 76 State-listed) may occur within corridors that would support the 

15 associated offsite facilities, which include up to 180 mi of transmission lines (Table 2-8). Limited 

16 reconnaissance surveys (PEF 2009a, e; Golder Associates 2008) and PEF (2008a) and 

17 FFWCC (2009a) database searches of these corridors have documented the presence of four 

18 listed plants: pinewood dainties (Phyllanthus leibmannianus) (state endangered), coastal mock 

19 vervain (Glandularia maritime) (state endangered), longspurred mint (Dicerandra cornutissima)

20 (federal and state endangered), and giant orchid (Pteroglossaspis ecristata) (state threatened), 

21 and other listed species could be present. Initial land clearing for the final rights-of-way could 

22 affect many existing plant populations (see Section 4.3.1.3), but the low-growing non-woody 

23 vegetation created could favor establishment of other listed plant species. Any listed plant 

24 populations that persist or newly establish within the final rights-of-way could be disturbed by 

25 vegetation maintenance (previously described in Section 5.3.1.2) designed to sustain a 

26 groundcover of low-growing, non-woody species. 

27 The collocation of more than 90 percent of the new transmission lines with existing PEF lines 

28 (PEF 2009g) would greatly minimize the extent of operational impacts resulting from the LNP 

29 project. If operational impacts on state listed species cannot be avoided, the applicant would be 

30 required to coordinate with the FFWCC on the need for appropriate mitigation under the FDEP 

31 (2010) conditions of certification. A biological assessment has been prepared by the review 

32 team to address impacts on Federally listed species that may use the associated offsite 

33 facilities. The biological assessment is presented in Appendix F. PEF would implement any 

34 mitigation recommended through this process. Additional mitigation could be required for State35 listed species under the FDEP (2010) State conditions of certification. However, Florida law 

36 does not regulate the removal of State-listed plants for development or other land alterations on 

37 privately owned land. The LNP project would also be exempt from restrictions on native flora 

38 disturbances during clearing under (8)(c) of Florida Statutes 581.185 (Hildebrandt 2010). PEF 

39 (2009f) has committed to work with the regulatory agencies to prepare management plans that 
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August 2010 5-39 Draft NUREG-1941 

1 reduce impacts on listed species that occur within rights-of-way under company control. The 

2 restoration, enhancement, and protection of several hundred acres of degraded pine plantation 

3 are proposed under the wetland mitigation plan for the proposed LNP project (see Section 

4 4.3.1.7). This effort would be highly beneficial to many listed species affected by the LNP 

5 project and could compensate for many of the potential impacts realized from development and 

6 operation of the LNP and associated offsite facilities. 

7 Other Important Terrestrial Species and Habitats 

8 LNP Site

9 No unique or rare habitats, or habitats with priority for protection (other than wetlands that are 

10 discussed in Section 5.3.1.1), are identified on the LNP site that could be affected by operations 

11 (PEF 2009a). Plant communities on the LNP site have been extensively modified by decades of 

12 intensive forest management. Several preserves and conservation areas are located near the 

13 LNP site – the closest being the Goethe State Forest, which lies along the northeastern 

14 boundary of the site. Any potential impacts associated with drift, fogging, and icing would not be 

15 expected to extend beyond 3280 ft from the nearest cooling tower (PEF 2009a), which would 

16 not reach the Goethe State Forest boundary. Noise modeling predicts no perceptible to very 

17 slight increases in noise from LNP operations at the site boundary (CH2M Hill 2008). 

18 Several recreationally valuable game species are known to occupy the LNP site that could be 

19 affected by project operations (e.g., white-tailed deer, northern bobwhite, and wild turkey 

20 [Meleagris gallopavo]). These species and the habitats they prefer are locally abundant in the 

21 project vicinity. Drift, fogging, and icing are expected to cause little impact on habitats and 

22 would not be expected to affect important game species. Increased noise levels near the 

23 cooling towers, as well as increased human activity and traffic, may cause these wildlife species 

24 to avoid habitats immediately adjacent to proposed LNP Units 1 and 2. However, some level of 

25 habituation to these disturbances would likely occur. If permanent displacement of some game 

26 species into adjacent habitats occurred, competition for finite resources could result in small 

27 declines in the local populations. However, restoration of low-value pine plantations to native 

28 habitats as proposed under the wetland mitigation may more than compensate for any potential 

29 population declines. Consequently, operational impacts on game species are considered to be 

30 minor, and no additional mitigation would be warranted. 

31 Impacts on bald eagles from operation of proposed LNP Units 1 and 2 are expected to be 

32 negligible. The LNP site does not provide quality aquatic foraging habitat for the bald eagle, 

33 and nesting is not documented there. Several bald eagle nests are documented between 1 and 

34 2 mi from the LNP site. However, noise from project operation is not expected to be perceptible 

35 at these nest sites. 
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August 2010 5-40 Draft NUREG-1941 

1 Associated Offsite Facilities

2 No unique or rare habitats, or habitats with priority for protection (other than wetlands that are 

3 discussed in Section 5.3.1.1), are identified for the associated offsite facilities corridors. 

4 However, because of the linear extent of the associated facilities, a number of wildlife 

5 sanctuaries, refuges, and preserves exist near or are crossed by the corridors (see Section 

6 2.4.1.4). Collocating more than 90 percent of the new transmission lines with existing PEF lines 

7 would minimize the extent of new operational impacts resulting from the LNP. Nevertheless, 

8 noise, traffic, and human presence associated with occasional maintenance activities could 

9 result in minor, temporary impacts on adjacent conservation areas. Studies reviewed by NRC 

10 (1996) on the impacts of EMFs on terrestrial resources indicate that the proposed 500-kV and 

11 230-kV transmission lines should pose no adverse effect on terrestrial flora and fauna in 

12 adjacent conservation areas (see Section 5.3.1.2). 

13 A variety of recreationally valuable game species (e.g., white-tailed deer, eastern cottontail 

14 rabbit, various waterfowl, mourning dove [Zenaida macroura], northern bobwhite) are expected 

15 to occur along the associated offsite facilities corridors wherever suitable habitat is present. 

16 Noise, equipment, and human presence associated with occasional maintenance activities 

17 could result in very minor, temporary impacts on these species. Most game species are highly 

18 mobile and should disperse from the area when disturbing activities occur. However, small 

19 game (e.g., cottontail rabbits) may occasionally be killed during mowing, and the eggs and 

20 young of ground-nesting game birds (e.g., northern bobwhite) could be destroyed if mowing was 

21 conducted during the nesting season. Transmission-line structures, conductors, and guy wires 

22 would all pose a potential avian collision hazard for waterfowl and other game birds that live in 

23 or fly through these areas. A review of avian collision hazards by NRC (1996) concluded that 

24 bird mortality associated with transmission lines was generally of small significance for healthy 

25 avian populations. Nonetheless, the Avian Protection Plan PEF is required to prepare as a 

26 condition of State certification by the FDEP (2010) would reduce the potential for mortality of 

27 avian game species (see Section 5.3.1.2). Periodic vegetation management of the upland 

28 portions of the transmission-line corridors would maintain these areas in an early successional 

29 state that would benefit game species that exploit early seral communities and habitat edge. 

30 Considering these factors, these operational impacts on game species are judged to be minor, 

31 and no additional mitigation would be warranted. 

32 Bald eagles are widely distributed throughout central Florida wherever suitable aquatic foraging 

33 habitat is present. A number of bald eagle nests (both active and inactive) exist on or near the 

34 corridors for the associated offsite facilities. If bald eagle nests are located near final rights-of35 way and maintenance is conducted during the nesting season, noise, equipment, and human 

36 presence could adversely affect nesting bald eagles. If operational impacts on bald eagle nests 

37 cannot be avoided by following FWS (2007) and the FFWCC (2008) guidelines for bald eagles, 

38 PEF would need to obtain a FFWCC Eagle Permit and FWS authorization under the Bald and 
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August 2010 5-41 Draft NUREG-1941 

1 Golden Eagle Protection Act of 1940 (16 USC 688a-d). Transmission-line structures, 

2 conductors, and guy wires all pose a potential avian collision hazard for bald eagles that fly 

3 through transmission-line corridors. The Avian Protection Plan PEF must prepare as a 

4 condition of State certification by the FDEP (2010) would minimize the potential for 

5 transmission-line mortality of bald eagles (see Section 5.3.1.2). Accounting for these 

6 circumstances, impacts on bald eagles from operations associated with the proposed LNP7 associated offsite facilities are likely to be minor, provided that appropriate permits are acquired 

8 from the FWS and FFWCC and an Avian Protection Plan is implemented. 

9 Transmission-line structures, conductors, and guy wires also pose a potential avian collision 

10 hazard for whooping crane that may fly across transmission lines. Substantial portions of the 

11 proposed transmission-line corridors (including both corridors up to the first substation and 

12 corridors beyond the first substation) lie within the primary range of the non-migratory 

13 Kissimmee Prairie population, the migration route for the migratory whooping crane population 

14 crosses proposed transmission-line corridors, and the CREC to Brookridge corridor would lie 

15 within 2 mi of the wintering site for the migratory population. Co-location of more than 

16 90 percent of the proposed transmission lines with existing PEF transmission lines (PEF 2009e) 

17 would minimize new bird collision hazards. The Avian Protection Plan to be prepared by PEF 

18 as a condition of State certification (FDEP 2010) would also minimize the potential for 

19 transmission-line mortality (see Section 5.3.1.2). These measures should greatly reduce the 

20 likelihood that whooping crane would suffer injury or mortality from LNP-associated transmission 

21 lines. 

22 5.3.1.4 Terrestrial Monitoring 

23 PEF prepared a wetland mitigation plan (Entrix 2010) to compensate for the loss or impairment 

24 of functions of all wetlands affected by development and operation activities, including wetland 

25 impacts on the LNP site and those on the associated offsite facilities corridors (see Section 

26 4.3.1.7). Monitoring to evaluate success of the mitigation wetlands and document permit 

27 compliance is a component of the wetland mitigation plan. 

28 A State condition of certification by FDEP (2010) would require PEF to develop and implement 

29 an environmental monitoring plan to evaluate the relative condition of surface waters and 

30 wetlands in areas potentially affected by operational groundwater withdrawals. Monitoring 

31 would be required for a minimum of 5 years following groundwater use rising to more than 

32 1.25 Mgd. Monitoring results are to be submitted annually to the SWFWMD for compliance 

33 review. If ongoing environmental monitoring, aquifer performance testing, or groundwater 

34 modeling predict or detect adverse environmental impacts, PEF would be required to either 

35 mitigate the adverse impacts on wetlands or implement an approved alternative water-supply 

36 project (FDEP 2010). 
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August 2010 5-42 Draft NUREG-1941 

1 A condition of certification by the FDEP (2010) would also require PEF to prepare an Avian 

2 Protection Plan in coordination with the FFWCC and FWS. The plan must detail a program to 

3 reduce the operational risk to birds posed by the LNP electric utility facilities, with the goal of 

4 reducing avian mortality. An important part of this plan would include a monitoring system to 

5 document bird mortalities along transmission lines. This information would be used to identify 

6 avian problem areas and potential or known high risks. 

7 Monitoring for Federally and State-listed species may be required to meet conditions stipulated 

8 by the FWS and the FFWCC, either associated with the Endangered Species Act of 1973, as 

9 amended, (ESA) or for State permits to take or relocate State-listed species. 

10 5.3.1.5 Potential Mitigation Measures for Terrestrial Impacts 

11 The wetland mitigation plan proposed by PEF (Entrix 2010), as well as the Avian Protection 

12 Plan PEF is required to prepare under the conditions of State certification by the FDEP (2010), 

13 would provide compensatory mitigation for terrestrial-related impacts resulting from the 

14 operation of the proposed LNP. The wetland mitigation plan, discussed in Section 4.3.1.7, 

15 provides a landscape-level ecosystem benefit by enhancing and restoring ecological functions 

16 to hundreds of acres of wetland habitat and supporting uplands in the watersheds affected by 

17 project wetland impacts. Mitigation for unavoidable wetland impacts is required under both the 

18 Federal Water Pollution Control Act (Clean Water Act) Section 404 permit process and the 

19 Florida Environmental Resource Permit process. This effort is expected to be beneficial to 

20 terrestrial resources and ecosystem functions in the project area, including Federally and State21 listed species. 

22 The Avian Protection Plan is intended to detail a program to reduce the operational risk to birds 

23 posed by the LNP electric utility facilities, with the goal of reducing avian mortality. If additional 

24 mitigation is identified during listed species consultations with the FWS and the FFWCC or other 

25 FDEP (2010) post-certification permit compliance requirements efforts, PEF would be obliged to 

26 implement these measures as well. PEF (2009i) also has committed to work with the regulatory 

27 agencies to prepare management plans that reduce impacts on listed species that occur within 

28 transmission-line corridors under company control. 

29 5.3.1.6 Summary of Impacts on Terrestrial Resources 

30 The review team evaluated the potential effects of operating the LNP project, including onsite 

31 and associated offsite facilities, on terrestrial ecological resources. Potential impacts on wildlife 

32 populations, habitats, and wetlands posed by the heat-dissipation system, tall structures, 

33 increased noise and traffic, nighttime lights, transmission lines, and rights-of-way maintenance 

34 for the associated offsite facilities are expected to be relatively localized, and mitigable. 

35 Uncertainty exists regarding the potential for wetland impacts caused by groundwater 

36 withdrawal. Hydrological monitoring to ensure that groundwater withdrawals do not adversely 
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August 2010 5-43 Draft NUREG-1941 

1 affect wetlands would be required under the State-imposed conditions of certification (FDEP 

2 2010). If wellfield aquifer performance testing, revised groundwater modeling or environmental 

3 monitoring of wetlands either detects or predicts adverse wetland impacts, PEF would be 

4 required to mitigate the impacts or implement an approved alternative water-supply project 

5 (FDEP 2010). 

6 As many as 32 listed wildlife species (9 Federally listed; 32 State-listed) and 76 listed plant 

7 species (13 Federally listed; 76 State-listed) may occur on or in the vicinity the LNP site and 

8 associated offsite facilities, including the transmission lines. To comply with Section 7 of the 

9 ESA, the review team has prepared a biological assessment that documents potential effects on 

10 Federally listed threatened or endangered terrestrial species (Appendix F). A condition of 

11 certification by the FDEP (2010) would require protocol surveys for all State-listed species 

12 (excluding plants) that may occur on the LNP site and associated offsite facilities corridors prior 

13 to land “clearing and construction”. This condition of State certification by FDEP also requires 

14 the applicant to coordinate with the FFWCC if listed species are identified during 

15 predevelopment surveys or listed species are encountered during development to determine the 

16 need for appropriate mitigation (FDEP 2010). Provided that adequate surveys are conducted 

17 prior to commencement of development, consultation with the FWS and FFWCC is initiated as 

18 needed, and appropriate mitigation is implemented, impacts on listed species would likely to be 

19 minimized. However, without proper surveys, consultation, and appropriate mitigation, the 

20 impact could be greater. 

21 Based on the review team’s independent evaluation of the LNP project, including the ER, the 

22 Site Certification Application, PEF’s responses to the review team’s RAIs, interactions with State 

23 and Federal agencies, the public scoping process, and the identified mitigation measures and 

24 BMPs, the review team concludes that operational impacts on terrestrial ecological resources 

25 (including wetlands and listed species) would be SMALL to MODERATE. A range is provided to 

26 account for the uncertainty that exists regarding the potential effects of groundwater withdrawal 

27 on wetlands and associated biota. Additional mitigation beyond that proposed by PEF is not 

28 warranted, however, as stated in the FDEP (2010) conditions of certification, PEF must monitor 

29 groundwater and, if substantial operational hydrological effects on wetlands are discovered, 

30 PEF must either mitigate or utilize an alternative water source. 

31 5.3.2 Aquatic Impacts Related to Operation 

32 This section discusses the potential impacts of the operation of proposed LNP Units 1 and 2 on 

33 the aquatic ecosystem in the LNP onsite ponds, CFBC, OWR, CREC offshore discharge area in 

34 the Gulf of Mexico, and Outstanding Florida Waters and creeks crossed by the transmission-line 

35 corridors.
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1 5.3.2.1 Aquatic Resources – Cooling-Water Withdrawal Impacts 

2 For aquatic resources, the primary concerns related to water withdrawal are the impacts related 

3 to the potential for organisms to be impinged on the intake screens or entrained into the cooling4 water system. Impingement occurs when organisms are trapped against the intake screens by 

5 the force of the water passing through the CWIS (66 FR 65256). Impingement can result in 

6 starvation and exhaustion, asphyxiation (water velocity forces may prevent proper gill 

7 movement or organisms may be removed from the water for prolonged periods of time), and 

8 descaling (66 FR 65256). Entrainment occurs when organisms are drawn through the CWIS 

9 intake screens into the proposed LNP Units 1 and 2 cooling system. Organisms that become 

10 entrained are normally relatively small benthic, planktonic, and nektonic (limited movement in 

11 the water column) forms, including early life stages of fish and shellfish, which often serve as 

12 prey for larger organisms (66 FR 65256). As entrained organisms pass through a plant’s 

13 cooling system, they are subject to mechanical, thermal, and toxic stresses. 

14 A number of factors, such as the type of cooling system, the design and location of the intake 

15 structure, and the amount of water withdrawn from the source waterbody, greatly influence the 

16 degree to which impingement and entrainment affect the aquatic biota. 

17 PEF stated in its ER that a closed-cycle, mechanical draft cooling system would be used for 

18 proposed LNP Units 1 and 2. Closed-cycle recirculating cooling-water systems can, depending 

19 on the quality of the makeup water, reduce water use by 96 to 98 percent of the amount that the 

20 facility would use if it used a once-through cooling system (66 FR 65256). This significant 

21 reduction in water-withdrawal rate results in very significant reductions in impingement and 

22 entrainment. 

23 The EPA indicated (66 FR 65256) that the optimal design requirement for the intake location is 

24 to place the inlet of the CWIS in an area of the source waterbody where impingement and 

25 entrainment of organisms are minimized by locating intakes away from areas that have the 

26 potential for high productivity. Biological surveys in the area of the proposed CWIS intake 

27 indicate a biologically depauperate community dominated by sedimentary worms and a few 

28 euryhaline fish (see Section 2.4.2). However, once the CWIS is operational, the environment 

29 near the intake would increase in salinity concentration and dissolved oxygen, resulting in an 

30 overall improvement in water quality that may attract individuals and species. 

31 Species surveyed in the OWR where it joins with the CFBC are similar to species found 

32 between sampling stations 1 and 2 within the CFBC. The predicted increase in salinity 

33 concentrations in the lower portion of the OWR is still within the salinity-tolerance range of the 

34 species sampled at this location. The zone of transition between brackish and freshwater 

35 habitats moves farther up the OWR depending on discharge events originating from the Inglis 

36 Dam on Lake Rousseau, but a freshwater zone remains at the origin of the OWR (CH2M Hill 

37 2009b). 
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1 The CFBC near the proposed intake essentially is a dead-end with tidal exchange being the 

2 only appreciable flow along with leakage through the lock. As discussed in Section 5.2.3.1, the 

3 increment in velocity within the CFBC due to the operation of the LNP intake would be less than 

4 one-sixth of the average velocity of the incoming tidal waters during low-flow conditions. The 

5 velocity of up-canal water movement associated with the intake flow would be less than 0.06 fps 

6 under low-flow conditions. 

7 Another factor, the intake design through-screen velocity, greatly influences the rate of 

8 impingement of fish and shellfish at a facility. Generally, for a fixed withdrawal rate, the higher 

9 the through-screen velocity, the greater the number of fish impinged. The EPA has established 

10 a national standard for the maximum design through-screen velocity of no more than 0.5 fps 

11 (66 FR 65256). The EPA determined that species and life stages evaluated in various studies 

12 could endure a velocity of 1.0 fps, and then applied a safety factor of 2 to derive the threshold of 

13 0.5 fps. PEF has stated that the proposed LNP Units 1 and 2 intake structure would have a 

14 design through-screen velocity below 0.5 fps (PEF 2009a). 

15 Entrainment losses due to operation for a closed-cycle plant are a function of the volume of 

16 water withdrawn and are independent of through-screen velocity rate because entrained 

17 organisms (i.e., eggs, plankton) are incapable of avoiding being drawn into the intake structure. 

18 Impingement and entrainment studies have been conducted for the existing CREC. The studies 

19 were performed in 1983 and 1984 to examine impingement and entrainment for three intakes 

20 providing cooling water for fossil-fuel Units 1 and 2 and nuclear Unit 3, post operation (Stone & 

21 Webster 1985). Although the operation of these three units has more than 13 times higher 

22 withdrawal rates (1897 to 1613 Mgd) and twice the through-screen velocity (1.0 fps) than those 

23 proposed for the LNP units, the impingement and entrainment studies provide contextual 

24 information about the impact on relevant species that are present in the Gulf of Mexico and may 

25 be affected by LNP operations. In support of the Clean Water Act Section 316(b) Track I 

26 requirements, PEF conducted a 316(b) demonstration study to incorporate these requirements 

27 into an NPDES permit for LNP Units 1 and 2 (PEF 2008a). 

28 Impingement and entrainment studies were conducted to assess impacts as required under 

29 NPDES Permit FL0000159 for CREC (Stone & Webster 1985). Sampling for impingement rates 

30 occurred four times over a 24-hour period every 2 weeks for 1 year by examination of collection 

31 baskets attached to screen-wash effluents. The three units were assessed by individual intake, 

32 but the results are combined for discussion purposes here. The highest abundances of 

33 organisms were collected in the spring, with bay anchovy (Anchoa mitchilli) collected in the 

34 greatest numbers with estimates of more than 87,000 impinged annually. Polka-dot batfish 

35 (Ogcocephalus cubifrons) and spot (Leiostomus xanthurus) were two other species also 

36 collected in significant numbers. Together, the three species represented more than 72 percent 

37 of the selected indicator fish impinged. In 1997, the State of Florida set an annual commercial 

38 harvest limit of 85,000 lb of bay anchovy for the counties of Wakulla, Franklin, Gulf, Bay, 
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August 2010 5-46 Draft NUREG-1941 

1 Okaloosa, and Walton (Fla. Amdin. Code 68B-50.002), but bay anchovy are not regulated for 

2 commercial harvest in Citrus or Levy Counties (FFWCC 2009b). Eighty-seven thousand 

3 organisms represents approximately 350 lb (average 0.004 lb per fish), indicating that the loss 

4 of 350 lb of bay anchovy due to plant operation compared to the commercial harvest limit listed 

5 above represents a fraction of this abundant species. The numbers of invertebrates impinged 

6 were much higher than for fish, with pink shrimp (Farfantepenaeus duorarum) and blue crab 

7 (Callinectes sapidus), the predominant species. Like fish, invertebrate impingement was 

8 highest in the spring. More than 640,000 pink shrimp and 383,000 blue crab were impinged 

9 over a year. These impingement numbers represent 0.6 percent and 0.7 percent of the annual 

10 commercial fishery for Citrus County in 1982, respectively (Stone & Webster 1985) and reflect 

11 impingement rates for a through-screen velocity of 1.0 fps and a combined intake flow rate of 

12 1897 to 1613 Mgd. By comparison, the potential impingement impacts of proposed LNP Units 1 

13 and 2 should be notably less with a through-screen velocity of less than 0.5 fps and a combined 

14 intake flow rate of 122 Mgd. 

15 Entrainment of marine species is limited to what will pass through the 3.5-in. opening between 

16 the bar racks and through the 3/8-in.-mesh intake screens. Because the life stages of 

17 threatened and endangered species described in this biological assessment are larger than the 

18 openings in the intake screen mesh, these species are not likely to be entrained into the LNP 

19 cooling-water system. However, food sources for the threatened and endangered species may 

20 pass through the intake screens as eggs or larvae and are discussed in terms of relative 

21 abundance. Plankton samples were collected for the CREC 316 studies (1985) from 

22 15 sampling stations offshore in the vicinity of the CREC intake canal every 2 weeks for 

23 15 months using 505-μm mesh with a 1-m mouth towed for 3 minutes from bottom to the 

24 surface at a constant flow rate. These samples were analyzed for estimation of entrainment of 

25 eggs and larvae for CREC intakes 1–3. April and May were peak collection times for eggs, 

26 while invertebrate meroplankton were collected in the highest numbers in July and August. Bay 

27 anchovy eggs, larvae, and juveniles were the most abundant, and using foregone production 

28 assumptions regarding life history and survival, represent approximately 21.7 million adults 

29 (Boreman et al. 1981). Recreationally important fish entrained included larvae and/or juveniles 

30 of silver perch (Bairdiella chrysoura; 6602 adult equivalents as assessed for growth and 

31 mortality factors (CH2M Hill 2009c), spotted seatrout (Cynoscion nebulosus; 900 adult 

32 equivalents), red drum (Sciaenops ocellatus; 18 adult equivalents), spot (690,000 adult 

33 equivalents), and striped mullet (Mugli cephalus; 5985 adult equivalents). With the exception of 

34 spot, the entrainment impact on these fish represents less than 0.2 percent of the estimated 

35 annual commercial harvest for each species. The 1982 commercial harvest of spot for Citrus 

36 and Levy Counties was equivalent to the estimated numbers (based on weight) of entrained 

37 spot (Stone & Webster 1985). 

38 Invertebrate sampling indicated that shrimp, stone crab (Menippe mercenaria), and brief squid 

39 (Lolliguncula brevis) could be entrained. Although no pink shrimp were collected, other shrimp 
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August 2010 5-47 Draft NUREG-1941 

1 post larvae and juveniles were assessed without distinguishing species and represent greater 

2 than 29,000 adult equivalents. Florida stone crab zoeal through megalops stages and brief 

3 squid were collected and estimated to represent 3652 and 3600 (194 lb) adult equivalents for a 

4 year, respectively. With commercial harvest of shrimp of more than 1 million lb, the number of 

5 shrimp lost to entrainment is minimal. Likewise, the number of entrained brief squid is small 

6 with commercial landings of squid in Pasco and Pinellas Counties in 1986 exceeding 2900 lb 

7 (FFWCC 1986). The impact on entrained stone crabs is difficult to assess because the 

8 commercial fishery is renewable and only the claws are harvested. However, more than 

9 950,000 lb of claws were harvested in Citrus and Levy Counties in 1982, and, assuming that 

10 claws make up half the weight (Lindberg and Marshall 1984), the loss of commercial harvest 

11 due to entrainment would be less than 0.01 percent. By comparison, the CREC withdrawal of 

12 water from the Gulf of Mexico is between 1897 and 1613 Mgd, which is more than 13 times 

13 greater than the proposed water withdrawal of 122 Mgd from the CFBC for proposed LNP Units 

14 1 and 2. Entrainment impacts for LNP are expected to be significantly less than for CREC and, 

15 when compared to estimated adult equivalent impacts for CREC, range from less than 

16 0.4 percent of total adult equivalents for spotted seatrout (3 adult equivalents for LNP) and less 

17 than 23 percent of total adult equivalents for red drum (4 adult equivalents for LNP) based on 

18 sampling done in the CFBC as described in Section 2.4.2.1 (CH2M Hill 2009c). 

19 For the LNP Units 1 and 2 CWIS, PEF estimated potential impingement and entrainment 

20 impacts for withdrawal of cooling water from the CFBC based on design and construction 

21 technology, baseline biological characterization, and zone of hydraulic influence. The zone of 

22 hydraulic influence is the region of the CFBC in which a nonmotile organism in the waterbody 

23 will be drawn into the intake. PEF estimated that the zone of hydraulic influence would extend 

24 5 mi west from the CWIS in the CFBC (PEF 2008c) and used an offshore station in the Gulf of 

25 Mexico to estimate impingement and entrainment impacts. Sampling in the area of the 

26 proposed CWIS indicated a biologically depauperate environment with relatively poor water 

27 quality (PEF 2009a). As described in Section 5.2.3, the CFBC currently has elevated salinity 

28 from incoming tidal exchange that would increase only slightly with operation of intakes for LNP 

29 Units 1 and 2. Using conservative assumptions that the water quality may approach attributes 

30 similar to those observed in the CFBC near sampling station 3 at the mouth, PEF estimates that 

31 the number and diversity of species are likely to increase near the CWIS for the life stages of 

32 organisms that are mobile and actively feeding. However, the portions of the CFBC sampled 

33 near stations 3 and 4 are not known spawning areas, and plankton likely drift in and out of this 

34 area under tidal influence. Therefore, the potential for entrainment of aquatic organisms during 

35 operation of the CWIS would likely increase as a result of the changes induced by operation of 

36 the CWIS and not due to colonization or use of habitat near the CWIS. However, the overall 

37 impingement and entrainment of aquatic organisms for LNP is still expected to be minimal for 

38 aquatic populations in the CFBC and the Gulf of Mexico. 
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August 2010 5-48 Draft NUREG-1941 

1 Maintenance of the CWIS includes the use of screen washes and mechanical scraping to 

2 prevent clogging or collection of debris and organisms on intake screens and bar racks, 

3 respectively. Bar racks would be removed and scraped once per quarter as currently done at 

4 CREC (PEF 2009e). Trash and organisms caught on traveling intake screens would be 

5 removed by a high-pressure spray wash and deposited into a collection dumpster. Collected 

6 debris and organisms would be disposed of in a licensed landfill. 

7 Based on the planned low through-screen intake velocity, the use of closed-cycle cooling, the 

8 distance of the intake canal from the Gulf of Mexico, the lack of spawning habitat within the 

9 CFBC, and the comparison of impingement rates for existing CREC Units 1–3, the staff 

10 concludes that impacts from impingement of aquatic organisms for proposed LNP Units 1 and 2 

11 would be minor. 

12 Based on the percentage of water withdrawn, the closed-cycle cooling-system design, the 

13 distance away from preferred spawning habitat in the Gulf of Mexico, and the comparison of 

14 entrainment rates for the existing CREC Units 1–3, the staff finds that the impacts on the 

15 aquatic organism eggs and zooplankton of the Gulf of Mexico from entrainment due to operation 

16 of LNP 1 and 2 would be minor. 

17 Cooling-Water Discharge Impacts 

18 The potential impacts on the Gulf of Mexico from the operation of proposed LNP Units 1 and 2 

19 would include the impacts of heated effluents on aquatic resources, chemical impacts, and 

20 physical impacts from discharge. 

21 Aquatic Thermal Impacts 

22 The effluents from proposed LNP Units 1 and 2 would be discharged directly into the CREC 

23 discharge. Section 4.3.2 of this EIS discusses the location and design of the discharge piping. 

24 The proposed LNP Units 1 and 2 discharge would be 4.4 percent of the total discharge from 

25 combining LNP and CREC Units 1 through 5 discharges. The potential incremental impacts on 

26 the Gulf of Mexico from the operation of proposed LNP Units 1 and 2 would include the impacts 

27 of heated effluents on aquatic resources, chemical impacts, and physical impacts from 

28 discharge.

29 Cold Shock

30 A factor related to thermal discharges that may affect aquatic biota is cold shock. Cold shock 

31 occurs when aquatic organisms that have been acclimated to warm water, such as fish in a 

32 power plant’s discharge canal, are exposed to a sudden temperature decrease. This 

33 sometimes occurs when single-unit power plants shut down suddenly in winter. Cold shock 

34 mortalities at U.S. nuclear power plants are “relatively rare” and typically involve small numbers 
Operational Impacts at the Proposed Site 

August 2010 5-49 Draft NUREG-1941 

1 of fish (NRC 1996). It is less likely to occur at a multiple-unit plant because the temperature 

2 decrease from shutting down one unit is moderated by the heated discharge from the units that 

3 continue to operate. The NRC staff is unaware of any outage that has resulted in cold shock 

4 stress at CREC. The discharge from proposed LNP Units 1 and 2 would be 4.4 percent of the 

5 total discharge from combining LNP and CREC discharges. Based on the foregoing, the staff 

6 concludes the thermal impacts on the fish populations due to cold shock would be minor, and 

7 additional mitigation would not be warranted. 

8 Heat Stress

9 The thermal tolerance for aquatic organisms is defined in different ways. Some definitions 

10 relate to the temperature that causes fish to avoid the thermal plume. Other definitions relate to 

11 the temperature that fish prefer for spawning, and still others relate to the temperatures (upper 

12 and lower) that may kill individual fishes. Some of these tolerances are termed “preferred 

13 temperatures,” “upper avoidance temperatures,” and “lethal temperatures.” 

14 In Section 5.2.3.1, the staff describes its independent assessment of the incremental impacts of 

15 proposed LNP Units 1 and 2 on the water temperatures within the CREC discharge and the Gulf 

16 of Mexico using a three-dimensional coastal ocean model. The staff is also aware of the 

17 proposed uprate of CREC Unit 3 and the possibility that CREC Units 1 and 2 (fossil-fuel plants), 

18 which contribute approximately two thirds of the discharge flow, would be decommissioned once 

19 LNP Units 1 and 2 begin operation. A thermal analysis discussing both scenarios is presented 

20 in Sections 7.2.2.1 and 7.3.2 describing potential future actions that may affect any LNP 

21 discharge impacts. During summer conditions at ebb tide, the surface-water temperatures near 

22 the CREC discharge channel would be slightly less with operation of LNP 1 and 2 when 

23 compared with current conditions that include operation of CREC Units 1–5. The discharge 

24 volume of the plume would be increased with the addition of LNP Units 1 and 2, but only a slight 

25 increase in surface-water temperature (<0.1°C) would result compared with current conditions. 

26 Temperature increase at the entrance of the CFBC channel would be between 0.05°C and 

27 ~0.1°C during the summer months at ebb tide (Figure 5-6). Similar trends in thermal plume 

28 temperatures would be observed during winter conditions with the addition of LNP discharge 

29 resulting in a slight temperature drop at the CREC discharge canal, and a slight increase in 

30 surface-water temperature beyond the immediate discharge area. Surface-water temperatures 

31 at the mouth of the CFBC are expected in increase by less than 0.5°C over the current 

32 conditions (Figure 5-7). The increased plume size would likely have minimal impact on aquatic 

33 biota that forage near the CFBC under both extreme conditions. Habitat usage is not expected 

34 to be affected under proposed conditions. 

35 Based on the foregoing, the staff concludes that the thermal impacts on habitat and aquatic 

36 biota of the discharge of waste heat from LNP Units 1 and 2 into the CREC discharge canal and 

37 Gulf of Mexico would be minor, and additional mitigation would not be warranted. 
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August 2010 5-50 Draft NUREG-1941 

1 

2 Figure 5-6. Thermal Plume Analysis Using the Finite Volume Community Ocean Model 

3 (FVCOM) Showing the Temperature Difference Between the Current and 

4 Proposed Thermal Discharge Under Summer Conditions at Ebb Tide 

5 

6 Figure 5-7. Thermal Plume Analysis Using the FVCOM Showing the Temperature Difference 

7 Between Current and Proposed Thermal Discharge Under Winter Conditions at 

8 Ebb Tide 
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August 2010 5-51 Draft NUREG-1941 

1 Invasive Nuisance Organisms

2 Invasive nuisance organisms found in the CFBC include the false dark mussel (Mytilopsis 

3 leucophaeata), barnacles (Chthamalus fragilis), and the green porcelain crab (Petrolisthes 

4 armatus). None of these invasive species, or any other invasive species, has been observed to 

5 have increased in numbers as a result of the thermal plume operated by CREC Units 1–5. 

6 Therefore, no large growth of invasive nuisance organisms is anticipated from the thermal 

7 plume for proposed LNP Units 1 and 2, because the overall thermal change would be less than 

8 1°C during summer and winter conditions. 

9 Chemical Impacts 

10 Other discharge-related impacts include the chemical treatment of the cooling water. The ER 

11 indicates that chemicals would be added to the circulating-, service-, and blowdown-water 

12 systems (PEF 2009a). Intake structures, such as the pump suction housings and sensor tubes, 

13 would be coated with a copper-based, anti-fouling substance to minimize fouling of these 

14 structures. In addition, ClamTrol (CT1300) would be injected every 21 days at a concentration 

15 not to exceed 4.5 ml/L into cooling-water intake structures to prevent biofouling of marine 

16 invertebrates (PEF 2009e). The use of chemicals in the existing CREC discharge is regulated 

17 by an NPDES permit, which is granted by the FDEP. The chemical concentrations at the outfall 

18 for the existing units meet the NPDES limits (FDEP 2008). 

19 Table 5-3 lists the water-treatment chemicals, their uses, and the concentrations that are 

20 anticipated to be discharged from proposed LNP Units 1 and 2 blowdown. The CREC effluent 

21 discharge and water flow from the Gulf of Mexico would further dilute the concentration of these 

22 chemicals. 

23 In addition, the NRC staff evaluated the potential for impact due to the increased salinity 

24 associated with the LNP Units 1 and 2 blowdown, which is estimated to have a TDS 

25 concentration of 1.5 times greater than seawater (PEF 2009e). This increase in TDS is due to 

26 evaporative loss of water through the cooling towers. Because the LNP discharge would be 

27 combined with CREC discharge prior to point of discharge into Crystal Bay and the CREC 

28 discharge accounts for the vast majority of the discharge volume (>95 percent), the increase in 

29 salinity would be slight (0~0.5 ppt) in the coastal region near the CREC discharge channel, and 

30 between 0.4 ppt~0.45 ppt at the mouth of the CFBC (Figure 5-8). Thus, the impacts from the 

31 addition of LNP discharge to the Gulf of Mexico would be minimal. As described in Section 

32 5.7.2, salt deposition from cooling-tower drift is predicted to be a maximum of 10.75 kg/ha/mo 

33 onsite. Deposition of salt decreases rapidly with increasing distance from cooling towers, and is 

34 therefore not expected to detectably affect the closest freshwater bodies, which are 

35 approximately 3 mi to the south (Lake Rousseau and the Lower Withlacoochee River) from the 

36 LNP site. 
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August 2010 5-52 Draft NUREG-1941 

1 Table 5-3. Chemical Discharges to the Gulf of Mexico from Proposed LNP Units 1 and 2 

Chemical Use Dosage Concentration 

Expected 

Concentration at 

Discharge Point 

Sodium hypochlorite Biocide 0.2 ppm residual chlorine or 

0.36 sodium hypochlorite 

<0.01 ppm 

Ammonium chloride Algaecide 0.2 ppm residual chlorine or 

0.303 ppm ammonium chloride 

<0.01 ppm 

Sulfuric acid pH adjuster 2.237 ppm sulfuric acid pH in range 

Orthopolyphosphate Corrosion inhibitor 30 ppm orthopolyphosphate Small amounts of total 

phosphorus 

Polyacrylate Silt dispersant 150 ppm polyacrylate Inert solids <10 microns 

Phosphonate Antiscalant 20 ppm phosphonate Negligible due to 

infrequent use and small 

discharge volume 

Sources: PEF 2008a , 2009a

2 

3 Figure 5-8. Salinity Difference Between the Current (CREC Units 1–5) and Proposed (CREC 

4 Units 1–5 and LNP Units 1 and 2) Discharge Plume at Ebb Tide 
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August 2010 5-53 Draft NUREG-1941 

1 Physical Impacts from Discharge 

2 The discharge volume of the LNP Units 1 and 2 blowdown would be 81.34 Mgd and would be 

3 combined with the CREC Units 1–5 discharge of 1651.8 Mgd in the CREC discharge canal, 

4 which opens into the Gulf of Mexico. The LNP discharge would contribute only 4.4 percent of 

5 the total discharge flow and would have little effect on physical scouring at the terminus of the 

6 discharge canal (PEF 2009a). 

7 Based on this analysis of the potential for physical impacts on the aquatic ecosystem from the 

8 discharge of cooling water to the Gulf of Mexico and the staff’s independent review, the staff 

9 concludes that the physical impacts from thermal discharges from proposed LNP Units 1 and 2 

10 would be minor because the incremental increase in the discharge flow is less than 5 percent 

11 and any impact due to the small increase in scouring would be undetectable outside of the short 

12 distance from the discharge terminus. 

13 Stormwater Drainage 

14 A few permanent and temporal shallow pools currently exist on the LNP site. Operation of Levy 

15 Units 1 and 2 would not result in any surface-water discharge to these waterbodies. Stormwater 

16 infiltration ponds would be constructed to manage runoff onsite during operations (PEF 2009a). 

17 Only in the unlikely overtopping of the infiltration ponds during a severe rainfall event would 

18 these onsite waterbodies receive any surface runoff from the infiltration ponds. There is no 

19 connection of these onsite pools or proposed stormwater infiltration ponds to the CFBC, 

20 Withlacoochee River, or the Gulf of Mexico. The staff concludes that based on the use of a 

21 stormwater system described in the stormwater-management plan, the impacts on onsite 

22 aquatic resources, the CFBC, Withlacoochee River, and the Gulf of Mexico from operation of 

23 the proposed LNP Units 1 and 2 would be minor. 

24 Maintenance Dredging 

25 The NRC staff evaluated the likelihood of maintenance dredging in front of the barge-unloading 

26 facility and CWIS. A barge slip/boat ramp and dock would be constructed along the northern 

27 shore of the CFBC just upstream of the proposed CWIS and 0.5 mi downstream from the Inglis 

28 Lock. Maintenance dredging for the barge-unloading facility and the CWIS within the CFBC is 

29 not proposed because the depth of the CFBC has not changed since its construction in the 

30 1960s, and increased sediment load is not predicted under operation conditions 

31 (CH2M Hill 2009d). The upland portion of the barge slip/boat ramp is expected to be available 

32 to members of the public.
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August 2010 5-54 Draft NUREG-1941 

1 Groundwater Use Impacts on Aquatic Resources

2 Based groundwater modeling, there may be a reduction of 0.4 Mgd of the groundwater 

3 discharge to the Lower Withlacoochee River and Lake Rousseau as a result of service-water 

4 pumping from groundwater wells for proposed LNP Units 1 and 2. As discussed in 

5 Section 5.2.2.2, the reduction is expected to have minimal impact on the estimated total 

6 groundwater discharge of 687 Mgd to the Lower Withlacoochee River/Lake Rousseau 

7 watersheds and thus would have minimal impact on the ecology of these waterbodies. 

8 5.3.2.2 Aquatic Resources – Transmission Lines 

9 Maintenance activities along the four 500-kV, five 230-kV, and two 69-kV transmission lines 

10 could lead to periodic temporary impacts on the waterways being crossed. However, it is 

11 assumed that the same vegetation-management practices currently used by PEF for the 

12 existing CREC facility transmission-line corridors would be applied to the existing and proposed 

13 new transmission-line corridors. PEF practices and procedures were developed to prevent 

14 impacts on surface waters and wetlands, so impacts on aquatic ecosystems from operation and 

15 maintenance of transmission lines would be small (PEF 2009a). PEF plans to leave a 25-ft 

16 buffer of existing vegetation with mature heights not exceeding 12 ft at locations where the 

17 transmission-line corridor crosses a navigable waterway, including limited use of herbicides 

18 near these buffer zones (PEF 2008a). Maintenance of vegetation in transmission-line corridors 

19 will be performed in accordance with PEF’s Transmission Vegetation Management Program 

20 (PEF 2008a). Impacts on aquatic species are not anticipated from maintenance of the 

21 transmission lines. Therefore, impacts would be considered small, and additional mitigation 

22 would not be warranted. 

23 The staff concludes that the impacts of transmission-line corridor maintenance activities on 

24 aquatic resources would not adversely impact aquatic ecosystems, and additional mitigation 

25 beyond that already described would not be warranted. 

26 5.3.2.3 Aquatic Species and Habitats 

27 Important Species 

28 This section describes the potential impacts on important aquatic species (see Table 2-14) 

29 resulting from operation of the new units at the proposed LNP site, cooling-water intake and 

30 discharge, and maintenance of transmission-line corridors. The staff has determined that 

31 operational aquatic impacts would be limited to the CFBC and the point of discharge from the 

32 CREC discharge canal, which includes the nearshore Crystal Bay area of the Gulf of Mexico. 

33 The general life histories of these species are presented in Section 2.4.2. The staff prepared 

34 biological assessments documenting the impacts of operation of a new nuclear unit on the 

35 Federally listed threatened and endangered aquatic species described in the FWS and National 
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August 2010 5-55 Draft NUREG-1941 

1 Marine Fisheries Service (NMFS) correspondence (FWS 2009; NOAA 2008a, b). The staff also 

2 prepared an essential fish habitat assessment submitted to NMFS. The staff’s impact 

3 determinations from the biological assessments and essential fish habitat assessment are 

4 reiterated in this section. 

5 Commercial Fishery

6 With the exception of the blue crab, all commercial fishery activities occur well offshore from the 

7 CFBC and CREC point of discharge into the Gulf of Mexico. Commercial blue crab pots were 

8 observed within the lower portion of the CFBC on two separate occasions, but they were not 

9 evident near the location of the proposed CWIS. Operation of the CWIS and discharge are not 

10 expected to affect commercial fisheries in the Gulf of Mexico within the CFBC because these 

11 species are able to escape from an intake velocity of less than 0.5 fps, they spawn offshore, and 

12 no significant changes are expected in the commercial fisheries due to changes in the CREC 

13 discharge with the addition of LNP effluent. 

14 Recreational Fishery

15 Recreational angling occurs within the CFBC, but it is limited to the CREC outside of the 

16 discharge canal at the point of discharge. Operation of the CWIS, discharge, and corridor 

17 maintenance are not expected to affect recreational fisheries in the Gulf of Mexico, within the 

18 CFBC, or within waterbodies spanned by transmission lines because these species are able to 

19 escape from an intake through-screen velocity of less than 0.5 fps, they spawn offshore, and 

20 would be unaffected by the insignificant changes expected in the Gulf due to changes in the 

21 CREC discharge with the addition of LNP effluent. 

22 Essential Species

23 The presence of abundant forage fish, such as silver perch and spotfin mojarra (Eucinostomus 

24 argenteus), within the CFBC and offshore of the CREC discharge are summarized in Table 

25 2-14. Operation of the CWIS, discharge, and corridor maintenance are not expected to affect 

26 the presence or habitat use of these forage species in the vicinity of these activities because 

27 these species are able escape away from an intake through-screen velocity of less than 0.5 fps, 

28 they spawn offshore, and no significant changes are expected in the Gulf due to changes in the 

29 CREC discharge with the addition of LNP effluent. 

30 Rare Species

31 Speckled hind (Epinephelus drummondhayi) and Warsaw grouper (Epinephelus nigritus), both 

32 listed as species of concern by the NMFS, are known to occur in the inland waters of the Florida 

33 Gulf Coast. However, neither of these species was collected during 2 years of sampling within 

34 the CFBC, so any CWIS operational impacts on these species would be unlikely. Addition of 
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August 2010 5-56 Draft NUREG-1941 

1 LNP effluent within the CREC discharge would not significantly alter the discharge in the CREC 

2 offshore area. No significant changes are expected in these species due to changes in the 

3 CREC discharge with the addition of LNP effluent. 

4 Federally and State-Listed Species 

5 The Florida manatee, loggerhead sea turtle (Caretta caretta), green sea turtle 

6 (Chelonia mydas), Kemp’s ridley sea turtle (Lepidochelys kempii), hawksbill sea turtle 

7 (Eretmochelys imbricata), and smalltooth sawfish (Pristis pectinata) are Federally listed 

8 threatened and endangered species known to occur in the vicinity of the proposed LNP site and 

9 the CREC site. The endangered leatherback sea turtle (Dermochelys coriacea) and threatened 

10 gulf sturgeon (Acipenser oxyrinchus desotoi) have not been reported in these areas. Appendix 

11 F provides a detailed discussion of the potential operational impacts on Federally threatened 

12 and endangered species, which are summarized here. The sea turtles and smalltooth sawfish 

13 do not nest or reproduce in the vicinity of the proposed LNP or CREC discharge. Therefore, the 

14 impact of intake or discharge operations on newly hatched turtles or juvenile sawfish would be 

15 insignificant. Because the flow requirements under 316(b) require through-screen velocities of 

16 0.5 feet/sec or less, any juvenile, subadult, and adult healthy sea turtles, sawfish, or manatees 

17 that enter the CFBC would be able to swim away from the zone of influence or the intake area 

18 itself during operation. However, injured or moribund species may become entrapped on the 

19 intake trash bars or traveling screens. Addition of LNP effluent within the CREC discharge 

20 would not significantly affect Federally or State-listed species due to changes in the CREC 

21 discharge. Therefore, operation of LNP may affect, but is not likely to adversely affect, juvenile, 

22 subadult, and adult sea turtles, sawfish, or manatees. 

23 Based on this review, the staff concludes that the impacts on aquatic Federally listed threatened 

24 and endangered species from operation of proposed LNP Units 1 and 2 would be minimal, and 

25 mitigation would not be warranted. 

26 Essential Fish Habitats 

27 There are no areas designated as critical habitat for threatened and endangered species in the 

28 vicinity of the LNP and CREC sites, but essential fish habitat is present for both the CFBC and 

29 offshore Gulf of Mexico area of the CREC discharge. Both the CFBC and CREC discharge 

30 canal are considered essential fish habitat within Ecoregion 2. No habitats of particular concern 

31 occur in either waterbody or associated nearshore areas. Table 2-14 lists the species and life 

32 stages included under essential fish habitat for the CFBC and CREC discharge canal. 

33 Appendix F contains a detailed discussion of potential LNP impacts on essential fish habitat. 

34 The known distributions and records of Ecoregion 2 listed species and life stages, the potential 

35 ecological impacts of the construction on the species, their habitats, and their prey have been 

36 considered. Based upon the project operation plans and the use of closed-cycle cooling, the 

37 staff believes that adverse impacts on essential fish habitat would be minimal. 
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August 2010 5-57 Draft NUREG-1941 

1 5.3.2.4 Aquatic Monitoring During Operation 

2 PEF plans to perform formal monitoring of CFBC and CREC offshore Gulf of Mexico aquatic 

3 ecosystems during operations. Preoperation and operation monitoring are planned for the 

4 CFBC in the vicinity of the CWIS, the CREC discharge canal, and offshore areas to establish a 

5 preoperational baseline and to assess the impacts of operation (PEF 2009a). Impingement and 

6 entrainment studies are proposed for 1 year following full operation of proposed LNP Units 1 

7 and 2 (PEF 2009a). As part of the State of Florida’s Conditions of Certification, “[p]re8 operational survey and post-operational monitoring shall be conducted for a period of time to be 

9 determined by statistical analysis in coordination between the FWC, in consultation with DEP, 

10 and the Licensee, utilizing the same pre-operational survey methodologies in order to identify 

11 and characterize biological and water quality impacts associated with the project for any needed 

12 mitigation purposes” (FDEP 2009b). PEF will submit a Cross Florida Barge Canal and 

13 Withlacoochee River Survey and Monitoring Plan to the State for approval prior to initiation of 

14 formal monitoring. LNP and CREC combined discharge monitoring is also specified in the State 

15 of Florida’s Conditions of Certification as requiring “[a] broad-based, pre-operational survey and 

16 a postoperational monitoring plan, for a period of time to be determined by statistical analysis in 

17 coordination between the DEP, FWC and the Licensee, that is available prior to operation of the 

18 facility, that includes sites outside of the existing or predicted plume areas to allow for a 

19 comparison of the plume area sites to a "control site"” (FDEP 2009b). PEF will submit a Levy 

20 Nuclear and Crystal River Energy Complex Combined Discharge Survey and Monitoring Plan to 

21 the State for approval prior to initiation of formal monitoring. 

22 5.3.2.5 Summary of Operational Impacts on Aquatic Resources 

23 The staff has reviewed the proposed operational activities for proposed LNP Units 1 and 2 and 

24 the potential impacts on aquatic biota in the CFBC, OWR, Gulf of Mexico, and rivers and 

25 perennial/seasonal streams crossed by transmission-line corridors. Based on this review, the 

26 staff has determined that the impacts resulting from the proposed operational activities would be 

27 SMALL, and any mitigation beyond what is already described above would not be warranted. 

28 5.4 Socioeconomic Impacts 

29 Plant operations can affect individual communities, the surrounding region, and minority and 

30 low-income populations. This evaluation assesses the impacts of operations-related activities 

31 and operations workforce on the 50 mile radius surrounding the plant (the region). The review 

32 team reviewed the ER prepared by PEF and verified the data sources used in its preparation by 

33 examining cited references and independently confirming data in discussions with community 

34 members and public officials (NRC 2009). The review team requested clarifications and 

35 additional information from PEF as needed to verify data in the ER. Unless otherwise specified 

36 in the following sections, the review team has drawn upon verified data from PEF 
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August 2010 5-58 Draft NUREG-1941 

1 (PEF 2009a, c, e, i, j). Where the review team used different analytical methods or additional 

2 information for its own analysis, the sections include explanatory discussions and citations for 

3 additional sources. 

4 PEF estimates the operations workforce for LNP Units 1 and 2 to be 773 workers (specific 

5 assumptions are discussed in ensuing sections). The operation of LNP Units 1 and 2 would 

6 increase the workforce during scheduled outages by an additional 800 workers for about 25 to 

7 30 days every 9 months (18 months between outages for each unit). To the extent practicable, 

8 outages would be staggered. 

9 Although the review team considered the entire region around the LNP site when assessing 

10 socioeconomic impacts, based on commuter patterns, the distribution of residential communities 

11 in the area, and the nature of the likely socioeconomic impacts of operations, the review team 

12 found the three counties that surround the site – Levy, Citrus, and Marion – to be a primary 

13 Economic Impact Area (EIA) for community impacts. 

14 5.4.1 Physical Impacts 

15 Potential physical impacts include noise, odors, exhausts, visual intrusions, and thermal 

16 emissions. Thermal emissions are addressed in Sections 5.2.3 and 5.3.2. The review team 

17 believes the physical impacts would be mitigated through site design and operation of the facility 

18 in accordance with all applicable Federal, State, and local environmental regulations and, 

19 therefore, would not significantly affect the EIA. The following sections assess the potential 

20 operations-related physical impacts of the proposed LNP on specific segments of the 

21 population, workers, and nearby communities. 

22 For more than a century, the proposed LNP site has been used for forest plantations. The 

23 closest residential properties are located 1.6 mi northwest and 1.7 mi west-southwest of the 

24 proposed site. There are no sensitive populations near the proposed LNP site. The nearest 

25 recreational resources are Goethe State Forest, the Marjorie Harris Carr Cross Florida 

26 Greenway, Inglis Island Trail, Inglis Lock Recreation Area, and the CFBC (see Figure 2-23 and 

27 Figure 2-24). These recreational resources are located south and northeast of the proposed 

28 LNP site. The operations workforce for the two units would be 773 people, with less than the 

29 total being onsite at one time because of shift work. 

30 5.4.1.1 Workers and the Local Public 

31 This section discusses potential effects of air emissions and noise on workers, nearby residents, 

32 and nearby users of recreational areas. 

33 Air emissions would be generated from the two mechanical draft cooling towers, the emergency 

34 power equipment (diesel generators and fire pumps), and vehicle traffic from plant operations. 
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1 The primary emitter would be the cooling towers, emitting water vapor and particulate matter. 

2 Visual effects of the water vapor plumes are discussed under “Aesthetics” (Section 5.4.1.4). 

3 The particulate matter in the cooling-tower emissions would be made up of naturally occurring 

4 salt particles dissolved and suspended in the cooling water that would be carried in water drops 

5 released to the air from the towers. As presented in Section 5.7.2, the review team reviewed 

6 modeling results that found deposition of the salt decreases rapidly with distance from the plant, 

7 at a maximum offsite deposition of 6.81 kg/ha/mo at a location west of the cooling towers. 

8 Certificates to operate the diesel generators and fire pumps require that air emissions comply 

9 with all applicable regulations. As indicated in Section 5.7.1, because these systems would be 

10 used on an infrequent basis, the review team concludes that the environmental impacts would 

11 be minimal. A small increase in local air emissions would be expected from the vehicles of the 

12 773 plant operations employees who would travel over the local road network. However, this 

13 increase is not expected to result in a significant change in total vehicle miles traveled in the 

14 region or a regulatory change in air quality attainment for the region or the state. The entire 

15 State of Florida is considered in attainment for the National Ambient Air Quality Standards 

16 (NAAQSs) (EPA 2010a). 

17 Neither the cooling-tower emissions of particulate matter, operation of the emergency 

18 equipment, nor increased vehicle traffic would cause NAAQS pollutants to be emitted in 

19 quantities that exceed Federal thresholds or create or contribute to a regional haze problem. 

20 Therefore, their impact on air quality is not considered significant. Because of the limited 

21 emission of air pollutants expected during operation of the proposed LNP, the review team 

22 determined that the LNP’s effect on air quality would be minor. 

23 Operation of the proposed LNP would produce noise from the operation of pumps, transformers, 

24 turbines, and generators, as well as periodic testing of emergency sirens. Some increase in 

25 noise in the area would result from vehicle travel by the permanent workforce. PEF must meet 

26 all applicable Occupational Safety and Health Administration (OSHA) noise requirements. 

27 Workers would use noise protection as required by OSHA when engaging in work subject to 

28 noise hazards. Emergency power equipment would be housed in insulated buildings to reduce 

29 noise and would be operated infrequently, primarily for testing and maintenance or during 

30 emergency conditions. The pump house would be constructed from noise-attenuating 

31 materials, and sounds emitted from it would not exceed the Levy County Noise Ordinance. 

32 A 2008 noise assessment for PEF’s Site Certificate Application to the State of Florida indicated 

33 that noise levels at offsite receptor sites would not exceed the Levy County Noise Ordinance 

34 and would be below both the ordinance’s daytime and nighttime maximum allowable levels of 

35 65 and 55 dBA outside the site boundary. Noise from plant operations would be within 

36 allowable levels at the residences closest to the site. Portions of the Marjorie Harris Carr Cross 

37 Florida Greenway are located near the pump house. Thus, pump noise would be audible to 

38 visitors near the pump house, but within allowable levels (PEF 2009a). Due to the distance and 
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August 2010 5-60 Draft NUREG-1941 

1 vegetative buffer that exists between the site and other recreational resources near the site, the 

2 review team does not expect any adverse noise impacts. For these reasons, the review team 

3 determined the noise-related effect on workers, residents, and recreational users of nearby 

4 areas would be minor, and no mitigation would be warranted. 

5 5.4.1.2 Buildings 

6 The distance of the proposed LNP site from offsite buildings means that operational activities 

7 would not affect them. Onsite buildings would be constructed to safely withstand any possible 

8 shock or vibration from operational activities. No other industrial, commercial, or residential 

9 structures would be affected. Consequently, the review team determined that there would be no 

10 impacts of operations on onsite or offsite buildings, and mitigation would not be warranted. 

11 5.4.1.3 Roads 

12 Roads near the proposed LNP site would experience an increase in traffic at the beginning and 

13 end of each operational shift, at the beginning and end of each outage support shift, and from 

14 deliveries made to the site. Section 5.4.4.1 addresses offsite traffic impacts. Commuter traffic 

15 would be controlled by speed limits onsite. With the exception of the heavy-haul road, the 

16 access roads to the LNP site would be paved. Maintaining good road conditions and enforcing 

17 appropriate speed limits would reduce the noise level, particulate matter, and other exhaust 

18 generated by the workforce and delivery vehicles entering and leaving the LNP site. Therefore, 

19 the review team determined the road-related impacts of operations from noise, dust, and 

20 exhaust on workers, residents, and other users of the roads near the proposed site would be 

21 minimal, and additional mitigation would not be warranted. 

22 5.4.1.4 Aesthetics 

23 Most of the proposed LNP site would be preserved in its present forested condition, with forest 

24 surrounding the industrial area. The tallest buildings, the two containment structures, would be 

25 225 ft high. The cooling towers would be 56 ft high (PEF 2009a). Because of the vegetation 

26 screening, the physical structures of the plant would not be visible from public areas at ground 

27 level. This includes the closest residences. Only during certain meteorological conditions 

28 would the plumes from the cooling towers (not the towers themselves) be visible from a few 

29 offsite locations. 

30 Typically, the plumes would extend only a short distance from the site and would dissipate. As 

31 discussed in Section 5.7.2, the EPA’s CALPUFF dispersion model was used to characterize 

32 plume behavior. The model found that less than 2 percent of the time (1 percent during daylight 

33 hours) the plume would be visible to surrounding areas more than 1000 m from the site, and the 

34 plume would rise to 200 m less than 1 percent of the time. Plumes visible from 5000 m or more 

35 are expected to occur during approximately 0.8 percent of the total summer and fall hours. The 
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August 2010 5-61 Draft NUREG-1941 

1 largest plume elevation would also occur in the summer, with the occurrence of plumes rising 

2 400 m or more during approximately 0.3 percent of the total hours. Occurrences of ground-level 

3 fog are not expected beyond 1000 m from the site. Because the nearest road is 1400 m from 

4 the site, neither ground-level fog nor icing is expected on nearby roadways as a result of the 

5 proposed LNP operation. Odors would not be associated with the cooling-tower plumes. 

6 Due to the vegetation buffer, the LNP’s physical structures would not be visible from the closest 

7 residences or recreation areas. Ground-level fog and associated icing associated with 

8 operation of the cooling towers would dissipate before reaching offsite roads. The noticeable 

9 aesthetic effects of the transmission line and corridor, described in Section 4.4.1.4, would 

10 continue throughout the life of the project. Based on this information, the review team has 

11 determined that the aesthetic impact of operating the proposed LNP would be minor, with the 

12 exception of the transmission lines and corridors, and mitigation other than that specified for the 

13 transmission-line corridors would not be warranted. 

14 5.4.1.5 Summary of Physical Impacts 

15 Based on the information provided by PEF and its independent review, the review team 

16 concludes that all physical impacts of operating proposed LNP Units 1 and 2 would be minor, 

17 with the exception of the transmission lines and corridors which would continue to be noticeable, 

18 and additional mitigation measures beyond those identified by PEF would not be warranted. 

19 5.4.2 Demography 

20 PEF anticipates employing 773 operations workers at the new units. This includes the 

21 140 operations workers present during preconstruction and construction and the 500 employed 

22 by the time of Unit 1 startup. The review team expects 232 (30 percent) of the operations 

23 workers would already reside within a reasonable commuting distance from the plant; 541 

24 (70 percent) of the operations workers and their families would migrate into the region and 

25 reside within a 1-hour commute of the LNP site. Of the 541 in-migrating workers, the review 

26 team expects 80 percent, or 432, to choose to live in the EIA. The Bureau of Economic 

27 Analysis (BEA) estimated each job for an in-migrating operations worker in the EIA would 

28 support an additional 1.2 indirect jobs (BEA 2009). Therefore, the 432 direct jobs filled by in29 migrating workers to the EIA would create an additional 519 indirect jobs in the EIA (432 times 

30 1.2). The review team assumed that the indirect jobs would be filled by people already residing 

31 in the region or by family members of in-migrating operations workers and would not add to the 

32 number of people migrating into the area as a result of the LNP operations. 

33 The average family size in Florida of 2.49 was applied to the 541 workers who would move to the 

34 region, resulting in a total increase in population of approximately 1347 people. This total 

35 includes the in-migrating workers and their families present during preconstruction, construction, 

36 and at initial startup of LNP Unit 1. The review team estimated that 80 percent of new operations 
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1 workers (workers migrating into the region) and their families would reside within the EIA (about 

2 202 persons in Levy County, 471 in Citrus County, and 403 in Marion County) and 20 percent 

3 (267 people) in the remainder of the region, mostly in Alachua County. Table 5-4 illustrates this 

4 distribution in comparison with projected population figures for 2015. 

5 Table 5-4. Potential Increase in Resident Population Resulting from Operating Proposed LNP 

6 Units 1 and 2

County

Number of 

In-Migrating 

Workforce 

Percent of 

In-Migrating 

Workforce

Related 

Increase in 

Population(a)

Projected

Population, 

2015(b)

Percentage 

Increase in 

Resident 

Population

Levy 81 15 202 46,466 0.43 

Citrus 189 35 471 161,108 0.29 

Marion 162 30 403 393,456 0.10 

Alachua 81 15 202 279,666 0.07 

Hernando 11 2 27 187,984 0.01 

Dixie 5 1 12 18,455 0.07 

Sumter 5 1 12 109,294 0.01 

Gilchrist 5 1 12 20,714 0.06 

Region 541 100 1347 1,313,751 0.10 

Total 100.0 

(a) Using an average Florida family size of 2.49. 

(b) From Table 2-16 and Appendix G of this EIS. 

7 Partly because of attrition due to the age structure of the regional workforce, partly due to an 

8 expanding demand for energy sector workers in Florida, and partly due to the specific skill 

9 requirements of the jobs, the review team believes it unlikely that the region could provide 

10 enough appropriately skilled workers for many of the operations jobs. Based on review of 

11 current operations staffing at CREC (PEF 2009i), the review team determined 30 percent of the 

12 positions might be handled by less specialized workers who would come from within the region. 

13 This differs from the assumption made in the ER that 100 percent of the operations workers 

14 would migrate into the region. To consider the effects of other in-migration assumptions, the 

15 effects discussed in this EIS can be multiplied by an appropriate scaling factor. 

16 Table 5-5 shows the review team’s projected distribution of operations workers, which differs 

17 somewhat from that reported in the PEF ER. The distribution reflects the fact that housing 

18 availability is not a constraint. There is ample housing to buy or rent in all counties (Table 4-13). 
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1 Table 5-5. Distribution of Operations-Related Workers 

County 

Percent 

of 

Workers 

In-Migrating 

Workers Taking 

New Operations 

Jobs(a) 

Local 

Workers 

Taking 

New 

Indirect 

Jobs(b) 

Local 

Workers 

Taking 

New 

Operations 

Jobs 

Total 

OperationsRelated 

Jobs(c) 

2005 

Employment(d) 

Levy 15 81 97 35 213 15,829 

Citrus 35 189 227 81 497 48,761 

Marion 30 162 195 70 427 122,098 

Alachua 15 81 NA NA NA 119,035 

Dixie 1 6 NA NA NA 5299 

Gilchrist 1 6 NA NA NA 7198 

Hernando 2 11 NA NA NA 53,891 

Sumter 1 5 NA NA NA 24,501 

Total 100 541 NA NA NA 396,612 

(a) 70 percent of workforce jobs filled by in-migrants. 

(b) Induced by the new in-migrant jobs, filled locally. 

(c) Includes 30 percent of workforce jobs filled locally. 

(d) US Department of Labor, Bureau of Labor Statistics (BLS) 2005. 

NA = not applicable. 

2 In addition, Citrus County has approved a number of new housing developments (NRC 2009). 

3 The distribution assumes that a commute time of 1 hour would be acceptable to many of the 

4 workers. Some commute times would be reduced from estimates based on conditions in 2008 

5 because of anticipated road improvements that would be in place by 2017. Primarily because of 

6 commute times, the review team assumes that most in-migrating operations workers would 

7 reside within the EIA. In contrast with the assumptions made for the construction workforce, the 

8 review team expects slightly higher percentages of operations workers to reside in Marion and 

9 Alachua Counties. Operations jobs are longer term, and many are higher salaried. Experience 

10 at other sites indicates that operations workers may emphasize amenities (shopping, 

11 healthcare, or specific recreation opportunities – golf, boating, fishing) and factors such as the 

12 quality of local schools and opportunities for spousal employment more than simple commute 

13 time or distance. Therefore, Ocala (Marion County) and Gainesville (Alachua County), large 

14 cities that require a 1-hour commute, would be more attractive to some operations workers than 

15 to construction workers. Within the region, the operations workers and their families are 

16 expected to increase the projected 2015 resident population by about 0.10 percent. Within 

17 Levy, Citrus, and Marion Counties, they would increase the projected 2015 resident populations 

18 by 0.43 percent, 0.29 percent, and 0.10 percent, respectively. 

19 Based on the analysis, the review team concludes that the demographic impacts of operation of 

20 the LNP site would be minor. 
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1 5.4.3 Economic Impacts on the Community 

2 The impacts of station operation on the local and regional economy are dependent on the 

3 region’s current and projected economy, tax base, and population. The primary economic 

4 impacts of operating the proposed LNP Units 1 and 2 would be related to revenue from new 

5 jobs and increased tax payments. 

6 5.4.3.1 Economy 

7 Key assumptions relate to the number, value, and location of new jobs, and where jobholders 

8 would reside. 

9 As indicated in Section 5.4.2, the review team assumes 70 percent of the 773 new workers, or 

10 541, would in-migrate from outside the region (distributed as shown in Table 5-4) and that 432 

11 of those in-migrating workers would reside within the EIA. An estimated 514 indirect jobs would 

12 be created in the EIA. 

13 The average wage at CREC in 2008 was $79,944. Assuming that wages inflate by 10 percent 

14 between 2008 and 2017, the review team assumed an average for LNP salaries of about 

15 $88,000 for 2017. This would result in an estimated $68 million in total annual salaries in the 

16 region for operations workers, including an estimated $38 million in annual salaries for the in17 migrating workers in the EIA and an additional $16 million for annual salaries for EIA area 

18 residents who fill operations jobs. Based on the average estimated median household income 

19 for the EIA in 2005–2007, the review team estimated that the new indirect jobs would provide 

20 $22 million in salaries in the 50 mi, including $19 million in the EIA (USCB 2009a, b, c), for a 

21 total earnings per year of $73 million in the EIA once both plants are operating. 

22 BEA (2009) stated that the earnings multiplier for utility industry jobs in the EIA is 1.4. As a 

23 check on the aforementioned earnings estimate, the review team applied the earnings multiplier 

24 to estimated annual operations salaries in the EIA, resulting in an estimated $69 million 

25 economic impact (1.4 times $38 million for in-migrating workers plus $16 million for local 

26 residents who fill operations jobs). 

27 Drawing on the assumptions as explained, Table 5-5 shows the assumed distribution of all 

28 operations jobs in comparison with 2005 employment figures. The increase in total employment 

29 would be 1137 jobs in the EIA. The table demonstrates that the direct and indirect jobs related 

30 to operation of the proposed LNP would be a small percentage of the total 2005 jobs in the EIA. 

31 The $73 million annual earnings from direct and indirect new jobs associated with LNP 

32 operation by in-migrating and local residents of the EIA is less than 2 percent of the 

33 approximately $6 billion total 2005 earnings in these counties shown in Table G-5 in Appendix 

34 G. The $54 million annual earnings in the region from direct jobs at the plant represents more 
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1 than 30 percent of the approximately $170 million total 2005 earnings in the transportation and 

2 utility sector in the EIA shown in Table G-5. Thus, LNP operations would noticeably boost 

3 employment in that sector but have little effect on overall regional employment. For Levy 

4 County, the annual earnings of incoming workers and associated indirect jobs would total about 

5 $10.5 million, slightly less than 3 percent of 2005 earnings in the county. For Marion and Citrus 

6 Counties, the percentage effect would be smaller in spite of the presence of more incoming 

7 operations workers because of the larger size of their economies. 

8 The operation of proposed LNP Units 1 and 2 would also increase the workforce by an 

9 additional 800 workers during scheduled outages for about 25 to 30 days every 9 months. This 

10 outage workforce would be composed of contract employees to perform equipment 

11 maintenance, refueling, and special outage projects at the site. To stay as close as possible to 

12 the LNP site, most of the outage workers would stay in local hotels, rent rooms in local homes, 

13 or bring travel trailers. The earnings and expenditures associated with these temporary 

14 workforce increases would be 5 percent or less of those discussed for the permanent operations 

15 workforce. 

16 The overall impact on the economies of the region and the EIA from operating proposed LNP 

17 Units 1 and 2 would be minor and positive. 

18 5.4.3.2 Commercial and Recreational Fishing 

19 In addition to the positive job-related impacts, operating a nuclear power plant could have a 

20 negative impact on other aspects of the economy. In particular, the impingement, entrainment, 

21 and thermal effects of the water uptake and discharge for the plant could affect commercial and 

22 recreational usage of fish species. Based on the information in Section 5.3.2.3, the review team 

23 determined the impact on commercial and recreational fishing from the operation of proposed 

24 LNP Units 1 and 2 would not be noticeable. 

25 5.4.3.3 Taxes 

26 Tax revenue categories that would be affected by the operation of proposed LNP Units 1 and 2 

27 include sales and use taxes, corporate income tax, and property taxes. The State of Florida 

28 does not collect an individual income tax. 

29 Sales and Use Taxes 

30 The $73 million in earnings from operations jobs and associated indirect jobs in the EIA once 

31 both units are in operation is less than half of the almost $170 million earnings created by LNP 

32 jobs in this area during peak construction and preconstruction employment. Using the same 

33 assumptions applied in Section 4.4.3.3, this would generate about $1.2 million in annual State 

34 sales tax revenue with less than $100,000 as the one-half percent share reaching the individual 
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August 2010 5-66 Draft NUREG-1941 

1 county governments in the EIA. This is a negligible amount when compared to annual tax 

2 revenue in each of these counties. 

3 The annual value of purchases subject to sales and use taxes would be much less during 

4 operations than during preconstruction and construction. Assuming the level of operations5 related purchases to be about 10 percent of the preconstruction- and construction-phase annual 

6 level, the operations-related sales tax revenue for the region would be less than $500,000, and 

7 the added use tax for the State would be about $3 million. These revenues are negligible when 

8 compared to annual sales and use tax revenues at the county and State levels. 

9 Corporate Income Tax 

10 PEF would pay corporate income taxes of approximately 5.5 percent of its net State income. 

11 These taxes would go directly to the State of Florida. Unlike sales tax, there is no specified 

12 return to the region or county of revenue generated by corporations within them. Given the 

13 magnitude of Florida’s State budget, the review team concludes that the impact on the State 

14 would be minor and positive. 

15 Property Taxes 

16 As indicated in Section 4.4.3.3, once each unit begins operating, the value of the LNP property 

17 would be assessed at the value of construction cost, less the cost of pollution-control 

18 components, or approximately three-quarters of the total construction cost. Property (ad 

19 valorem) taxes will then be applied to this assessed value, approximately $10.6 billion when 

20 both LNP Units 1 and 2 are operational. Using the 2008 millage rate of 15.78, the review team 

21 estimated an annual payment of $63 million when Unit 1 comes on line, increasing to 

22 $104 million when Unit 2 is operational. Compared to Levy County’s $18 million tax revenue 

23 and $38.8 million total revenue in 2006, these increases would have a noticeable and 

24 substantial positive impact. 

25 The review team recognizes that some operations workers would purchase new homes that 

26 also would generate new property taxes. Given the magnitude of the local tax base in the EIA, 

27 this additional revenue would constitute a small percentage increase. Therefore, the review 

28 team determined that the impact of operations of proposed LNP Units 1 and 2 on residential 

29 property tax revenues would be minor. 

30 Summary of Tax Impacts 

31 The review team expects tax revenue increases in the form of sales, use, corporate income, 

32 and property taxes because of the operation of the proposed LNP units and the influx of 

33 operations workforce into the region. This impact, however, is likely to be minimal for all 
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August 2010 5-67 Draft NUREG-1941 

1 locations except Levy County, which would experience a noticeable and substantial increase in 

2 property tax revenue. 

3 5.4.3.4 Summary of Economic Impacts on the Community 

4 Based on the information provided by PEF, review team interviews with local public officials, 

5 and NRC’s independent review of data about the region’s economy and taxes, the review team 

6 concludes that the impacts on the region’s economy of operating the proposed units at the LNP 

7 site would be SMALL and beneficial for all counties except Levy, which would experience a 

8 LARGE positive increase in tax revenue. 

9 5.4.4 Infrastructure and Community Services 

10 This section describes the estimated impacts on infrastructure and community services, 

11 including transportation, recreation, housing, public services, and education. 

12 5.4.4.1 Transportation 

13 The effects of LNP operation on transportation and traffic would be greatest on US-19, the 

14 north-south highway that provides the main access to the LNP site. Primary access to the site 

15 during operations would be via a new main driveway intersecting with US-19 south of the 

16 construction driveway. The review team determined operations impacts in a manner similar to 

17 that used to evaluate the construction and preconstruction impacts in Section 4.4.4.1. 

18 The analysis draws on a traffic study (Kimley-Horn 2009) that considered the number and timing 

19 of operations worker vehicles on the road for two shifts that correspond to the a.m. and p.m. 

20 peak hours, the number and timing of truck deliveries per day, the projected population growth 

21 rate in Levy County, and the capacity and usage of the road system. As explained in 

22 Section 4.4.4.1, the Kimley-Horn (KH) study adopted Levy County’s level of service (LOS) 

23 standards for roads in the county (Levy County 2009). KH used 24-hour traffic counts collected 

24 in July 2008 from a previous study performed by Linck and Associates (Kimley-Horn 2009), 

25 2007 24-hour counts from the Florida Department of Transportation, and p.m. peak-hour counts 

26 collected in November and December 2008 by KH staff (Kimley-Horn 2009). 

27 The review team agreed with the assumption in the KH study that the same major travel routes 

28 described in Section 4.4.4.1 would be used by operations workers to commute to and from the 

29 LNP site with a similar directional split. The study estimated vehicle usage by the operations 

30 workforce in 2017, the first year when both proposed LNP Units 1 and 2 would be operating. 

31 The study assumed that turn-lane improvements and signal controls described in 

32 Section 4.4.4.1 would remain in place after construction and identified the need for the 

33 construction of turn lanes, but no traffic signal, at the intersection of US-19 with the main 

34 (operations) driveway to accommodate the operations workforce. The KH study did not include 
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August 2010 5-68 Draft NUREG-1941 

1 consideration of traffic effects of a proposed northward expansion of the Suncoast Parkway into 

2 Citrus County that could be completed before or soon after the proposed LNP units are 

3 operational. The parkway extension, currently planned as a toll road, is intended to link the 

4 Veterans Expressway in Tampa with US-19/US-98 in northern Citrus County, south of the 

5 proposed LNP site. Because there is sufficient capacity on the existing roadways to 

6 accommodate the operations workforce, completion of the Suncoast Parkway northern 

7 extension could only help reduce the effect of the operations workforce on the surrounding road 

8 network. Not including it in the analysis provides an upper bound on expected traffic impacts. 

9 The review team agrees with the KH study approach of excluding the effects of the Suncoast 

10 Parkway to avoid underestimating potential operational impacts. Nevertheless, if the Suncoast 

11 Parkway were completed, it would help move traffic to and from the site to Citrus County and 

12 south to Tampa. During outages, planned to occur every 9 months, an additional 800 outage 

13 workers would be onsite for a period of 25 to 30 days. Outage workers would access the LNP 

14 site through the construction entrance on US-19/US-98, not the main (operations) driveway. 

15 Trucks delivering new reactor fuel, equipment, and materials also would use the construction 

16 driveway. The outage workforce and refueling freight traffic would be much less than traffic 

17 during peak construction employment. Consequently, the turn lanes and traffic signal installed 

18 to accommodate construction and preconstruction traffic would also accommodate the traffic 

19 associated with outages. 

20 Because the number of operations workers is less than a quarter of the number of construction 

21 and preconstruction workers at peak, the review team determined that traffic impacts from 

22 operations would be smaller than those estimated for construction and preconstruction. Based 

23 on its review of the KH traffic study and assuming implementation of the study’s mitigation 

24 recommendations, the review team finds that there would be minimal impacts on the road 

25 network with the exception of an expected discernable impact at the intersection of US-19 with 

26 the construction driveway at shift change during outages. However, given that outages would 

27 only occur for 1 out of every 9 months and would be limited to shift changes, the review team 

28 determined the overall traffic-related impact would be minimal. 

29 5.4.4.2 Recreation 

30 A detailed description of the local availability and use of recreational facilities is provided in 

31 Section 2.5.2.4. The physical impacts of operation of proposed LNP Units 1 and 2 are 

32 discussed in Section 5.4.1. Impacts from increased demand or use would be similar to, but 

33 smaller than, the construction and preconstruction impacts described in Section 4.4.4.2 because 

34 the in-migrating operations workforce would be smaller than the construction workforce. Given 

35 that the construction- and preconstruction-related impacts on recreation were deemed minor, 

36 the review team concludes the impacts of plant operations on recreation in the EIA and within 

37 50 mi of the proposed LNP site would be minimal. 
Operational Impacts at the Proposed Site 

August 2010 5-69 Draft NUREG-1941 

1 5.4.4.3 Housing 

2 The assumptions underlying the review team’s estimated in-migration of operations workers 

3 were provided in Section 5.4.3. Seventy percent, or 541 workers, of the total operations 

4 workforce of 773 workers would be expected to move into the region; 432 of the workers would 

5 reside within the EIA – 81 in Levy, 189 in Citrus, and 162 in Marion. Overall, this represents a 

6 decrease in the number of workers migrating into the region and EIA compared to those 

7 expected during construction and preconstruction. 

8 Section 2.5.2.5 states that there were 37,784 vacant units and 78,889 housing units for rent or 

9 sale in the EIA in 2000. The review team determined there currently is enough available 

10 housing to support the maximum influx of workers and their families (1347 total people) into the 

11 region, particularly in the EIA where 1076 new people (workers and their families) are expected 

12 to reside. Because the available housing within the EIA exceeds the number of operations 

13 workers expected to move into the area for the proposed LNP, the review team anticipates no 

14 shortage of housing or developable land and, therefore, no upward pressure on housing prices. 

15 Marion and Citrus Counties, which have more available housing than Levy County, may 

16 experience an increase in housing demand or a shift in demand toward relatively higher-value 

17 houses. Levy County may notice a shift toward construction of new homes due to the age and 

18 condition of the existing housing stock within the county. New construction to accommodate 

19 operations workers and their families within Levy County’s town of Inglis, the closest community 

20 to the proposed LNP site, would be limited because there is no public sewer service. Inglis 

21 regulates 1 house per ac or 1 house per 5 ac near the coast (NRC 2009). 

22 The 800 outage workers likely would stay in area apartments, hotels, motels, or 

23 camping/recreational vehicles (RVs) areas dispersed throughout the EIA. The analysis of 

24 housing availability for the construction workforce in Section 4.4.4.3 and Table 4-13 indicates 

25 that the supply of public lodging and camping and/or RV areas is sufficient to accommodate the 

26 influx of temporary workers within the EIA, and no single community would be expected to be 

27 overburdened by the influx of temporary workers. 

28 Given the ample supply of available housing in the EIA and region, the review team determined 

29 that the overall impact on housing demand and prices from plant operations over the expected 

30 40-year life would not be noticeable. 

31 5.4.4.4 Public Services 

32 This section describes the available public services and discusses the impacts of construction 

33 and preconstruction at the proposed LNP site on water supply and waste treatment; police, fire34 protection, emergency, and medical services; and education, in the region with a focus on the 

35 EIA. 
Operational Impacts at the Proposed Site 

August 2010 5-70 Draft NUREG-1941 

1 Water-Supply Facilities 

2 The proposed LNP would use an average of 35 gpm with a maximum of 69 gpm of potable 

3 water from onsite wells. Because of the availability of groundwater at the site, assumed permit 

4 compliance, and the site’s independence from municipal water supplies, the review team has 

5 determined plant operations would have minimal impact on this water resource. 

6 Using the same assumptions presented in Section 4.4.4.4, the review team calculated the 

7 increase in demand for residential water attributable to the in-migrating operations workers and 

8 their families. The demand for water within the EIA would increase by 0.161 Mgd of potable 

9 water. This increase, slightly less than a 0.2 of 1 percent increase over projected water demand 

10 in the EIA without the in-migrants, would be spread proportionally among the counties according 

11 to the distribution of workers discussed in Section 5.4.2, resulting in an increase of 0.43 percent 

12 in Levy County, 0.29 percent in Citrus County, and 0.10 in Marion County. To the extent 

13 operations workers purchase existing homes, their demand for water would already be planned. 

14 However, some in-migrating operations workers may decide to have new homes built, which 

15 would increase demand for water and sewer services in the EIA. For purposes of this analysis, 

16 the review team assumes full conformance with local municipal regulations and permit 

17 requirements to demonstrate sufficient water capacity prior to the approval of new construction. 

18 Given the small increase in demand that would result from the operations workers and their 

19 families who move into the area, the review team has determined that operations-related 

20 impacts on the water supply in the EIA would not be noticeable, and no mitigation would be 

21 warranted. 

22 Wastewater-Treatment Facilities 

23 The proposed LNP would have a private wastewater-treatment facility with capacity of 

24 80,000 gpd, sufficient to serve the operations workforce, as well as additional workers during 

25 planned outages. 

26 The review team calculated the increase in wastewater treatment that would be required in the 

27 EIA during operations due to in-migrating workers and their families. Using an average of 110 

28 gpd per person for in-migrating workers and their families (Marion County’s LOS standard, 

29 highest among those reported in Section 2.5.2.6) and 2015 population projections from Table 2-

30 16, wastewater-treatment needs would be 0.118 Mgd for the new construction and 

31 preconstruction workers and families and onsite workers during peak construction employment. 

32 As with water demand, this increase in wastewater-treatment needs would be slightly less than 

33 0.2 of 1 percent increase over projected water-treatment demand in the EIA without the in34 migrants and would be spread among the counties according to the distribution of workers 

35 discussed in Section 5.4.2. The estimated increase as a result of the in-migrating operations 

36 workers and their families is 0.43 percent in Levy County, 0.29 percent in Citrus County, and 

37 0.10 in Marion County. As with the discussion of water services, new home construction may 
Operational Impacts at the Proposed Site 

August 2010 5-71 Draft NUREG-1941 

1 call for additional wastewater infrastructure to areas that are not currently served. For purposes 

2 of this analysis, the review team assumes full conformance with local municipal regulations and 

3 permit requirements to demonstrate sufficient wastewater capacity prior to the approval of new 

4 construction. Given the small increase in demand that would result from the operations workers 

5 and their families who move into the area, the review team has determined that operations6 related impacts on the wastewater-treatment capabilities in the EIA would not be noticeable, 

7 and no mitigation would be warranted. 

8 Police, Fire-Protection, Emergency, and Medical Services 

9 Section 5.4.4.3 discusses the distribution of housing for in-migrating operations workers and 

10 their families in the EIA. The additional population amounts to less than 0.2 of 1 percent 

11 increase in Levy, Citrus, and Marion Counties over 2015 projections. This long-term population 

12 increase would potentially add to the workload for police, fire-protection, and emergency 

13 services and increase the number of users of local medical facilities. However, such small 

14 numbers should not noticeably affect performance, except in localities where services currently 

15 are near or over capacity. 

16 The review team used the same approach presented in Section 4.4.4.4 to evaluate the potential 

17 impacts on the services. Differences are long-term residency of operations staff, smaller total 

18 numbers, a slightly different allocation of workers in the EIA, availability of substantial property 

19 tax revenues to Levy County, and timing – the EIA will already have adapted their capabilities to 

20 address the demands created during the building phase, as described in Section 4.4.3. The 

21 review team anticipates the project-related population and activities would add a minor 

22 increment to the demand for police and emergency services by the residents of the EIA. 

23 Locally, for the Inglis police and emergency services, the review team expects a short-term 

24 noticeable impact until Levy County is able to draw on tax revenues to supplement Inglis 

25 resources as needed. Likewise, the review team would expect noticeable impacts on the city of 

26 Dunnellon police and emergency services because police services already are at capacity, and 

27 the community is expected to attract a number of the operations workers. The review team 

28 determined that, given the 40-year life of the proposed two units, all of the noticeable impacts 

29 would be mitigated to a minimal level by readjustment of community resources. 

30 The review team expects little impact on fire-protection services in Marion and Citrus Counties 

31 because they already have available capacity. Because the current fire-protection services in 

32 Levy County are at capacity, the review team expects that even the small increase in demand 

33 for fire-protection services in Levy County would prolong the noticeable impact discussed in 

34 Section 4.4.4.4 until services could be added using property tax revenue. 

35 Given the current 16-percent vacancy rate in the region’s hospitals, the review team expects 

36 minor impacts on access to medical care in the region. The increase represented by a 

37 population increase of about 0.1 of 1 percent would fill only a small part of those vacancies.
Operational Impacts at the Proposed Site 

August 2010 5-72 Draft NUREG-1941 

1 5.4.4.5 Education 

2 As indicated in Section 5.4.2, the review team projects that 80 percent of incoming workers and 

3 their families would settle within the EIA, resulting in 189 new households in Citrus County, 81 in 

4 Levy County, and 162 in Marion County. The review team used county school district estimates 

5 of students per household from Table 2-35 to calculate the added students attributable to in6 migrating operations worker households, as shown in Table 5-6. 

7 Table 5-6. Expected Number of Students from In-Migrating Operations Worker Households 

Elementary 

School Students 

Middle School 

Students 

High School 

Students 

Total 

Students 

Levy County 16 9 9 34 

Citrus County 22 11 13 47 

Marion County 26 13 15 53 

EIA 64 32 37 134 

Values calculated using county school district estimates of students per household from Table 2-35 in Chapter 2 and 

number of in-migrating workers per county from Table 5-4. 

8 The addition of 134 students would be a small number added to the existing rolls (approximately 

9 66,000 in 2007–2008 as indicated in Section 2.5.2.7). 

10 As indicated in Section 2.5.2.7, there are capacity issues in Levy County schools, including the 

11 Yankeetown School, which is closest to the proposed LNP site, and in Marion County schools, 

12 including Dunnellon High School and the elementary school closest to the LNP site. Because 

13 the State of Florida mandates that new development cannot be approved without appropriate 

14 accommodations for school-age children, the review team assumes that school capacity would 

15 be available for any locations where operations workers might build housing. 

16 Levy County can anticipate an increased tax base once proposed LNP Unit 1 is operational, 

17 which could provide funding for expansion of Yankeetown School beginning in 2017, including 

18 the addition of a high school. Levy School District staff indicated it has available land for 

19 expansion, but lacks the budget (NRC 2009). The addition of a high school in Levy County 

20 would alleviate crowding at Dunnellon High School, even if some operations workers settle in 

21 Dunnellon. 

22 Based on these considerations, the review team has determined that operation of the proposed 

23 LNP would have little impact on EIA school capacity with possible short-term impact on 

24 Yankeetown School and Dunnellon High School until additional capacity is provided in Levy 

25 County. 
Operational Impacts at the Proposed Site 

August 2010 5-73 Draft NUREG-1941 

1 5.4.5 Summary of Socioeconomics Impacts 

2 The review team determined that the physical effects of plant operations would be SMALL, with 

3 the exception of a continued MODERATE aesthetics impact from the transmission lines and 

4 corridors. Economic, demographic, and tax impacts would be SMALL and beneficial except for 

5 Levy County where tax impacts would be LARGE and beneficial. Impacts on infrastructure and 

6 community services would be SMALL except for short-term extension of MODERATE impacts 

7 on police and emergency services in Inglis and Dunnellon; fire-protection services in Levy 

8 County; and schools serving Inglis, Yankeetown, and Dunnellon. The review team determined 

9 that in the long term once local funding has been adjusted, all of these MODERATE impacts 

10 would reduce to SMALL. 

11 5.5 Environmental Justice 

12 The review team evaluated whether minority and low-income populations identified in Section 

13 2.6 of this EIS could experience disproportionately high and adverse impacts from the operation 

14 of two reactors at the proposed LNP site. In this evaluation, the review team also included 

15 populations of particular interest due to their unique characteristics. To perform this 

16 assessment, the review team used the same process described in Section 4.5. The review 

17 team reviewed the ER prepared by PEF and verified the data sources used in its preparation by 

18 examining cited references and by independently confirming data in discussions with community 

19 members and public officials (NRC 2009). To verify data in the ER, the review team requested 

20 clarifications and additional information from PEF as needed. Unless otherwise specified in the 

21 sections that follow, the review team has drawn upon verified data from PEF (2009a, c, e, i, j). 

22 Where the review team used different analytical methods or additional information for its own 

23 analysis, the sections include explanatory discussions and citations for additional sources. 

24 5.5.1 Health Impacts 

25 For all three health-related considerations, the review team determined through literature 

26 searches and consultations with NRC staff health physics experts that the expected operations27 related level of environmental emissions is well below the protection levels established by NRC 

28 and EPA regulations, and therefore cannot impose a disproportionately high and adverse 

29 radiological health effect on minority or low-income populations. 

30 The results of the normal operation dose assessments (see Section 5.9) indicate that the 

31 maximum individual dose for the pathways identified in Section 5.9 was found to be 

32 insignificant, that is, well below the NRC and EPA’s regulatory guidelines. Because there would 

33 be no significant adverse health impacts on the most exposed members of the public, there 

34 would be no disproportionately high and adverse health impacts on any minority and low35 income populations. Therefore the environmental justice impacts from operations would be 

36 minimal. 
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August 2010 5-74 Draft NUREG-1941 

1 As discussed in Section 5.8.5, nonradiological health impacts from emissions during the 

2 operation period on the public and onsite workers would be minimal. The review team has not 

3 found any environmental pathway that would lead to offsite nonradiological health effects that 

4 would create a disproportionately high and adverse impact on any minority or low-income 

5 populations. For example, any increase in traffic accidents due to heavier traffic is unlikely to 

6 have a disproportionately high and adverse impact on any particular population subgroup. 

7 Section 5.2.3 states the effects of Unit 1 and 2 discharges would be minimal on water quality. In 

8 addition, Section 5.8 found that health impacts on the public and workers from etiological 

9 agents, noise generated by plant operations, and acute impacts of EMF from power lines would 

10 be minimal. The review team reviewed available scientific literature on chronic effects of EMF 

11 on human health and found that the scientific evidence regarding the chronic effects of ELF12 EMF on human health does not conclusively link ELF-EMF to adverse health impacts. 

13 Furthermore, as discussed in Section 2.6.3, the review team did not identify any evidence of 

14 unique characteristics or practices in the minority and low-income populations that may result in 

15 health pathway impacts that are different from those of the general population. Therefore, the 

16 potential impacts of nonradiological effects resulting from the operation of the proposed two 

17 units would be minimal and there would be no disproportionately high and adverse impacts felt 

18 by minority or low-income populations within the analytical area. Therefore, the environmental 

19 justice impacts on health derived from operating the proposed units at LNP would be SMALL. 

20 5.5.2 Physical and Socioeconomic Impacts 

21 As shown in Figure 2-26, all census block groups with minority and low-income populations that 

22 meet the criteria discussed in Section 2.6 are located 10 mi or farther away from the LNP site. 

23 The closest minority populations (both aggregate and African-American) are in Citrus County 

24 between Citrus Springs and Dunnellon, approximately 10 mi from the site. The closest low25 income populations, near Otter Creek in Levy County, are almost 20 mi from the site. There are 

26 concentrations of block groups with African-American populations around the communities of 

27 Otter Creek, Usher, Chiefland, and Williston in Levy County between 20 and 30 mi from the site; 

28 around Ocala in Marion County, about 30 mi from the site; around Gainesville in Alachua 

29 County, about 45 mi from the site; and in the northwest corner of Sumter County, between 20 

30 and 30 mi from the site. (These are linear distances from the LNP site center; driving distances 

31 to all communities are greater). Some block groups with low-income populations of interest 

32 overlap with African-American populations of interest around Otter Creek, Usher, and Chiefland 

33 in Levy County and around Ocala (Marion County) and Gainesville (Alachua County). 

34 The review team determined that there would be no disproportionately high and adverse 

35 physical impacts on minority or low-income people within the identified census blocks. Distance 

36 from the site and intervening vegetation would mitigate physical impacts of operations on soil, 

37 water, noise, and air such that they would be minimal for all populations, including the minority 

38 and low-income populations closest to the site. 
Operational Impacts at the Proposed Site 

August 2010 5-75 Draft NUREG-1941 

1 The review team assessed socioeconomic impacts discussed in Section 5.4 to evaluate 

2 whether any operations-related activities could have a disproportionately high and adverse 

3 effect on minority or low-income populations. The review team determined that the physical 

4 effects of plant operations would be SMALL, with the exception of a continued MODERATE 

5 impact from the transmission lines and corridors. Economic, demographic, and tax impacts 

6 would be SMALL and beneficial except for Levy County where tax impacts would be LARGE 

7 and beneficial. Impacts on infrastructure and community services would be SMALL except for 

8 short-term extension of MODERATE impacts on police and emergency services in Inglis and 

9 Dunnellon; fire-protection services in Levy County; and schools serving Inglis, Yankeetown, and 

10 Dunnellon. The review team determined that in the long term once local funding has been 

11 adjusted, all of these MODERATE impacts would reduce to SMALL. 

12 As discussed in Section 2.6.2 of this EIS, the review team did not identify any evidence of 

13 unique characteristics or practices in minority or low-income communities that may result in 

14 socioeconomic impacts different from those on the general population. Therefore, the review 

15 team found no evidence that impacts on the minority and low-income populations in these 

16 instances would be disproportionately high and adverse as compared to other populations. 

17 Based on the above analysis, the review team determined that the environmental justice 

18 impacts from physical and socioeconomic sources would be minor. 

19 5.5.3 Subsistence and Special Conditions 

20 The NRC’s environmental justice methodology includes an assessment of populations with 

21 unique characteristics or practices; e.g., minority communities exceptionally dependent on 

22 subsistence resources or identifiable in compact locations, such as Native American settlements 

23 or high-density concentrations of minority populations. 

24 5.5.3.1 Subsistence 

25 Subsistence fishers and hunters, like recreational fishers and hunters, may choose to move to 

26 locations away from operations impacts for aesthetic or experience-based reasons, but such 

27 voluntary relocation would not be excessively burdensome given that other nearby locations are 

28 available. Consequently, because the review team did not identify any pathway that could lead 

29 to a disproportionately high and adverse impact on subsistence resource users, the review team 

30 concludes that there would be no such impacts related to subsistence activity among minority 

31 and low-income populations due to LNP operations. 
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August 2010 5-76 Draft NUREG-1941 

1 5.5.3.2 High-Density Communities 

2 As discussed in Section 2.6.2, the review team determined that there are no high-density 

3 communities within the vicinity of the LNP site or along any pathway that might lead to 

4 disproportionately high and adverse impacts. 

5 5.5.4 Summary of Environmental Justice Impacts 

6 The review team expects the physical impacts of plant operation on all populations in the region, 

7 including minority and low-income populations, would be SMALL because of their distance from 

8 the site. The adverse socioeconomic impacts on minority and low-income populations also are 

9 expected to be in proportion with the impacts discussed in Section 5.4 for the overall population 

10 and, therefore, are SMALL for most elements and MODERATE in the short term for education, 

11 police, emergency services, and fire protection in certain locations. The review team 

12 determined that in the long term once local funding has been adjusted, all of these MODERATE 

13 impacts would reduce to SMALL. In these locations, there is no evidence that impacts would be 

14 disproportionately high and adverse on minority or low-income populations or to communities 

15 with unique characteristics or practices. Based on the preceding analysis, the review team 

16 concludes that there are no disproportionately high and adverse impacts on minority and low17 income populations resulting from operation of LNP, and environmental justice impacts would 

18 be SMALL. 

19 5.6 Historic and Cultural Resources Impacts from 

20 Operations 

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

22 requires Federal agencies to take into account the potential impacts of their undertakings on the 

23 cultural environment, which includes archaeological sites, historic buildings, and traditional 

24 places important to local populations. The National Historic Preservation Act of 1966 (NHPA), 

25 also requires Federal agencies to consider impacts on those resources if they are eligible for 

26 listing in the National Register of Historic Places (NRHP or National Register) (such resources 

27 are referred to as “Historic Properties” in NHPA). As outlined in 36 CFR 800.8 (c), 

28 “Coordination with the National Environmental Policy Act of 1969,” the NRC is coordinating 

29 compliance with NHPA Section 106 to fulfill its responsibilities under NEPA. 

30 Operating new nuclear power plants can affect either known or potential historic properties that 

31 may be located at the site. In accordance with NHPA and NEPA provisions, the NRC and the 

32 USACE are required to make a reasonable and good faith effort to identify historic properties in 

33 the Areas of Potential Effect (APE) and, if such properties are present, determine whether 

34 significant impacts are likely to occur. Identification of historic properties is to occur in 

35 consultation with the State Historic Preservation Office (SHPO), Native American Tribes, 
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August 2010 5-77 Draft NUREG-1941 

1 interested parties, and the public. If significant impacts are possible, then efforts should be 

2 made to mitigate them. As part of the NEPA/NHPA integration, even if no historic properties 

3 (i.e., places eligible for listing in the National Register) are present or affected, the NRC and 

4 USACE are still required to notify the SHPO before proceeding. If it is determined that historic 

5 properties are present, the NRC and USACE are required to assess and resolve any adverse 

6 effects of the undertaking. 

7 For a description of the historic and cultural resources at the LNP site, see Section 2.7. PEF 

8 concluded that no known cultural resources exist within the direct or indirect APEs and issued a 

9 determination of “no historic properties affected” concurred with by the Florida SHPO (Florida 

10 SHPO 2008). 

11 PEF has procedures in place for informing managers and workers to stop work if cultural 

12 materials or human remains are inadvertently discovered during operations and to notify staff 

13 within the appropriate Environmental Support Organization (ESO) (PEF 2008c, 2009a). All 

14 work would be halted while the permitting specialist from within the ESO consults with the 

15 Florida SHPO. Any land-disturbing activity that affects a cultural resource would require a 

16 cultural resource assessment. In addition, if any area proposed for disturbance by construction 

17 is near known cultural resources, the appropriate staff within the ESO should be notified (PEF 

18 2008c). 

19 For the purposes of NHPA 106 consultation, based on (1) no known historic properties within 

20 the APEs, (2) the review team’s cultural resource analysis and consultation, (3) PEF’s 

21 commitment to follow its procedures if ground-disturbing or maintenance activities discover 

22 historic or cultural resources, and (4) PEF’s consultation with the Florida SHPO that concluded 

23 a finding of “no historic properties affected” (Florida SHPO 2008), the review team determines a 

24 finding of no historic properties affected (36 CFR Section 800.4(d)(1)). 

25 For the purposes of the review team’s NEPA analysis, based on (1) no known significant 

26 cultural resources within the APEs, (2) the review team’s cultural resource analysis and 

27 consultation, (3) PEF’s commitment to follow its procedures should ground-disturbing or 

28 maintenance activities discover historic or cultural resources, and (4) PEF’s consultation with 

29 the Florida SHPO that concluded a finding of “no historic properties affected” (Florida SHPO 

30 2008), the review team concludes that the impacts from operation would be SMALL. Mitigative 

31 actions may be warranted only if an unanticipated discovery is made during any ground32 disturbing activities associated with maintenance of the operating facility; these actions would 

33 be determined by PEF in consultation with the Florida SHPO. PEF has cultural resource 

34 management procedures in place (PEF 2008c). 
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August 2010 5-78 Draft NUREG-1941 

1 5.7 Meteorology and Air Quality Impacts 

2 The primary impacts of operation of two new nuclear units on local meteorology and air quality 

3 would be from releases to the environment of heat and moisture from the primary cooling 

4 system mechanical draft cooling towers, operation of auxiliary equipment (generators and 

5 boilers), and emissions from workers’ vehicles. The potential impacts of releases from 

6 operation of the cooling system are discussed in Section 5.7.2. Section 5.7.1 covers potential 

7 air quality impacts from nonradioactive effluent releases at the proposed LNP site, and 

8 Section 5.7.3 covers the potential air quality impacts of transmission lines during plant 

9 operation. 

10 5.7.1 Air Quality Impacts 

11 Standby diesel generators and auxiliary power systems would be used for emergency power 

12 and auxiliary steam purposes. These systems would be used on an infrequent basis and 

13 pollutants discharged (e.g., particulates, sulfur oxides, carbon monoxide, hydrocarbons, and 

14 nitrogen oxides [NOx]) would be permitted in accordance with Florida State and Federal 

15 regulatory requirements. 

16 A Prevention of Significant Deterioration (PSD) Permit application for the standby and auxiliary 

17 systems has been submitted to the State of Florida (FDEP 2009b). These systems include the 

18 following (PEF 2009a): 

19 four standby generators rated at 4000 kW 

20 four ancillary generators rated at 35 kW 

21 two diesel-driven fire pumps rated at 7571 Lpm 

22 two fuel oil storage tanks. 

23 Based on estimates provided by PEF (2008a), the annual release of criteria pollutants at the 

24 LNP related to the operation of the generators and fire pumps are listed in Table 5-7. 

25 Because these systems would be used on an infrequent basis (i.e., typically 4 hours per month), 

26 the staff concludes the environmental impact of the pollutants from these sources would be 

27 minimal, and additional mitigation would not be warranted. 

28 Finally, the operation of a nuclear power plant involves the emission of some greenhouse 

29 gases, primarily carbon dioxide (CO2). The review team has estimated that the total carbon 

30 footprint for actual plant operations of LNP Units 1 and 2 for 40 years is of the order of 

31 280,000 MT of CO2 equivalent, as compared to a total U.S. annual CO2 emissions rate of 

32 6,000,000,000 MT (EPA 2010b). Workforce transportation accounts for about 90 percent of the 
Operational Impacts at the Proposed Site 

August 2010 5-79 Draft NUREG-1941 

1 Table 5-7. Regulated Source Emissions (lb/yr) 

Source PM(a) SOx

(b), CO(c)

 VOC(d) NOx

(e)

 CO2

(f)

Four standby generators(g) 2168 111 6645 2518 30,848 1,147,171 

Four ancillary generators(g) 33 1.6 101 38 467 17,381 

Two fire pumps(g)

 136 6.4 415 157 1928 71,698 

Source: PEF 2009a 

(a) PM = particulate matter. 

(b) SOx = oxides of sulfur. 

(c) CO = carbon monoxide. 

(d) VOC = volatile organic compounds. 

(e) NOx = oxides of nitrogen. 

(f) CO2 = carbon dioxide. 

(g) Assumes 4 hours per month operation for each generator or fire pump and Number 2 diesel fuel with sulfur 

content of 0.05 percent.

2 total. Periodic testing of diesel generators accounts for most of the rest. These estimates are 

3 based on carbon footprint estimates in Appendix I and emissions data contained in the ER (PEF 

4 2009a). Based on its assessment of the relatively small plant operations carbon footprint 

5 compared to the U.S. annual CO2 emissions, the review team concludes that the atmospheric 

6 impacts of greenhouse gases from plant operations would not be noticeable, and additional 

7 mitigation would not be warranted. 

8 The review team has considered the timing and magnitude of atmospheric releases related to 

9 operation of proposed Units 1 and 2, the existing air quality at the LNP site and the distance to 

10 the closest Class I Federal Area, and PEF’s commitment to manage and mitigate emissions in 

11 accordance with applicable regulations. On these bases, the review team concludes that the air 

12 quality impacts of operation of proposed LNP Units 1 and 2 would not be noticeable. Based on 

13 its assessment of the carbon footprint of plant operations, the review team concludes that the 

14 atmospheric impacts of greenhouse gases from plant operations would be insignificant. 

15 5.7.2 Cooling-System Impacts 

16 The proposed cooling system for the LNP site consists of two mechanical draft cooling towers 

17 associated with the CWS and two smaller mechanical draft cooling towers associated with the 

18 service-water system. Mechanical draft cooling towers remove excess heat by evaporating 

19 water. Upon exiting the cooling tower, water vapor mixes with the surrounding air, and this 

20 process can lead to condensation and the formation of a visible plume. Aesthetic impacts from 

21 the visible plume; land-use impacts from cloud shadowing, fogging, icing, increased humidity; 

22 and drift from dissolved salts and chemicals found in the cooling water can result. 

23 The EPA-approved CALPUFF model was selected to estimate the visual impacts associated 

24 with operating the cooling towers. One year of data (January 1 through December 31, 2003) 

25 collected at Gainesville, Florida, was used as input to the CALPUFF model. The analysis 
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August 2010 5-80 Draft NUREG-1941 

1 indicates that the vast majority (nearly 98 percent) of all plumes would be less than 100 m in 

2 length and rise less than 200 m (PEF 2009a) regardless of the season. In general, the longest 

3 plumes would occur in the summer and fall. Plumes extending 5000 m or more are expected to 

4 occur during approximately 1.7 percent of the total summer and fall hours. The largest plume 

5 rise would also occur in the summer, with plumes that rise 400 m or more occurring during 

6 approximately 0.3 percent of the total hours. Ground-level fogging or icing was limited to 

7 locations within 1000 m of the cooling towers. The towers are approximately 1400 m from the 

8 nearest roadway (US-19), so ground-level fogging is not expected to affect local roads. 

9 The particulate matter emissions from the cooling towers consist of naturally occurring dissolved 

10 solids that originate with the cooling water removed from the CFBC. The concentration of TDS 

11 in the CFBC is assumed to be 25 ppt and consist of only salts. On average, the salinity of the 

12 world’s oceans is 35 ppt (ONR 2009), but the salinity of the CFBC is reduced by flow from Lake 

13 Rousseau and other tributaries. Water leaves the cooling towers as either pure water vapor or 

14 as small water drops. These drops are referred to as “cooling-tower drift,” and drift eliminators 

15 are used to limit the drift to 0.0005 percent of the water flowing through the cooling towers. 

16 Emission of particulate matter and salt deposition only occur for water drops that escape from 

17 the cooling towers as drift. In operation, the cooling towers will evaporate up to 1,682,400 gph 

18 (PEF 2009a). This water will leave the cooling towers as pure water vapor. In comparison, the 

19 total amount of dissolved solids that could leave the cooling towers as drift is estimated to be 

20 115.7 lb/hr during normal operations and 154.26 lb/hr during short-duration excursions. The 

21 particulate matter emissions from the cooling towers would be classified by the State of Florida 

22 as a major source because emissions would exceed the State’s threshold of 100 T/yr. A PSD 

23 Permit for air emissions has been prepared and submitted to the State (PEF 2009a). An 

24 analysis of the deposition of salts from the cooling-tower drift was conducted using the EPA25 approved AERMOD model and 5 years of surface data collected at Gainesville and upper air 

26 observations from Jacksonville, Florida. Using the source terms described and the AERMOD 

27 results, the maximum predicted offsite deposition rate during normal operations is 6.81 

28 kg/ha/mo at a location west of the cooling towers. The salt deposition decreases rapidly with 

29 distance from the plant. The maximum predicted onsite deposition is 10.75 kg/ha/mo. 

30 Deposition rates between 1 and 2 kg/ha/mo are normally not damaging to plants, while rates 

31 approaching 10 kg/ha/mo can cause leaf damage (NRC 2000a). The terrestrial ecological 

32 impacts due to salt deposition associated with cooling tower drift are discussed in more detail in 

33 section 5.3.1.1 of this EIS. 

34 5.7.3 Transmission-Line Impacts 

35 The impacts of existing transmission lines on air quality are addressed in the Generic 

36 Environmental Impact Statement for License Renewal (NRC 1996). Small amounts of ozone 

37 and even smaller amounts of NOx are produced by transmission lines. The production of these 

38 gases was found to be insignificant for 745-kV transmission lines (the largest lines in operation) 
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1 and for a prototype 1200-kV transmission line. In addition, it was determined that potential 

2 mitigation measures, such as burying transmission lines, would be costly and not warranted. 

3 Up to four new 500-kV transmission lines would be constructed to accommodate the new 

4 power-generating capacity (PEF 2009a). This size is well within the range of transmission lines 

5 provided in the GEIS. On this basis, the staff concludes that air quality impacts from 

6 transmission lines would be minimal, and additional mitigation would not be warranted. 

7 5.7.4 Summary of Meteorology and Air Quality Impacts 

8 The review team evaluated potential impacts on air quality associated with criteria pollutants 

9 and greenhouse gas emissions from operating LNP Units 1 and 2. The review team also 

10 evaluated potential impacts of cooling-system emissions and transmission lines. In each case, 

11 the review team determined that the impacts would be minimal. On this basis, the review team 

12 concludes that the impacts of operation of LNP Units 1 and 2 on air quality from emissions of 

13 criteria pollutants, CO2 emissions, cooling-system emissions, and transmission line impacts 

14 would be SMALL, and no further mitigation would be warranted. 

15 5.8 Nonradiological Health Impacts 

16 This section addresses the nonradiological human health impacts on the public and workers 

17 from operating the proposed new nuclear Units 1 and 2 at the LNP site. Nonradiological public 

18 health impacts are considered from operation of the cooling system, noise generated by 

19 operations, EMF, and transporting materials and personnel to the site. Nonradiological health 

20 impacts from the same sources are also evaluated for workers during the operation of proposed 

21 Units 1 and 2. Section 2.10 provides background information on the affected environment and 

22 nonradiological health at and within the vicinity of the LNP site. Health impacts from radiological 

23 sources during operations are discussed in Section 5.9. 

24 5.8.1 Etiological Agents 

25 Operation of proposed LNP Units 1 and 2 would result in a thermal discharge through the CREC 

26 to the Gulf of Mexico (PEF 2009a). The staff investigated the possibility of the thermal 

27 discharges to increase the growth of thermophilic microorganisms, including those that can 

28 cause diseases (etiological agents), in both the CWS and the Gulf of Mexico. In addition, 

29 growth of thermophilic organisms in the cooling tower might pose a health risk during 

30 occupational exposures. As discussed in Section 2.10.1.3, the types of organisms of concern 

31 include enteric pathogens (such as Salmonella spp., Pseudomonas aeruginosa, and Shigella 

32 sonnei), thermophilic fungi, bacteria (such as Legionella spp. and Vibrio spp.), and free-living 

33 amoeba (such as Naegleria fowleri and Acanthamoeba spp.). These microorganisms could 

34 result in potentially serious human health concerns, particularly at high exposure levels (NRC 

35 1996). 
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1 The discharge of blowdown water to the CREC is expected to have minimal effects on the total 

2 thermal discharge to the Gulf of Mexico. The discharge volume from the proposed LNP would 

3 contribute only 4.4 percent of the total discharge flow, and the temperature of the LNP 

4 blowdown actually would be slightly below the average temperature of the current CREC 

5 discharge (PEF 2009a, i). In addition, recreational exposure to thermophilic organism in the 

6 discharge from the CREC is likely to be minimal because access to the discharge channel is 

7 strictly limited by buoys and barricades, and the restriction is enforced by armed guards. No 

8 fishing or shellfishing is allowed near the discharge channel (PEF 2009i).

9 Because the addition of the proposed LNP discharge to the CREC is expected to have minimal 

10 impact on the temperature of the discharge plume and due to significant physical and 

11 administrative barriers to prevent contact with blowdown, the potential for human exposure to 

12 thermophilic organisms from operation of the proposed LNP is low. Thus, the staff concludes 

13 that the impacts of thermal discharges from proposed LNP Units 1 and 2 on human health 

14 would be minimal, and mitigation would not be warranted. 

15 5.8.2 Noise 

16 In NUREG-1437 (NRC 1996), the staff discusses the environmental impacts of noise at existing 

17 nuclear power plants. Common sources of noise from plant operation include cooling towers 

18 and transformers with intermittent contributions from loud speakers and auxiliary equipment, 

19 such as diesel generators. 

20 The primary sources of noise from proposed LNP Units 1 and 2 operations would be the 

21 mechanical draft cooling towers and circulating-water pumps 

22 CWIS makeup-water pump house that would be located adjacent to the CFBC, 

23 approximately 3.5 mi south of the center of the main plant site near County Road (CR) 40. 

24 The Levy County Noise Ordinance (Levy County Code 50-349) limits sound levels experienced 

25 by offsite receptors due to industrial activities. For residential, rural agricultural, and commercial 

26 districts, the maximum allowable noise level at the property line is 65 dBA for the hours between 

27 7:00 a.m. to 10:00 p.m. For industrial districts, the maximum allowable noise level is 75 dBA at 

28 all times. Allowable noise limits are lower from 10:00 p.m. to 7:00 a.m. in residential areas 

29 (55 dBA) and rural districts (60 dBA). 

30 As discussed in Section 4.8.2, a noise assessment of the proposed LNP site was performed in 

31 support of the LNP’s Site Certification Application to the State of Florida to estimate overall 

32 noise impacts of facility operation and assess compliance with the Levy County Noise 

33 Ordinance. As part of this assessment, the sources of noise evaluated included the main plant 

34 components, namely the cooling towers and the cooling-system makeup-water pump house 

35 located near the CFBC. The closest noise-sensitive receptors were identified as being the 
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1 residences located approximately 1.6 mi to the northwest and 1.7 mi to the west-southwest of 

2 the center of the project site (PEF 2009a). 

3 Modeling of cooling-tower operations predicted noise impacts in the range of 25 to 28 dBA 

4 attributable to normal plant operation at these locations. The noise analysis also predicted that 

5 offsite noise levels from the cooling towers would not approach or exceed the noise limitations 

6 established by the Levy County Noise Ordinance (65 dBA for daytime hours and 55 dBA for 

7 nighttime hours in rural and residential areas). 

8 Noise levels in publicly accessible areas from the CWIS makeup-water pump house were also 

9 modeled. Noise impacts from the proposed plant and pump house are not expected to be 

10 significant at the nearest residences or at the closest recreational areas (Crystal River Preserve 

11 State Park and Goethe State Forest) except in the immediate vicinity of the pump house. All 

12 estimated noise impacts (even near the pump house) were below Levy County standards (PEF 

13 2009a). 

14 PEF anticipates that four 500-kV transmission lines would service the proposed LNP 

15 (PEF 2009a). For 500-kV transmission lines, corona noise, when present, is typically below 

16 ambient outdoor levels. During rain showers, the corona noise likely would not be readily 

17 distinguishable from background noise. During very moist but not rainy conditions, such as 

18 heavy fog, the resulting small increase in the background noise levels would not be expected to 

19 result in annoyance to adjacent residents. Periodic maintenance activities, particularly 

20 vegetation management, would produce noise from mowing, bush-hogging, and tree and limb 

21 trimming and grinding (PEF 2009a). 

22 As discussed in Section 4.8.2, noise levels below 60 to 65 dBA are considered to be of small 

23 significance (NRC 1996, 2002). Based on the relatively low levels of noise associated with the 

24 operation of the proposed LNP Units 1 and 2 and transmission lines, the significant attenuation 

25 of that noise, and that the postulated noise levels from the cooling towers and CWIS intake 

26 pump house are all in compliance with the Levy County Noise Ordinance, the review team 

27 concludes that potential noise impacts associated with the operation of the new units on the 

28 public would be minor and would not require mitigation. 

29 5.8.3 Acute Effects of Electromagnetic Fields 

30 In its ER, PEF states that four 500-kV transmission lines would service the proposed LNP 

31 (PEF 2009a). Electric shock resulting from either direct access to energized conductors or 

32 induced charges in metallic structures is an example of an acute effect from EMF associated 

33 with transmission lines (NRC 1996). PEF has evaluated electric shock potential of template 

34 500-kV lines built to present National Electric Safety Code (NESC) standards. Three scenarios 

35 involving different vehicle sizes were evaluated to determine maximum induced current as a 

36 function of distance from different types of transmission-tower/line configurations. The results of 
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1 the calculations are used to assure that the transmission lines, as installed, would comply with 

2 the 5-mA standard in the present NESC (PEF 2009a). 

3 The transmission lines would also be designed to comply with the FDEP regulations (Fla. 

4 Admin. Code Rule 62-814.450(3)) limiting maximum electrical and magnetic field strength 

5 (FDEP 2010): 

6 The maximum electric field at the edge of the transmission-line corridor and at the new 

7 substation property boundary shall not exceed 2 kV/m. 

8 The maximum electric field on the transmission-line corridor shall not exceed 10 kV/m. 

9 The maximum magnetic field at the edge of the transmission-line right-of-way and at the 

10 new substation property boundary shall not exceed 200 milliGauss (mG). 

11 Based on PEF’s commitment to design new transmission lines to ensure that the present NESC 

12 criteria are met for all of the anticipated transmission-line configurations for the proposed LNP, 

13 the staff concludes that the impact on the public from acute effects of EMFs would be minimal, 

14 and additional mitigation would not be warranted. 

15 5.8.4 Chronic Effects of Electromagnetic Fields 

16 Operating power transmission lines in the United States produce an EMF of nonionizing 

17 radiation at 60 Hz, which is considered to be an extremely low frequency (ELF) EMF. Research 

18 on the potential for chronic effects of EMF from energized transmission lines was reviewed and 

19 addressed by the NRC in NUREG-1437 (NRC 1996). At that time, research results were not 

20 conclusive. The National Institute of Environmental Health Sciences (NIEHS) directs related 

21 research through the U.S. Department of Energy (DOE). An NIEHS report (NIEHS 1999) 

22 contains the following conclusion: 

23 “The NIEHS concludes that ELF-EMF exposure cannot be recognized as entirely safe 

24 because of weak scientific evidence that exposure may pose a leukemia hazard. In our 

25 opinion, this finding is insufficient to warrant aggressive regulatory concern. However, 

26 because virtually everyone in the United States uses electricity and therefore is routinely 

27 exposed to ELF-EMF, passive regulatory action is warranted such as a continued 

28 emphasis on educating both the public and the regulated community on means aimed at 

29 reducing exposures. The NIEHS does not believe that other cancers or non-cancer 

30 health outcomes provide sufficient evidence of a risk to currently warrant concern.” 

31 The review team reviewed available scientific literature on chronic effects on human health from 

32 ELF-EMF published since the NIEHS report and found that several other organizations reached 

33 the same conclusions (AGNIR 2006; WHO 2007). Additional work under the auspices of the 

34 World Health Organization (WHO) updated the assessments of a number of scientific groups 

35 reflecting the potential for transmission-line EMF to cause adverse health impacts in humans. 
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1 In the report by WHO, the authors summarized the potential for ELF-EMF to cause diseases, 

2 such as cancers in children and adults, depression, suicide, reproductive dysfunction, 

3 developmental disorders, immunological modifications, and neurological disease. The results of 

4 the review by WHO found that the extent of scientific evidence linking these diseases to EMF 

5 exposure is not conclusive (WHO 2007). 

6 The review team reviewed available scientific literature on chronic effects of EMF on human 

7 health and found that the scientific evidence regarding the chronic effects of ELF-EMF on 

8 human health does not conclusively link ELF-EMF to adverse health impacts. 

9 5.8.5 Occupational Health 

10 As discussed in Section 2.10, human health risks for personnel engaged in activities such as 

11 maintenance, testing, and plant modifications for LNP Units 1 and 2 are expected to be 

12 dominated by occupational accidents (e.g., falls, electric shock, or burns) or occupational 

13 illnesses due to noise exposure, exposure to toxic or oxygen-replacing gases, and other 

14 hazards. The 2008 annual incidence rate (the number of injuries and illnesses per 100 full-time 

15 workers) for electric power generation, transmission, and distribution workers in the United 

16 States was 3.2 (BLS 2010). The 2008 national annual illness and injury rate for nuclear electric 

17 power generation workers was 0.7 (BLS 2010). Assuming a total operations workforce of 773 

18 (PEF 2009a), this suggests that operation of LNP Units 1 and 2 would be associated with 

19 approximately 5 occupational injuries and illnesses per year. However, as was the case for 

20 construction injury estimates in Section 4.8, these are gross estimates that do not take into 

21 account injury risks that workers would face if they were employed somewhere other than the 

22 LNP. The net effect of LNP operation on total occupational injuries in Levy County could be 

23 considerably lower, or even negative, if alternative employment is associated with higher risks. 

24 Occupational injury and fatality risks are reduced by strict adherence to NRC and OSHA safety 

25 standards (29 CFR Part 1910), practices, and procedures. These safe work practices address 

26 a number of occupational health issues (e.g., hearing protection; confined space entry; personal 

27 protective equipment; heat stress; electrical safety; the safe use of ladders; chemical handling, 

28 storage, and use; and other industrial hazards). PEF states that it will adhere to NRC, OSHA, 

29 and State safety standards, practices, and procedures during new nuclear unit operations 

30 (FDEP 2010). 

31 Additional occupational health impacts may result from exposure to hazards such as noise, toxic 

32 or oxygen-replacing gases, thermophilic microorganisms in the condenser bays, and caustic 

33 agents. PEF indicates that (1) workers potentially exposed to thermophilic organisms during 

34 maintenance activities would use respiratory protection (PEF 2008a), and (2) it would comply 

35 with applicable Federal standards and with its own internal corporate procedures to ensure 

36 proper management of hazardous wastes and assure worker safety (PEF 2008a). 
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1 Based on mitigation measures identified by PEF in its ER; strict adherence to NRC and OSHA 

2 safety standards, practices, and procedures; and the review team’s independent evaluation, the 

3 review team concludes that occupational health impacts on LNP onsite personnel would be 

4 minimal, and no further mitigation would be warranted. 

5 5.8.6 Impacts of Transporting Operations Personnel to and from the Proposed 

6 Site 

7 This EIS assesses the impact of transporting workers to and from the LNP site from the 

8 perspective of three areas of impact: (1) the socioeconomic impacts, (2) the air quality impacts 

9 of fugitive dust and particulate matter emitted by vehicle traffic, and (3) the potential health 

10 impacts related to additional traffic-related accidents. Human health impacts are addressed in 

11 this section, while the socioeconomic impacts are addressed in Section 5.4.1.3, and air quality 

12 impacts are addressed in Section 5.7.1. 

13 

14 The general approach used to calculate the nonradiological impacts of fuel and waste 

15 shipments is the same as that used to calculate the impacts of transporting operations and 

16 outage personnel to and from the proposed LNP site (see Section 4.8.3 of this EIS). However, 

17 preliminary estimates are the only data available to estimate these impacts. The impacts 

18 evaluated in this section for two new nuclear generating units at the LNP site are appropriate to 

19 characterize the alternative sites discussed in Section 9.3 of this EIS. Alternative sites 

20 evaluated in this EIS include Crystal River in Citrus County, Dixie in Dixie County, Highlands in 

21 Highlands and Glades counties, and Putnam in Putnam County. There is no meaningful 

22 differentiation among the proposed and alternative sites regarding the nonradiological 

23 environmental impacts from transporting operations and outage personnel to the LNP site and 

24 alternative sites, and these issues are not discussed further in Chapter 9. 

25 The assumptions made by the review team to provide reasonable estimates of the parameters 

26 needed to calculate nonradiological impacts are listed below. 

27 The total number of workers estimated for operation of the proposed LNP site was 

28 estimated to be 800 for two Westinghouse AP1000 pressurized water reactor units (Kimley29 Horn 2009). An additional 800 temporary workers are estimated to be needed for refueling 

30 outages (Kimley-Horn 2009), which would occur at 18-month intervals for each AP1000 unit. 

31 The staff assumed that outages for the two units would not occur simultaneously. However, 

32 the staff assumed that two outages could occur during the same year. 

33 The average commuting distance for operations and outage workers was conservatively 

34 assumed by the review team to be 20 mi one way, based on U.S. Department of 

35 Transportation (DOT) data that estimates that the typical commute is 16 mi (DOT 2003). 
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1 To develop representative commuter traffic impacts, data from the Florida Department of 

2 Highway Safety and Motor Vehicles provides Florida-specific accident, injury, and fatality 

3 rates for the years 2003 to 2007 (FLHSMV 2007). 

4 The estimated impacts of transporting operations and outage workers to and from the proposed 

5 LNP site and alternative sites are listed in Table 5-8. The total annual traffic fatalities during 

6 operations, including both operations and outage personnel, represent about a 0.6 percent 

7 increase above the average 17 traffic fatalities per year that occurred in Levy County, Florida, 

8 from 2003 to 2007 (FLHSMV 2007). The impacts of transporting operations and outage 

9 workers to and from the alternatives sites were about a 0.4 percent increase for the Crystal 

10 River site in Citrus County, a 1-percent increase for the Dixie site in Dixie County, a 0.5- to 2-

11 percent increase for the Highland site in Highland and Glades Counties, and a 0.5 percent 

12 increase for the Putnam site in Putnam County. These percentages represent negligible 

13 increases relative to the current traffic fatality risks in the areas surrounding the proposed LNP 

14 site and alternative sites. 

15 Table 5-8. Nonradiological Impacts of Transporting Workers to and from the Proposed 

16 LNP Site for Two Reactors 

Accidents Per 

Year 

Injuries Per 

Year 

Fatalities Per 

Year 

Permanent workers 6.8 × 100 5.9 × 100 8.8 × 102

Outage workers 1.6 × 100 1.4 × 100 2.1 × 102

17 Based on the information provided by PEF, the review team’s independent evaluation, and 

18 considering this increase would be negligible relative to the current traffic fatalities (i.e., before 

19 the proposed units are constructed) in the affected counties, the review team concludes that the 

20 nonradiological impacts of transporting operations and outage workers to the proposed LNP site 

21 and alternative sites would be minimal, and mitigation would not be warranted. 

22 5.8.7 Summary of Nonradiological Health Impacts 

23 The review team evaluated health impacts on the public and workers from the proposed cooling 

24 system, noise generated by plant operations, acute and chronic impacts of EMFs, and 

25 transporting operations and outage workers to and from the proposed LNP Units 1 and 2. 

26 Health risks to workers are expected to be dominated by occupational injuries at rates below the 

27 average U.S. industrial rates. Health impacts on the public and workers from etiological agents, 

28 noise generated by plant operations, and acute impacts of EMF would be minimal. The review 

29 team reviewed available scientific literature on chronic effects of EMF on human health and 

30 found that the scientific evidence regarding the chronic effects of ELF-EMF on human health 

31 does not conclusively link ELF-EMF to adverse health impacts. Based on the information 

32 provided by PEF and the review team’s independent evaluation, the review team concludes that 
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1 the potential impacts on nonradiological health resulting from the operation of the proposed LNP 

2 Units 1 and 2 would be SMALL, and mitigation would not be warranted. 

3 5.9 Radiological Impacts of Normal Operations 

4 This section addresses the radiological impacts of normal operations of proposed LNP Units 1 

5 and 2, including a discussion of the estimated radiation dose to a member of the public and to 

6 the biota inhabiting the area around the LNP site. Estimated doses to workers at Units 1 and 2 

7 are also discussed. Radiological impacts were determined using the Westinghouse AP1000 

8 reactor design with expected direct radiation and liquid and gaseous radiological effluent rates 

9 in the evaluation (see discussion in Section 3.2.1). 

10 Revision 15 of the AP1000 design (Westinghouse 2005) is a certified design as set forth in 

11 10 CFR Part 52, Appendix D. Subsequently, Westinghouse submitted Revisions 16 and 17 of 

12 the AP1000 design. Revision 1 of the PEF ER incorporates Revision 17 of the Design Control 

13 Document (DCD). Therefore, the COL application and evaluation of radiological impacts of 

14 normal operations presented here are based on Revision 17 of the DCD (Westinghouse 2008). 

15 5.9.1 Exposure Pathways 

16 The public and biota would receive radiation dose from a nuclear unit via the liquid effluent, 

17 gaseous effluent, and direct radiation pathways. PEF estimated the potential exposures to the 

18 public and biota by evaluating exposure pathways typical of those surrounding a nuclear unit at 

19 the LNP site. PEF considered pathways that could cause the highest calculated radiological 

20 dose based on the use of the environment by the residents located around the site (PEF 

21 2009a). For example, factors such as the location of homes in the area, consumption of meat 

22 from the area, and consumption of vegetables grown in area gardens were considered. 

23 For the liquid effluent release pathway, the ER considered the following exposure pathways in 

24 evaluating the dose to the maximally exposed individual (MEI): ingestion of aquatic food 

25 (i.e., fish and invertebrates), direct radiation exposure from shoreline activities, and swimming 

26 and boating exposure. The analysis for population dose considered the following exposure 

27 pathways: ingestion of aquatic food and direct radiation exposure from shoreline activities, 

28 swimming, and boating. PEF plans to release liquid effluents into the Gulf of Mexico at the end 

29 of the CREC Unit 3 discharge canal. The MEI and the population within 50 mi of the proposed 

30 LNP Units 1 and 2 do not consume drinking water from the Gulf of Mexico; therefore, doses 

31 associated with the drinking water pathway were not evaluated (PEF 2009a). 

32 For the gaseous effluent release pathway, PEF considered the following exposure pathways in 

33 evaluating the dose to the MEI: immersion in the radioactive plume, direct radiation exposure 

34 from deposited radioactivity, inhalation, ingestion of garden fruit and vegetables, and ingestion 
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1 of beef. PEF (2009a) calculated a dose from goat milk but not cow milk ingestion because the 

2 most recent land-use census indicated that no milk cows existed within 5 mi of the site. 

3 For population doses from the gaseous effluents, PEF (2009a) used the same exposure 

4 pathways used for the individual dose assessment – with the addition of the cow milk ingestion 

5 pathway. All agricultural products grown within 50 mi of LNP Units 1 and 2 were assumed to be 

6 consumed by the population dose within 50 mi of the proposed LNP site (see Figure 5-9). 

7 PEF (2009a) states that direct radiation from the reactor buildings would be the primary sources 

8 of direct radiation exposure to the public from the LNP site. However, PEF assumes that 

9 contained sources of radiation at the LNP site would be shielded and provide a negligible 

10 contribution to the external dose of the MEI or the population. The assumption of negligible 

11 contribution from direct radiation beyond the site boundary is supported by the DCD 

12 (Westinghouse 2008). The direct radiation from the containment and other plant buildings 

13 would be negligible. The AP1000 design also provides for the storage of refueling water inside 

14 the containment building instead of in an outside storage tank; that eliminates it as a radiation 

15 source. The NRC staff concurs that the doses from direct radiation at the site boundary would 

16 be negligible. 

17 Exposure pathways considered in evaluating dose to biota are shown in Figure 5-10 and include 

18 the following: 

19 ingestion of aquatic foods 

20 ingestion of water 

21 external exposure from water immersion and shoreline sediments 

22 inhalation of airborne radionuclides 

23 external exposure to immersion in gaseous effluent plumes 

24 surface exposure from deposition of iodine and particulates from gaseous effluents (NRC 

25 1977). 

26 The NRC staff reviewed the exposure pathways for the public and non-human biota identified by 

27 PEF and found them to be appropriate, based on a documentation review and a tour of the 

28 environs with PEF staff and contractors during the site visit in December 2008. 

29 5.9.2 Radiation Doses to Members of the Public 

30 PEF calculated the dose to the MEI and the population living within a 50-mi radius of the site 

31 from both the liquid and gaseous effluent release pathways (PEF 2009a). As discussed in 

32 Section 5.9.1, direct radiation exposure to the MEI from sources of radiation at the LNP Units 1 

33 and 2 would be negligible. 
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1 

2 

3 Figure 5-9. Exposure Pathways to Man (adapted from Soldat et al. 1974) 
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1 

2 Figure 5-10. Exposure Pathways to Biota Other Than Man (adapted from Soldat et al. 1974) 
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1 5.9.2.1 Liquid Effluent Pathway 

2 Liquid pathway doses were calculated using the LADTAP II computer program (Strenge et al. 

3 1986). Fish consumption and recreational usage were considered in the PEF dose calculations 

4 (PEF 2009a). 

5 The liquid effluent releases used in the estimates of dose are found in Table 5.4-1 of the ER 

6 (PEF 2009a). Other parameters used as inputs to the LADTAP II program, including liquid 

7 pathway consumption and usage factors (i.e., fish consumption and recreational usage), are 

8 found in Tables 5.4-1 and 5.4-2 of the ER (PEF 2009a). PEF calculated liquid pathway doses to 

9 the MEI as shown in Table 5-9. 

10 Table 5-9. Annual Doses to the Maximally Exposed Individual for Liquid Effluent Releases 

11 from a New Unit

Pathway 

Age Group/ 

MEI 

Total Body 

(mrem/yr) 

Maximum Organ 

(GI-LLI)(a)

(mrem/yr) 

Thyroid 

(mrem/yr) 

Fish Adult 0.0027 0.0089 0.0056 

 Teen 0.0018 0.0064 0.0051 

 Child 0.0012 0.0026 0.0052 

Invertebrate Adult 0.0013 0.062 0.0058 

 Teen 0.0012 0.049 0.0054 

 Child 0.0012 0.021 0.0058 

Shoreline Adult 0.00039 0.00039 0.00039 

 Teen 0.0022 0.0022 0.0022 

 Child 0.00045 0.00045 0.00045 

Swimming Adult 0.0000019 0.0000019 0.0000019 

 Teen 0.000010 0.000010 0.000010 

 Child 0.0000022 0.0000022 0.0000022 

Boating Adult 0.0000079 0.0000079 0.0000079 

 Teen 0.0000053 0.0000053 0.0000053 

 Child 0.0000011 0.0000011 0.0000011 

Source: LADTAP II Output File (PEF 2009i) 

(a) GI-LLI is the gastrointestinal tract-lower large intestine. 

12 The staff recognizes the LADTAP II computer program as an appropriate method for calculating 

13 dose to the MEI for liquid effluent releases. The staff concluded that all of the input parameters 

14 used in the PEF calculation were appropriate. The staff performed an independent evaluation 
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1 of liquid pathway doses using input parameters from the ER and found similar results. The 

2 results of the staff's independent evaluation are found in Appendix J. 

3 5.9.2.2 Gaseous Effluent Pathway 

4 PEF calculated gaseous pathway doses to the MEI using the GASPAR II computer program 

5 (Strenge et al. 1987) at the nearest residence, the exclusion area boundary, the nearest garden, 

6 milk goat, and meat cow. The GASPAR II computer program was also used to calculate annual 

7 population doses. The following activities were considered in the dose calculations: (1) direct 

8 radiation from immersion in the gaseous effluent cloud and from particulates deposited on the 

9 ground, (2) inhalation of gases and particulates, (3) ingestion of meat from animals eating 

10 contaminated grass, and (4) ingestion of garden vegetables contaminated by gases and 

11 particulates. PEF (2009a) indicates that milk goats, but not milk cows, are located within 5 mi of 

12 the proposed site. PEF calculated MEI doses for the goat milk pathway; but PEF included cow 

13 milk pathway for the calculation of population dose. The gaseous effluent releases used in the 

14 estimate of dose to the MEI and population are found in Table 11.3-3 of the Westinghouse 

15 AP1000 DCD Revision 17 (Westinghouse 2008). Other parameters used as inputs to the 

16 GASPAR II program, including population data, atmospheric dispersion factors, ground17 deposition factors, receptor locations, and consumption factors, are found in Tables 5.4-3 and 

18 5.4-4 of the ER (PEF 2009a). PEF calculated the MEI dose by combining the plume, ground, 

19 and inhalation pathways at the nearest residence with the milk goat, meat, and vegetable 

20 garden ingestion pathways at the locations with the highest doses. The goat-milk pathway 

21 provides a higher dose than the cow-milk pathway at any given location and therefore is more 

22 conservative for this analysis. Gaseous pathway doses for a single unit are shown in 

23 Table 5-10. 

24 The NRC staff recognizes the GASPAR II computer program as an appropriate tool for 

25 calculating dose to the MEI and population from gaseous effluent releases. The NRC staff 

26 reviewed the input parameters and values used by PEF and concluded that the parameters 

27 used by PEF were appropriate. The NRC confirmed the dose calculations using the information 

28 contained in the ER. The staff performed an independent evaluation of gaseous pathway doses 

29 and obtained similar results for the MEI. The NRC staff’s evaluation is presented in Appendix J. 

30 5.9.3 Impacts on Members of the Public 

31 This section describes the staff’s evaluation of the estimated impacts from radiological releases 

32 and direct radiation of the proposed two new units at the LNP site. The evaluation addresses 

33 dose from operations to the MEI located at the LNP site and the population dose (collective 

34 dose to the population within 50 mi) around the LNP site. 
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August 2010 5-94 Draft NUREG-1941 

1 Table 5-10. Annual Individual Doses to the Maximally Exposed Individual from Gaseous 

2 Effluents for a New Unit 

Pathway 

Age 

Group 

Total Body 

Dose(a)

(mrem/yr) 

Max Organ 

(Bone) 

(mrem/yr) 

Skin Dose(b)

(mrem/yr) 

Thyroid 

Dose(a)

(mrem/yr) 

Plume 

(0.83 mi westsouthwest [WSW]) 

All 0.985 0.985 6.32 0.985 

Ground 

(0.83 mi WSW) 

All 0.114 0.114 0.133 0.114 

Goat Milk 

(2.4 mi northnorthwest) 

Adult 

Teen 

Child 

Infant 

0.0253 

0.0404 

0.0867 

0.170 

0.0770 

0.141 

0.347 

0.673 

NA 

NA 

NA 

NA 

0.155 

0.246 

0.497 

1.17 

Inhalation 

(0.83 mi WSW) 

Adult 

Teen 

Child 

Infant

0.0598 

0.0605 

0.0536 

0.0309 

0.00863 

0.0104 

0.0127 

0.00637 

NA 

NA 

NA 

NA 

0.521 

0.649 

0.753 

0.673 

Vegetable 

(1.7 mi WSW) 

Adult 

Teen 

Child(c) 

0.530 

0.804 

1.80 

2.08 

3.40 

8.16 

NA 

NA 

NA 

1.43 

1.98 

4.05 

Meat 

(2.8 mi southsouthwest) 

Adult 

Teen 

Child(c) 

0.0128 

0.0104 

0.0189 

0.0564 

0.0476 

0.08741 

NA 

NA 

NA 

0.0180 

0.0142 

0.0246 

Source: PEF 2009a. 

(a) See PEF ER Table 5.4-7 Gaseous Pathways – Dose Summary Maximum Exposed Individuals for one AP1000 

Unit 

 (b) Skin dose is applicable for plume and ground and not for inhalation, vegetable, milk, and meat pathways. 

(c) Infant doses are not calculated for the vegetable or meat pathways because the doses that infants receive from 

this diet would be bounded by the dose calculated for the child. 

NA = not applicable. 

3 5.9.3.1 Maximally Exposed Individual 

4 PEF (2009a) states that total body and organ dose estimates to the MEI from liquid and 

5 gaseous effluents for each new unit would be within the dose design objectives of 

6 10 CFR Part 50, Appendix I. Liquid effluents released to the Gulf of Mexico would result in 

7 doses to the MEI (total body and maximum organ) that would be well within the respective 

8 3-mrem/yr and 10-mrem/yr Appendix I dose design objectives. Doses at the exclusion area 

9 boundary from gaseous effluents would be well within the Appendix I dose design objectives of 

10 a 10-mrad/yr air dose from gamma radiation, a 20-mrad/yr air dose from beta radiation, a 

11 5-mrem/yr dose to the total body, and a 15-mrem/yr dose to the skin. In addition, dose to the 
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August 2010 5-95 Draft NUREG-1941 

1 thyroid would be within the 15-mrem/yr Appendix I dose design objective. A comparison of 

2 dose estimates for each new unit to the Appendix I dose design objectives is found in 

3 Table 5-11. The staff completed an independent evaluation of compliance with Appendix I dose 

4 design objectives and obtained similar results. The staff’s evaluation is presented in 

5 Appendix J. 

6 Table 5-11. Comparisons of MEI Dose Estimates from Liquid and Gaseous Effluent for a Single 

7 New Nuclear Unit to 10 CFR Part 50, Appendix I Dose Design Objectives 

Pathway/Type of Dose PEF (2009a) 

Appendix I Design 

Objectives 

Liquid Effluents 

 Total Body 0.0052 mrem 

(Teen – all pathways) 3 mrem 

 Maximum Organ Dose 0.071 mrem 

(Adult – GI-LLI) 10 mrem 

Gaseous Effluent (Noble Gases Only) 

 Gamma Air Dose 1.7 mrad 10 mrad 

 Beta Air Dose 9.9 mrad 20 mrad 

 Total Body Dose 3.1 mrem 5 mrem 

 Skin Dose 6.3 mrem 15 mrem 

Gaseous Effluents (Radioiodines and Particulates) 

 Maximum Organ Dose 9.7 mrem 

(Child – bone) 15 mrem 

Source: PEF 2009a. 

GI-LLI = gastrointestinal tract-lower large intestine. 

8 Table 5-12 presents the comparison of doses for LNP Units 1 and 2 with the dose standards of 

9 40 CFR Part 190. The table shows PEF’s assessment of total doses to the MEI from LNP liquid 

10 and gaseous effluents. PEF’s assessment of doses includes releases of radiation from CREC 

11 Unit 3 because LNP shares a common discharge point for liquid releases with the CREC Unit 3. 

12 In addition, although the LNP and CREC sites are separated by nearly 10 mi, PEF added the 

13 gaseous effluent doses for CREC to the gaseous effluent doses for LNP to provide a bounding 

14 assessment for LNP. As stated in Section 5.9.1, the direct radiation doses from LNP Units 1 

15 and 2 at the site boundary would be negligible. PEF’s assessment shows that the 

16 40 CFR Part 190 standards would be met. The NRC staff completed an independent evaluation 

17 of compliance with 40 CFR Part 190 standards and obtained similar results. The NRC staff’s 

18 evaluation is presented in Appendix J. 
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August 2010 5-96 Draft NUREG-1941 

1 Table 5-12. Comparison of Maximally Exposed Individual Dose Rates with 40 CFR Part 190 

2 Criteria (mrem/yr) 

CREC Total Liquid 

and Gaseous Dose(a) 

LNP Units 1 and 2(b)

Total 

40 CFR 190 

Dose 

Liquid Gaseous Standards 

Total Body 0.00008 0.021 5.5 5.5 25 

Thyroid 0.002 0.025 12.8 12.9 75 

Other Organ – Bone 0.002 0.14 19.4 19.5 25 

Source: PEF 2009a. 

(a) CREC operating data. 

(b) Calculated LNP Units 1 and 2 doses. 

3 5.9.3.2 Population Dose 

4 PEF estimated the collective total body dose within a 50-mi radius of the proposed LNP site for 

5 gaseous and liquid pathways to be 5.74 and 1.13 person-rem/yr per unit, respectively (PEF 

6 2009a). Collective population doses from the gaseous and liquid effluent pathways were 

7 estimated by PEF using the GASPAR II and LADTAP II computer codes, respectively. The 

8 NRC staff performed an independent evaluation of population doses and obtained similar 

9 results (see Appendix J). 

10 The estimated collective dose to the same population from background radiation is 

11 520,000 person-rem/yr (PEF 2009a). The dose from natural background radiation was 

12 calculated by multiplying the 50-mi population projected to 2020 of approximately 1.44 million by 

13 the annual background dose rate of 360 mrem/yr. A recent National Council on Radiological 

14 Protection and Measurements (NCRP) publication (NCRP 2009) estimates a background dose 

15 rate of 311 mrem/yr. Using this dose rate, the NRC staff estimate of dose from natural 

16 background radiation is 450,000 person-rem/yr. 

17 Radiation protection experts assume that any amount of radiation may pose some risk of 

18 causing cancer or a severe hereditary effect and that the risk is higher for higher radiation 

19 exposures. Therefore, a linear, no-threshold dose response relationship is used to describe the 

20 relationship between radiation dose and detriments such as cancer induction. A recent report 

21 by the National Research Council (2006), the Biological Effects of Ionizing Radiation (BEIR) VII 

22 report, uses the linear, no-threshold model as a basis for estimating the risks from low doses. 

23 This approach is accepted by the NRC as a conservative method for estimating health risks 

24 from radiation exposure, recognizing that the model may overestimate those risks. Based on 

25 this method, the NRC staff estimated the risk to the public from radiation exposure using the 

26 nominal probability coefficient for total detriment. This coefficient has the value of 570 fatal 

27 cancers, nonfatal cancers, and severe hereditary effects per 1,000,000 person-rem 

28 (10,000 person-Sv), equal to 0.00057 effects per person-rem. The coefficient is taken from 
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August 2010 5-97 Draft NUREG-1941 

1 International Commission on Radiation Protection (ICRP) Publication 103 (ICRP 2007). The 

2 estimated collective total body dose to the population living within 50 mi of the proposed LNP 

3 site is 6.9 person-rem/yr per unit, which is less than the 1754 person-rem/yr value that ICRP 

4 and NCRP suggest would most likely result in zero excess health effects (ICRP 2007; NCRP 

5 1995). 

6 In addition, at the request of the U.S. Congress, the National Cancer Institute (NCI) conducted a 

7 study and published Cancer in Populations Living Near Nuclear Facilities in 1990 (Jablon et al. 

8 1990). This report included an evaluation of health statistics around all nuclear power plants, as 

9 well as several other nuclear fuel cycle facilities, in operation in the United States in 1981 and 

10 found “no evidence that an excess occurrence of cancer has resulted from living near nuclear 

11 facilities” (Jablon et al. 1990). 

12 5.9.3.3 Summary of Radiological Impacts on Members of the Public 

13 The NRC staff evaluated the health impacts from routine gaseous and liquid radiological effluent 

14 releases from proposed new units at the LNP site. Based on the information provided by PEF 

15 and NRC’s independent evaluation, the NRC staff concludes there would be no observable 

16 health impacts on the public from normal operation of the proposed new units, the health 

17 impacts would be SMALL, and additional mitigation would not be warranted. 

18 5.9.4 Occupational Doses to Workers 

19 Radiation exposures in an AP1000 type plant would be primarily due to direct radiation from 

20 components and equipment containing radioactive material. In addition, in some areas of the 

21 plant there would be radiation exposure to personnel due to the presence of airborne 

22 radionuclides. In Section 12.4 of the AP1000 DCD, the annual occupational dose is estimated 

23 to be 67.1 person-rem/yr per unit for normal operation and anticipated inspection and 

24 maintenance activities (Westinghouse 2008). This collective dose is based on an 18-month fuel 

25 cycle and would be bounding for a 24-month fuel cycle. 

26 The licensee of a new plant would need to maintain individual doses to workers within 5 rem 

27 annually as specified in 10 CFR 20.1201 and to incorporate provisions to maintain doses as low 

28 as reasonably achievable (ALARA). 

29 The NRC staff concludes that the health impacts from occupational radiation exposure would be 

30 SMALL based on individual worker doses being maintained within the limits of 10 CFR 20.1201 

31 and collective occupational doses being typical of doses found in current operating LWR 

32 reactors. Additional mitigation would not be warranted because the operating plant would be 

33 required to maintain doses ALARA. 
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August 2010 5-98 Draft NUREG-1941 

1 5.9.5 Impacts on Non-Human Biota 

2 PEF estimated doses to biota species in the LNP site environs, in many cases using surrogate 

3 species. Surrogate species used in the ER are well-defined and provide an acceptable method 

4 for evaluating doses to biota. Surrogate species analysis was performed for aquatic species, 

5 such as fish, invertebrates, and algae, and for terrestrial species, such as muskrats, raccoons, 

6 herons, and ducks. 

7 PEF calculated doses to important aquatic and terrestrial biota species in addition to surrogate 

8 species. Important biota species for the LNP site are as follows: various mussel and mollusk 

9 species; grouper (red, black, and gag), spotted sea trout, flounder, and sturgeon; white-tailed 

10 deer and Florida black bear; wild turkey, wood duck, bald eagle, northern bobwhite, red11 cockaded woodpecker, and wood stork. The important biota species with the highest calculated 

12 dose was the northern bobwhite. 

13 Exposure pathways considered in evaluating dose to biota are discussed in Section 5.9.1 and 

14 shown in Figure 5-10. The NRC staff reviewed PEF’s calculations (PEF 2009a) and performed 

15 an independent evaluation with results similar to those reported by PEF (2009a). 

16 5.9.5.1 Liquid Effluent Pathway 

17 PEF used the LADTAP II computer code to calculate doses to biota from the liquid effluent 

18 pathway. Liquid pathway doses are higher for biota compared to humans because of 

19 considerations of bioaccumulation of radionuclides, ingestion of aquatic plants, ingestion of 

20 invertebrates, and increased time spent in the water and at the shoreline compared to humans. 

21 Proposed LNP Units 1 and 2 blowdown and liquid releases would flow into the discharge canal 

22 that serves CREC Unit 3. Parameters used in the PEF analysis are found in Tables 3.3-2, 5.5-1 

23 and 5.4-14 of the ER. Table 5-13 presents the PEF estimates of liquid effluent pathway doses 

24 to biota from proposed LNP Units 1 and 2. The staff performed an independent analysis 

25 (Appendix J) and concludes that all of the input parameters used in the PEF calculation and the 

26 resulting doses are appropriate. 

27 5.9.5.2 Gaseous Effluent Pathway 

28 Gaseous effluents would contribute to the total body dose of the terrestrial surrogate species 

29 (i.e., muskrat, raccoon, heron, and duck). The exposure pathways include inhalation of airborne 

30 radionuclides, external exposure because of immersion in gaseous effluent plumes, and surface 

31 exposure from deposition of iodine and particulates from gaseous effluents. PEF calculated 

32 doses to terrestrial species using the methods described in Section 5.9.2 with some 

33 modifications. PEF used the results of the GASPAR II computer code to calculate doses to 

34 terrestrial biota from gaseous effluent releases with four modifications. The first modification 
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August 2010 5-99 Draft NUREG-1941 

Table 5-13. Biota Doses for Proposed Units 1 and 2(a) 1 

Doses from Liquid Effluents in 

Discharge Canal Doses from Gaseous Effluents 

LNP 1 and 2 LNP 1 and 2 

Internal Dose 

(mrad/yr) 

External Dose 

(mrad/yr) 

Internal Dose 

(mrad/yr) 

External Dose 

(mrad/yr) 

Saltwater Fish 0.11 0.57 0.0 0.0 

Invertebrate 3.90 1.10 0.0 0.0 

Algae 8.80 0.00 0.0 0.0 

Muskrat 0.88 0.38 0.0 2.00 

Raccoon 0.14 0.28 0.0 2.00 

Heron 0.62 0.38 0.0 1.40 

Duck 0.83 0.57 0.0 2.00 

Northern Bobwhite 0.00 0.00 0.014 18.0 

Source: PEF 2009a. 

(a) Radiological doses to non-human biota are expressed in units of absorbed dose (rad). 

2 was to adjust the doses for residence time; the second was to increase the external dose from 

3 ground deposition by a factor of two to account for closer proximity to the ground; third, the 

4 gamma energy absorption rate in air was used; and fourth, the beta energy absorption rate in air 

5 was reduced by a factor of 2. Parameters used in the PEF analysis are found in Tables 3.5-5, 

6 5.5-1, and 5.4-14 of the ER. Table 5-13 presents the PEF estimates of gaseous effluent 

7 pathway doses to biota from the proposed LNP Units 1 and 2. The staff performed an 

8 independent analysis (Appendix J) and concludes that all of the input parameters used in the 

9 PEF calculation and the resulting doses are appropriate. 

10 5.9.5.3 Impact of Estimated Biota Doses 

11 The International Atomic Energy Agency (IAEA 1992) and the NCRP (1991) reported that a 

12 chronic dose rate of no greater than 10 mGy/d (1000 mrad/d) to the MEI in a population of 

13 aquatic organisms would ensure protection of the population. IAEA (1992) also concluded that 

14 chronic dose rates of 1 mGy/d (100 mrad/d) or less do not appear to cause observable changes 

15 in terrestrial animal populations. 

16 Table 5-14 compares estimated total body dose rates to surrogate biota species produced by 

17 releases from LNP Units 1 and 2 to the IAEA/NCRP biota dose guidelines (IAEA 1992, NCRP 

18 1991). The maximum total dose from liquid and gaseous pathways from the bounding 

19 calculation is about 0.5 mrad/d. Thus, the doses to biota calculated by PEF are far below the 

20 100-mrad/d IAEA guideline (IAEA 1992) for terrestrial biota and the 1000-mrad/d guideline for 

21 aquatic biota. Based on the information provided by PEF and the NRC staff’s independent 

22 evaluation, the NRC staff concludes that the radiological impact on biota from the routine 
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August 2010 5-100 Draft NUREG-1941 

1 operation of the proposed LNP Units 1 and 2 would be SMALL, and additional mitigation would 

2 not be warranted.

3 Table 5-14. Comparison of Biota Doses from the Proposed LNP Units 1 and 2 to IAEA 

4 Guidelines for Biota Protection 

Biota 

PEF Estimate of Dose 

to Biota (mrad/d)(a)

IAEA/NCRP 

Guidelines for 

Protection of Biota 

Populations 

(mrad/d)(b)

Fish 0.01 1000 

Invertebrate 0.02 1000 

Algae 0.03 1000 

Muskrat 0.02 100 

Raccoon 0.01 100 

Heron 0.01 100 

Duck 0.02 100 

Northern bobwhite 0.5 100 

Sources: PEF 2009a, IAEA 1992. 

(a) Sum of doses to biotic species is from PEF ER Table 5.4-16. 

(b) Guidelines in NCRP and IAEA reports expressed in Gy/d (1 mGy/d equals 

100 mrad/d). 

5 5.9.6 Radiological Monitoring 

6 The LNP site is a greenfield site. Therefore, PEF has not established a radiological monitoring 

7 program at the site. A preoperational monitoring program would begin 2 years prior to the start 

8 of operation of LNP Unit 1, and an operational radiological environmental monitoring program 

9 (REMP) would be established prior to the beginning of operation of LNP Unit 1. A REMP has 

10 been in place at PEF’s CREC Unit 3 site since operations began in 1977. Accordingly, the staff 

11 expects that PEF will develop a REMP for the operation of LNP Units 1 and 2 based on 

12 information from the CREC Unit 3 program and data collected during the preoperational REMP. 

13 The CREC Unit 3 REMP includes monitoring of the following exposure pathways: airborne, 

14 direct, water, aquatic from the Gulf of Mexico, and ingestion within a 5-mi radius of the station, 

15 with indicator locations near the plant perimeter and control locations at distances greater than 

16 10 mi away. Many of the sampling stations used for CREC Unit 3 would also be used for 

17 proposed LNP Units 1 and 2 because they would share a common liquid discharge canal. 

18 Many of the control or background sampling stations may also be shared. The State of Florida 

19 Department of Health, Bureau of Radiation Control (BRC), performs sampling of the facility 

20 environs for PEF. The State also performs the required analyses, participates in the 

21 Interlaboratory Comparison Program, and performs the annual land-use census. Radiological 
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August 2010 5-101 Draft NUREG-1941 

1 releases are summarized in an annual radiological environmental operating report produced by 

2 BRC and transmitted by PEF to the NRC. 

3 The staff reviewed the CREC Unit 3 annual reports for 2006 and 2007 and consulted with the 

4 State’s BRC Environmental Administrator during the December 2008 site audit. Observations 

5 and trending analysis of past conditions provide a robust and comprehensive program 

6 (PEF 2007, 2008d). 

7 The CREC Unit 3 annual reports for 2006 and 2007 show that trace concentrations of CREC 

8 Unit 3 effluents enter the intake canal for CREC Unit 3. LNP would share effluent discharge 

9 point with CREC Unit 3; therefore, some of the LNP effluents may also enter the CREC Unit 3 

10 intake canal. NRC Regulatory Issue Summary 2008-03 indicates that water containing 

11 radioactive material returned from the environment can be used by the licensee and returned to 

12 the environment without being considered a new radioactive material effluent released (NRC 

13 2008a). The staff review of these reports found no indication of radiological consequence 

14 associated with the operation of CREC Unit 3 that would affect the NRC’s conclusion regarding 

15 LNP Units 1 and 2. 

16 5.10 Nonradioactive Waste Impacts 

17 This section describes the environmental impacts that could result from the generation, 

18 handling, and disposal of nonradioactive waste and mixed waste during operation of the 

19 proposed LNP. As discussed in Section 3.4.4, the types of nonradioactive waste that would be 

20 generated, handled, and disposed of during operation include municipal solid waste, industrial 

21 solid wastes, stormwater runoff, sanitary waste, liquid effluents containing chemicals or 

22 biocides, industrial liquid wastes, and combustion emissions. In addition, small quantities of 

23 hazardous waste and mixed waste, which is waste that has both hazardous and radioactive 

24 characteristics, may be generated during plant operations. The assessment of potential impacts 

25 resulting from these types of wastes is presented in the following sections. 

26 5.10.1 Impacts on Land 

27 The expected nonradioactive waste streams destined for land-based treatment or disposal 

28 during operation include water-treatment wastes, laboratory wastes, trash, sanitary waste, 

29 cooling-water intake screen debris, and small quantities of hazardous waste. 

30 Nonhazardous solid waste generated during operation would be segregated and recycled to the 

31 extent practicable, with the balance disposed of in an offsite, permitted landfill. Debris collected 

32 from the CFBC intake structure trash racks and screens would also be disposed of in local 

33 landfills. Spent filters from the raw-water system and from the reverse osmosis system for 

34 demineralized water treatment would be disposed of in accordance with applicable industrial 

35 solid waste regulations. No solid wastes would be burned or disposed of onsite during 
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August 2010 5-102 Draft NUREG-1941 

1 operations (PEF 2009a). PEF estimates that during operations, the LNP would generate an 

2 average of 1617 tons of solid waste annually (PEF 2008a). A licensed sanitation contractor 

3 would periodically remove and dispose of the sludge from the sanitary waste-treatment plant 

4 (PEF 2008a). 

5 All transportation, storage, and disposal of regulated hazardous wastes would be in accordance 

6 with applicable Federal, State, and local requirements. All hazardous wastes would be 

7 collected, transported offsite by a licensed and permitted Resource Conservation and Recovery 

8 Act (RCRA) waste hauler, and treated or disposed of offsite at a RCRA-permitted facility. 

9 Storage of some hazardous materials and associated wastes would occur in the Hazardous 

10 Waste Storage Building (Building 136), two Chemical Storage Buildings (Buildings 119 and 

11 120), and the Painting and Sandblast Shop (Building 105) (PEF 2009a, i). 

12 Mixed waste contains both low-level radioactive waste and hazardous waste. The generation, 

13 storage, treatment, or disposal of mixed waste is regulated by the Atomic Energy Act of 1954, 

14 the Solid Waste Disposal Act of 1965, as amended by RCRA in 1976, and the Hazardous and 

15 Solid Waste Amendments (which amended RCRA in 1984). The mixed waste from the LNP 

16 would be handled and managed in accordance with the applicable Federal, State, and local 

17 requirements. The packaged waste would be stored in the auxiliary and radwaste buildings until 

18 it is shipped offsite to a licensed disposal facility (PEF 2009a, i). 

19 Because no wastes would be landfilled onsite and all wastes destined for land-based treatment 

20 or disposal would be transported offsite by licensed contractors to existing, licensed, disposal 

21 facilities operating in compliance with all applicable Federal, State and local requirements, the 

22 review team expects that impacts on land from nonradioactive and mixed wastes generated 

23 during operation of the LNP would be minor, and no further mitigation would be warranted. 

24 5.10.2 Impacts on Water 

25 The nonradioactive liquid waste streams during operation would include cooling-water 

26 blowdown, auxiliary-boiler blowdown, water-treatment wastes, discharge from floor and 

27 equipment drains, stormwater runoff, and effluents from the sanitary sewage-treatment system. 

28 All nonradioactive, liquid discharges during operation would need to comply with the applicable 

29 provisions of NPDES Permit No. FL0633275-001-IW1S/NP upon final issuance (FDEP 2010). 

30 All of the liquid effluent streams from the LNP would combine into a single stream and be 

31 discharged via the CREC discharge canal into the Gulf of Mexico (PEF 2009a). 

32 Because all nonradioactive liquid wastes from the LNP would be combined into a single, 

33 permitted, and monitored discharge stream, the review team concludes that impacts on water 

34 from nonradioactive liquid wastes generated during operation of the LNP would be minimal, and 

35 no further mitigation would be warranted. 
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August 2010 5-103 Draft NUREG-1941 

1 5.10.3 Impacts on Air 

2 The nonradioactive gaseous waste streams during operation would include emissions from the 

3 combustion of fossil fuels, volatile emissions from those fuels, and other volatile organic 

4 compounds (VOCs) from the use of materials such as paints, oils, and solvents. 

5 Gaseous emissions would be produced by the combustion of diesel fuel during monthly testing 

6 of the 10 diesel engines that would power fire-water pumps and standby generators. Each of 

7 these diesel engines would have an associated fuel tank that would release small quantities of 

8 VOCs. Additional VOCs would be released from the use of paints, oils, solvents, and other 

9 standard building and maintenance materials. 

10 PEF also plans to construct and operate a fueling station in the motor pool area but details are 

11 not yet available on the size of the station, the number and types of fuel tanks, or the makeup of 

12 the vehicle fleet to be serviced by the station (PEF 2009i). Any emissions from the fueling 

13 station would be offset by a reduction in emissions from offsite service stations, at which the 

14 LNP vehicle fleet would need to be refueled in the absence of an onsite service station. 

15 Nonradioactive gaseous emissions from operations (including greenhouse gas emissions) 

16 would be limited in magnitude. PEF would install equipment with appropriate emission controls 

17 and comply with all applicable Federal, State and local requirements. Based on the above 

18 analysis, the NRC staff concludes that impacts on air from nonradioactive gaseous wastes 

19 generated during operation of the LNP facility would be minimal, and mitigation would not be 

20 warranted. 

21 5.10.4 Summary of Nonradioactive Waste Impacts 

22 Solid, liquid, gaseous, hazardous, and mixed wastes generated during operation of proposed 

23 LNP Units 1 and 2 would be handled according to county, State, and Federal regulations. 

24 County and State permits for handling and disposal of solid waste would be obtained and 

25 implemented. Compliance with the NPDES permit for releases of cooling water and other liquid 

26 effluents would ensure compliance with the Federal Water Pollution Control Act (Clean Water 

27 Act) and Florida water-quality standards. Air emissions from the LNP would be minimal and 

28 would not reduce the local air quality. All transportation, storage, and disposal of regulated 

29 hazardous and mixed wastes would be in accordance with applicable Federal, State, and local 

30 requirements. 

31 Based on the information provided by PEF, the planned practices for recycling, minimizing, 

32 managing, and disposing of wastes, the requirements to obtain regulatory approvals for waste 

33 disposal and discharges, and the review team’s independent evaluation, the review team 

34 concludes that the potential impacts from nonradioactive and mixed waste resulting from the 

35 operation of the proposed LNP facility would be SMALL, and mitigation would not be warranted. 
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August 2010 5-104 Draft NUREG-1941 

1 5.11 Environmental Impacts of Postulated Accidents 

2 The staff considered the radiological consequences on the environment of potential accidents at 

3 the LNP site. PEF based its COL application on the proposed installation of AP1000 reactors for 

4 Units 1 and 2. Revision 15 of the AP1000 design (Westinghouse 2005) is a certified design as 

5 set forth in 10 CFR Part 52, Appendix D. Subsequently, Westinghouse submitted Revision 17 of 

6 the AP1000 design (Westinghouse 2008). The PEF application (PEF 2009b) references 

7 Revision 17 of the AP1000 DCD. The NRC staff is reviewing the Westinghouse application to 

8 amend the design-certification rule for the AP1000. 

9 The term “accident,” as used in this section, refers to any off-normal event not addressed in 

10 Section 5.9 that results in release of radioactive materials into the environment. The focus of 

11 this review is on events that could lead to releases that are substantially in greater than 

12 permissible limits for normal operations. Normal release limits are specified in 10 CFR Part 20, 

13 Appendix B, Table 2. 

14 Numerous features combine to reduce the risk associated with accidents at nuclear power 

15 plants. Safety features in the design, construction, and operation of the plants, which comprise 

16 the first line of defense, are intended to prevent the release of radioactive materials from nuclear 

17 plants. The design objectives and the measures for keeping levels of radioactive materials in 

18 effluents to unrestricted areas ALARA are specified in 10 CFR Part 50, Appendix I. Additional 

19 measures are designed to mitigate the consequences of failures in the first line of defense. 

20 These include NRC’s reactor site criteria in 10 CFR Part 100, which require the site to have 

21 certain characteristics that reduce the risk to the public and the potential impacts of an accident; 

22 emergency preparedness plans and protective action measures for the site and environs, as set 

23 forth in 10 CFR 50.47; 10 CFR Part 50, Appendix E; and NUREG-0654/FEMA-REP-1 

24 (NRC 1980). All of these safety features, measures, and plans make up the defense-in-depth 

25 philosophy to protect the health and safety of the public and the environment. 

26 This section discusses (1) the types of radioactive materials, (2) the paths to the environment, 

27 (3) the relationship between radiation dose and health effects, and (4) the environmental 

28 impacts of reactor accidents, both design basis accidents (DBAs) and severe accidents. The 

29 environmental impacts of accidents during transportation of spent fuel are discussed in 

30 Chapter 6. 

31 The potential for dispersion of radioactive materials in the environment depends on the 

32 mechanical forces that physically transport the materials and on the physical and chemical 

33 forms of the material. Radioactive material exists in a variety of physical and chemical forms. 

34 Most of the material in the fuel is in the form of nonvolatile solids. However, a significant 

35 amount of material is in the form of volatile solids or gases. The gaseous radioactive materials 

36 include the chemically inert noble gases (e.g., krypton and xenon), which have a high potential 
Operational Impacts at the Proposed Site 

August 2010 5-105 Draft NUREG-1941 

1 for release. Radioactive forms of iodine, which are created in substantial quantities in the fuel 

2 by fission, are volatile. Other radioactive materials formed during the operation of a nuclear 

3 power plant have lower volatilities and, therefore, have lower tendencies to escape from the fuel 

4 than the noble gases and iodines. 

5 Radiation exposure to individuals is determined by their proximity to radioactive material, the 

6 duration of their exposure, and the extent to which they are shielded from the radiation. 

7 Pathways that lead to radiation exposure include (1) external radiation from radioactive material 

8 in the air, on the ground, and in water, (2) inhalation of radioactive material, and (3) ingestion of 

9 food or water containing material initially deposited on the ground and in water. 

10 Radiation protection experts assume that any amount of radiation may pose some risk of causing 

11 cancer or a severe hereditary effect and that the risk is higher for higher radiation exposures. 

12 Therefore, a linear, no-threshold dose response relationship is used to describe the relationship 

13 between radiation dose and detriments such as cancer induction. A recent report by the National 

14 Research Council (2006), the BEIR VII report, uses the linear, no-threshold dose response 

15 model as a basis for estimating the risks from low doses. This approach is accepted by the NRC 

16 as a conservative method for estimating health risks from radiation exposure, recognizing that 

17 the model may overestimate those risks. 

18 Physiological effects are clinically detectable if individuals receive radiation exposure resulting in 

19 a dose greater than about 25 rem over a short period of time (hours). Untreated doses of about 

20 250 to 500 rem received over a relatively short period (hours to a few days) can be expected to 

21 cause some fatalities.

22 5.11.1 Design Basis Accidents 

23 PEF evaluated the potential consequences of postulated accidents to demonstrate that an 

24 AP1000 reactor could be constructed and operated at the LNP site without undue risk to the 

25 health and safety of the public (PEF 2009a). These evaluations used a set of surrogate DBAs 

26 that are representative of the reactor design being considered for the LNP site and site-specific 

27 meteorological data. The set of accidents covers events that range from a relatively high 

28 probability of occurrence with relatively low consequences to a relatively low probability with 

29 high consequences. 

30 The DBA review focuses on the AP1000 reactor at the LNP site. The bases for analyses of 

31 postulated accidents for this design are well established, because they have been considered 

32 as part of NRC’s advanced reactor design-certification process. Potential consequences of 

33 DBAs are evaluated by following procedures outlined in regulatory guides and standard review 

34 plans. The potential consequences of accidental releases depend on the specific radionuclides 

35 released, the amount of each radionuclide released, and the meteorological conditions. The 
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August 2010 5-106 Draft NUREG-1941 

1 source terms for the AP1000 reactor and methods for evaluating potential accidents are based 

2 on guidance provided in Regulatory Guide 1.183 (NRC 2000b). 

3 For environmental reviews, consequences are evaluated assuming realistic meteorological 

4 conditions. Meteorological conditions are represented in these consequence analyses by an 

5 atmospheric dispersion factor, which is also referred to as relative concentration (/Q; units of 

s/m3 6 ). Acceptable methods of calculating /Q for DBAs from meteorological data are set forth in 

7 Regulatory Guide 1.145 (NRC 1983). 

8 Table 5-15 lists /Q values that the NRC staff considers pertinent to the environmental review of 

9 DBAs for the LNP site. Small /Q values are associated with greater dilution capability. The 

10 first column lists the time periods and boundaries for which /Q and dose estimates are needed. 

11 For the exclusion area boundary (EAB), the postulated DBA dose and its atmospheric 

12 dispersion factor are calculated for a short-term period (i.e., 2 hours), and for the low-population 

13 zone (LPZ), they are calculated for the course of the accident (i.e., 30 days composed of four 

14 time periods). The second column lists the /Q values for the LNP site; these values are 

15 presented calculated at the EAB and LPZ boundary defined in the PEF Final Safety Analysis 

16 Report (PEF 2009b) using 2 years of meteorological data for the LNP site (February 1, 2007 

17 through January 31, 2009). 

18 As discussed in Section 2.9.3.1, the NRC staff reviewed the meteorological data used by PEF 

19 and the /Q values in the PEF ER. Based on these reviews, the NRC staff concluded that the 

20 atmospheric dispersion factors for the LNP site in the ER did not appropriately reflect the 

21 realistic dispersion conditions needed for use in evaluating potential environmental 

22 consequences of postulated DBAs for the AP1000 reactor design at the LNP site because they 

23 were too conservative. Consequently, the /Q values in Table 5-15, which are more realistic, 

24 were estimated by the NRC staff using the LNP meteorological data. 

25 Table 5-15. Atmospheric Dispersion Factors for the LNP Site DBA Calculations 

Time Period and Boundary/Zone /Q (s/m3) 

0 to 2 hr, exclusion area boundary 3.60 × 105

0 to 8 hr, low-population zone 6.04 × 106

8 to 24 hr, low-population zone 4.74 × 106

1 to 4 d, low-population zone 3.75 × 106

4 to 30 d, low-population zone 2.81× 106

26 Table 5-16 lists the set of DBAs considered by PEF and presents the estimates of the 

27 environmental consequences of each accident in terms of total effective dose equivalent 

28 (TEDE) calculated by the NRC staff using the /Q values from Table 5-15. TEDE is estimated 

29 by the sum of the committed effective dose equivalent from inhalation and the effective dose 
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August 2010 5-107 Draft NUREG-1941 

1 equivalent from external exposure. Dose conversion factors from Federal Guidance Report 11 

2 (Eckerman et al. 1988) were used to calculate the committed effective dose equivalent. 

3 Similarly, dose conversion factors from Federal Guidance Report 12 (Eckerman and Ryman 

4 1993) were used to calculate the effective dose equivalent. 

5 Table 5-16. DBA Doses for an AP1000 Reactor for LNP Units 1 and 2 

Accident

Standard Review 

Plan Section(b)

TEDE (rem)(a)

EAB(c) LPZ(d)

Review 

Criterion

Main steam line break 15.1.5 

 Preexisting iodine spike 3.60 × 102 1.09 × 102 2.5 × 101(e)

 Accident-initiated iodine spike 3.96 × 102

 3.17 × 102 2.5 × 100(f)

Steam generator rupture 15.6.3 

 Preexisting iodine spike 7.92 × 102

 1.52 × 102 2.5 × 101(e)

 Accident-initiated iodine spike 3.96 × 102

 1.02 × 102 2.5 × 100(f)

Loss-of-coolant accident 15.6.5 1.74 × 100

 6.49 × 101 2.5 × 101(e)

Rod ejection 15.4.8 1.30 × 101

 7.00 × 102 6.25 × 100(f)

Reactor coolant pump rotor 

seizure (locked rotor) 

15.3.3 

 Without feedwater 2.88 × 102

 4.70 × 103 2.5 × 100(f)

 With feedwater 2.16 × 102

 9.60 ×103 2.5 × 100(f)

Failure of small lines carrying 

primary coolant outside 

containment 

15.6.2 7.56 × 102

 1.23 ×102 2.5 × 100(f)

Fuel handling 15.7.4 1.87 × 101

 3.13×102 6.25 × 100(f)

(a) To convert rem to Sv, divide by 100. 

(b) NUREG-0800 (NRC 2007). 

(c) EAB = exclusion area boundary. 

(d) LPZ = low-population zone. 

(e) 10 CFR 52.79 (a)(1) and 10 CFR 100.21 criteria. 

(f) Standard Review Plan 15.0.3 criterion. 

6 The NRC staff reviewed the PEF selection of DBAs by comparing the accidents listed in the 

7 PEF DBA analysis with the DBAs considered in Revision 17 of the AP1000 DCD, which is 

8 currently in the design-certification process (Westinghouse 2008). The DBAs in the analysis are 

9 the same as those considered in design certification, therefore the staff concludes that the set of 

10 DBAs is appropriate. 
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August 2010 5-108 Draft NUREG-1941 

1 The review criteria used in the staff’s safety review of DBA doses are included in Table 5-16 to 

2 illustrate the magnitude of the calculated environmental consequences (TEDE doses) because 

3 there are no environmental criteria related to the potential consequences of DBAs. In all cases, 

4 the calculated TEDE values are considerably smaller than the TEDE doses used as safety 

5 review criteria; therefore, the NRC staff concludes that, with respect to DBAs, the LNP site is 

6 environmentally suitable for operation of two new AP1000 reactors. 

7 NRC staff reviewed the PEF DBA analysis, which is based on analyses performed for design 

8 certification of Revision 17 of the AP1000 reactor design with adjustment for LNP site-specific 

9 characteristics. The NRC staff also performed an independent DBA analysis. The results of the 

10 PEF and NRC staff analyses indicate that the environmental risks associated with DBAs, if an 

11 AP1000 reactor were to be located at the LNP site, would be small. On this basis, the NRC 

12 staff concludes that the environmental consequences of DBAs at the LNP site would be SMALL 

13 for an AP1000 reactor.

14 5.11.2 Environmental Impacts of Postulated Severe Accidents 

15 In its ER (PEF 2009a), PEF considers the potential consequences of severe accidents for an 

16 AP1000 reactor at the LNP site. Three pathways are considered: (1) the atmospheric pathway 

17 in which radioactive material is released to the air; (2) the surface-water pathway in which 

18 airborne radioactive material falls out on open bodies of water; and (3) the groundwater pathway 

19 in which groundwater is contaminated by a basemat melt-through with subsequent 

20 contamination of surface water by the groundwater. 

21 PEF’s consequence assessment is based on the probabilistic risk assessment (PRA) for 

22 Revision 15 of the AP1000 design (Westinghouse 2005), which is certified in 10 CFR Part 52, 

23 Appendix D. Westinghouse subsequently upgraded and updated the PRA model; however, 

24 Westinghouse reviewed the AP1000 probabilistic risk assessment for Revision 15 and 

25 concluded that the PRA remains valid for proposed revisions to the DCD (Westinghouse 

26 2007b). The NRC staff evaluated the current PRA model and its results using “Probabilistic 

27 Risk Assessment Information to Support Design Certification and Combined License 

28 Applications” (DC/COL-ISG-3) (NRC 2008b) and concluded that the Revision 15 results remain 

29 conservative and are an acceptable basis for evaluating severe accidents and strategies for 

30 mitigating them. PEF is required by regulation to upgrade and update the PRA prior to fuel 

31 loading. At that time, the NRC staff expects the PRA to be site-specific and that it will no longer 

32 use the bounding assumptions of the design-specific PRA. 

33 5.11.2.1 Internally Initiated Events 

34 The PEF (2008a) evaluation of the potential environmental consequences for the atmospheric 

35 and surface-water pathways incorporates the results of the Melcor Accident Consequence Code 

36 System (MACCS2) computer code Version 1.12 (Chanin and Young 1997) run using AP1000 
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August 2010 5-109 Draft NUREG-1941 

1 reactor source-term information and LNP site-specific meteorological, population, and land-use 

2 data. PEF provided the NRC with copies of the input and output files for the MACCS2 computer 

3 runs (PEF 2009i). The NRC staff reviewed the files, ran confirmatory calculations, and 

4 determined that PEF’s results are reasonable.

5 The MACCS2 computer codes were developed to evaluate the potential offsite consequences 

6 of severe accidents for the sites covered by NUREG-1150 (NRC 1990). The MACCS2 codes 

7 evaluate the consequences of atmospheric releases of material after a severe accident. The 

8 pathways modeled include exposure to the passing plume, exposure to material deposited on 

9 the ground and skin, inhalation of material in the passing plume and resuspended from the 

10 ground, and ingestion of contaminated food and surface water. 

11 Three types of severe accident consequences were assessed in the MACCS2 analysis: 

12 (1) human health, (2) economic costs, and (3) land area affected by contamination. Human 

13 health effects are expressed in terms of the number of cancers that might be expected if a 

14 severe accident were to occur. These effects are directly related to the cumulative radiation 

15 dose received by the general population. MACCS2 estimates both early cancer fatalities and 

16 latent fatalities. Early fatalities are related to high doses or dose rates and can be expected to 

17 occur within a year of exposure. 

18 Latent fatalities are related to exposure of a large number of people to low doses and dose rates 

19 and can be expected to occur after a latent period of several (2 to 15) years. Population health20 risk estimates are based on the population distribution within a 50-mi radius of the site. 

21 Economic costs of a severe accident include the costs associated with short-term relocation of 

22 people; decontamination of property and equipment; interdiction of food supplies, land, and 

23 equipment use; and condemnation of property. The affected land area is a measure of the areal 

24 extent of the residual contamination after a severe accident. Farmland decontamination is an 

25 estimate of the area that has an average whole body dose rate for the 4-year period following 

26 the release that would be greater than 0.5 rem/yr if not reduced by decontamination, and that 

27 would have a dose rate following decontamination of less than 0.5 rem/yr. Decontaminated 

28 land is not necessarily suitable for farming. 

29 Risk is the product of the frequency and the consequences of an accident. For example, the 

30 probability of a severe accident without loss of containment for an AP1000 reactor at the LNP site 

is estimated to be 2.2 × 107 31 /reactor-year (Ryr), and the cumulative population dose associated 

with a severe accident without loss of containment at the site is calculated to be 4.5 × 103 32 person33 rem (PEF 2009i). The population dose risk for this class of accidents is the product of 

2.2 × 107/Ryr and 4.5 × 103

 person-rem, or 9.9 × 104 34 person-rem/Ryr. The following sections 

35 discuss the estimated risks associated with each pathway. 

36 The risks presented in the tables that follow are risks per year of reactor operation. PEF has 

37 indicated that the LNP site could hold two reactors of the AP1000 reactor design. The 
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August 2010 5-110 Draft NUREG-1941 

1 consequences of a severe accident would be the same regardless of whether one or two 

2 AP1000 reactors were built at the LNP site. If two AP1000 reactors were built, the risks would 

3 apply to each reactor, and the total risk for new reactors at the site would be double the risk for 

4 a single reactor. A discussion of these risks is presented in the following sections. 

5 5.11.2.2 Air Pathway 

6 The MACCS2 codes directly estimate the consequences of releases to the air pathway. The 

7 risks calculated from the results of the MACCS2 runs are presented in Table 5-17. The core 

8 damage frequencies (CDFs) given in the following tables are for internally initiated accident 

9 sequences while the facility is at power. Internally initiated accident sequences include those 

10 that are initiated by human error, equipment failures, loss of offsite power, etc. Estimates of the 

11 CDFs for externally initiated events and during shutdown are discussed later. 

12 Table 5-17 shows that the probability-weighted consequences (i.e., risks) of severe accidents 

13 for an AP1000 reactor located on the LNP site are small for all risk categories considered. For 

14 perspective, Table 5-18 and Table 5-19 compare the health risks from severe accidents for an 

15 AP1000 reactor at the LNP site with the risks for current-generation reactors at various sites and 

16 with health risks for AP1000 reactors at the North Anna, Clinton, Grand Gulf, and Vogtle early 

17 site permit (ESP) sites. 

18 In Table 5-18, the health risks estimated for an AP1000 reactor at the LNP site are compared 

19 with health-risk estimates for the five reactors considered in NUREG-1150 (NRC 1990). Although 

20 risks associated with both internally and externally initiated events were considered for the 

21 Peach Bottom and Surry reactors in NUREG-1150, only risks associated with internally initiated 

22 events are presented in Table 5-19. Table 5-19 also compares the health risks of an AP1000 

23 reactor at the LNP site with the health risks of an AP1000 reactor at four ESP sites (NRC 

24 2006a, b, c; 2008c; PEF 2009a). 

25 The last two columns of Table 5-18 provide average individual fatality risk estimates. To put 

26 these estimates into context for the environmental analysis, the NRC staff compares these 

27 estimates to safety goals. The Commission has set safety goals for average individual early 

28 fatality and latent cancer fatality risks from reactor accidents in the Safety Goal Policy Statement 

29 (51 FR 30028). These goals are presented here solely to provide a point of reference for the 

30 environmental analysis and do not serve the purpose of a safety analysis. The Policy 

31 Statement expressed the Commission’s policy regarding the acceptance level of radiological 

32 risk from nuclear power plant operation as follows:
August 2010 5-111 Draft NUREG-1941

Operational Impacts at the Proposed Site

• Table 5-17. Mean Environmental Risks from an AP1000 Reactor Severe Accident at the LNP Site 1 

Release Category Description 

(Accident Class)

Core Damage 

Frequency 

(per Ryr) 

Environmental Risk

Population 

Dose (personrem/Ryr)(a)

Fatalities 

(Ryr1) 

Cost(d)

($/Ryr) 

Farmland 

Decontamination(e)

(ac/Ryr) 

Population Dose 

from Water 

Ingestion 

(personrem/Ryr)(a) Early(b) Latent(c)

IC Intact containment 2.2 × 107 9.9 × 104 0.0 × 100 4.5 × 107 0.31 1.6 × 106 2.6 × 106BP Containment bypass, fission 

products released directly to environment 

1.1 × 108 4.1 × 102 1.3 × 109 2.0 × 105 328.65 1.3 × 103 1.2 × 103

CI Containment isolation failure 

occurs prior to onset of core damage 

1.3 × 109 2.0 × 103 1.7 × 1011 1.3 × 106 9.64 3.3 × 105 2.7 × 105

CFE Early containment failure, after 

onset of core damage but before core relocation 

7.5 × 109 1.2 × 102 1.1 × 109 6.5 × 106 68.13 2.7 × 104 1.9 × 104

CFI Intermediate containment 

failure, after core relocation but before 24 hr 

1.9 × 1010 3.0 × 104 3.0 × 1012 1.3 × 107 1.67 6.3 × 106 3.3 × 106

CFL Late containment failure 

occurring after 24 hr 

3.5 × 1013 3.2 × 107 0.0 × 100 1.0 × 1010 0.01 2.7 × 108 7.4 × 1010

Total 2.4 × 107 5.6 × 102 2.4 × 109 2.8 × 105 408.40 1.6 × 103 1.4 × 103

(a) To convert person-rem to person-Sv, divide by 100. (b) Early fatalities are fatalities related to high doses or dose rates that generally can be expected to occur within a year of the exposure (Jow et al. 1990). (c) Latent fatalities are fatalities related to low doses or dose rates that can be expected to occur after a latent period of several (2 to 15) years. (d) Cost risk includes costs associated with short-term relocation of people, decontamination, interdiction, and condemnation. It does not include costs 

associated with health effects (Jow et al. 1990). 

(e) Land risk is area where the average whole body dose rate for the 4-year period following the accident exceeds 0.5 rem/yr but can be reduced to less than 

0.5 rem/yr by decontamination. 

2 
Operational Impacts at the Proposed Site 

Draft NUREG-1941 5-112 August 2010 Table 5-18. Comparison of Environmental Risks for an AP1000 Reactor at the LNP Site with Risks for Current- 1 Generation Reactors at Five Sites Evaluated in NUREG-1150 2 Core Damage Frequency (per Ryr) 50-mi Population Dose Risk (person-rem/Ryr)(a) Fatalities per Reactor- Year Average Individual Fatality Risk (per Ryr) Early Latent Early Latent Cancer Grand Gulf(b) 4.0 × 106 5 × 101 8 × 109 9 × 104 3 × 1011 3 × 1010 Peach Bottom(b) 4.5 × 106 7 × 102 2 × 108 5 × 103 5 × 1011 4 × 1010 Sequoyah(b) 5.7 × 105 1 × 103 3 × 105 1 × 102 1 × 108 1 × 108 Surry(b) 4.0 × 105 5 × 102 2 × 106 5 × 103 2 × 108 2 × 109 Zion(b) 3.4 × 104 5 × 103 4 × 105 2 × 102 9 × 109 1 × 108 AP1000(c) Reactor at the LNP site 2.4 × 107 5.6 × 102 2.4 × 109 2.8 × 105 1.2 × 1011 3.9 × 1011 AP1000(d) Reactor at North Anna 2.4 × 107 8.3 × 102 1.2 × 1010 4.0 × 105 2.6 × 1013 4.9 × 1011 AP1000(e) Reactor at Clinton 2.4 × 107 2.2 × 102 1.4 × 108 1.2 × 105 6.4 × 1013 5.5 × 1011 AP1000(f) Reactor at Grand Gulf 2.4 × 107 1.4 × 102 <1.0 × 1012 6.9 × 106 <1.0 × 1014 2.0 × 1011 AP1000(g) Reactor at the VEGP site 2.4 × 107 2.8 × 102 1.9 × 1010 1.9 × 105 1.6 × 1012 1.1 × 1011 (a) To convert person-rem to person-Sv, divide by 100. (b) Risks were calculated using the MACCS code and presented in NUREG-1150 (NRC 1990). (c) Calculated with MACCS2 code using LNP site-specific input. (d) NUREG-1811 (NRC 2006a). (e) NUREG-1815 (NRC 2006b). (f) NUREG-1817 (NRC 2006c). (g) NUREG-1872 (NRC 2008c). 
Operational Impacts at the Proposed Site 

August 2010 5-113 Draft NUREG-1941 

1 Table 5-19. Comparison of Environmental Risks from Severe Accidents Initiated by Internal 

2 Events for an AP1000 Reactor at the LNP Site with Risks Initiated by Internal 

3 Events for Current Nuclear Power Plants Undergoing Operating License Renewal 

4 Review and Environmental Risks of the AP1000 Reactor at Other Sites 

Core Damage Frequency 

(per year)

50-mi Population Dose 

Risk (person-rem/Ryr)(a)

Current reactor maximum(b) 2.4 × 104 6.9 × 101

Current reactor mean(b) 2.7 × 105 1.6 × 101

Current reactor median(b) 1.6 × 105 1.3 × 101

CREC Unit 3(c)

 5.0 × 106 4.0 × 100

Current reactor minimum(b) 1.9 × 106 3.4 × 101

AP1000 LNP Unit 1 or 2(d)(e) 2.4 × 107 5.6 × 102

AP1000(f) reactor at North Anna 2.4 × 107 8.3 × 102

AP1000(g)

 reactor at Clinton 2.4 × 107 2.2 × 102

AP1000(h) reactor at Grand Gulf 2.4 × 107 1.4 × 102

AP1000(i) reactor at the Vogtle site 2.4 × 107 2.8 × 102

(a) To convert person-rem to person-Sv, divide by 100. 

(b) Based on MACCS (Chanin et al. 1990) and MACCS2 (Chanin and Young 1997) calculations for 76 current 

plants at 44 sites. 

(c) PEF 2008b. 

(d) PEF 2009a, LNP MACCS2 Results. 

(e) Calculated with MACCS2 code using LNP site-specific input. 

(f) NUREG-1811 (NRC 2006a). 

(g) NUREG-1815 (NRC 2006b). 

(h) NUREG-1817 (NRC 2006c). 

(i) NUREG-1872 (NRC 2008c). 

5 The following quantitative health objectives are used in determining achievement of the safety 

6 goals: 

7 The risk to an average individual in the vicinity of a nuclear power plant of prompt fatalities 

8 that might result from reactor accidents should not exceed 0.1 of 1 percent (0.1 percent) of 

9 the sum of prompt fatality risks resulting from other accidents to which members of the 

10 U.S. population are generally exposed. 

11 The risk to the population in the area near a nuclear power plant of cancer fatalities that 

12 might result from nuclear power plant operation should not exceed 0.1 of 1 percent 

13 (0.1 percent) of the sum of cancer fatality risks resulting from all other causes. 
Operational Impacts at the Proposed Site 

Draft NUREG-1941 5-114 August 2010 

1 Individual members of the public should be provided a level of protection from the 

2 consequences of nuclear power plant operation such that individuals bear no significant 

3 additional risk to life and health. 

4 Societal risks to life and health from nuclear power plant operation should be comparable to 

5 or less than the risks of generating electricity by viable competing technologies and should 

6 not be a significant addition to other societal risks. 

7 These quantitative health objectives are translated into two numerical objectives as follows: 

8 The individual risk of a prompt fatality from all “other accidents to which members of the 

U.S. population are generally exposed” is about 4.0 × 104/yr, including a 1.6 × 104 9 /yr risk 

10 associated with transportation accidents (NSC 2006). One-tenth of 1 percent of these 

11 figures imply that the individual risk of prompt fatality from a reactor accident should be less 

than 4 × 107 12 /Ryr. 

13 “The sum of cancer fatality risks that result from all other causes” for an individual is taken to 

be the cancer fatality rate in the United States, which is about 1 in 500 or 2 × 103 14 /yr (Reed 

15 2007). One-tenth of 1 percent of this implies that the risk of cancer to the population in the 

area near a nuclear power plant from its operation should be limited to 2 × 106 16 /Ryr. 

17 MACCS2 calculates average individual early and latent cancer fatality risks. The average 

18 individual early fatality risk is calculated using the population distribution within 1 mi of the plant 

19 boundary. The average individual latent cancer fatality risk is calculated using the population 

20 distribution within 10 mi of the plant. For the plants considered in NUREG-1150, these risks 

21 were well below the Commission’s safety goals. Risks calculated by PEF for the AP1000 

22 reactor design at the LNP site are also well below the Commission’s safety goals. 

23 The NRC staff compared the CDF and population dose risk estimate for an AP1000 reactor at 

24 the LNP site with statistics summarizing the results of contemporary severe accident analyses 

25 performed for 76 reactors at 44 sites. The results of these analyses are included in the final 

26 site-specific Supplements 1 through 37 to the GEIS for license renewal (NUREG-1437) (NRC 

27 1996) and in the ERs included with license renewal applications for the power stations for which 

28 supplements have not been published. All of the analyses were completed after publication of 

29 NUREG-1150 (NRC 1990), and the analyses for 72 of the reactors used MACCS2, which was 

30 released in 1997. Table 5-19 shows that the CDF estimated for the AP1000 reactor is 

31 significantly lower than those of current-generation reactors. Similarly, the population doses 

32 estimated for an AP1000 reactor at the LNP site are well below the mean and median values for 

33 current-generation reactors undergoing license renewal. 

34 Finally, the population dose risk from a severe accident for an AP1000 reactor at the LNP site, 

5.6 × 102 35 person-rem/Ryr (PEF 2009a), may be compared with the dose risk for normal 
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August 2010 5-115 Draft NUREG-1941 

1 operation of a single AP1000 reactor at the LNP site, 6.1 person-rem/Ryr (PEF 2009a); 

2 comparatively, the population dose risk for a severe accident is small.

3 5.11.2.3 Surface-Water Pathway 

4 Surface-water dose pathways are an extension of the air pathway. These pathways cover the 

5 effects of radioactive material deposited on open bodies of water and include ingestion of water 

6 and aquatic foods as well as water submersion and activities occurring near the water. Of these 

7 surface-water pathways, the ingestion of contaminated water was evaluated by MACCS2 

8 codes. The risks associated with this pathway were calculated for the LNP site and are 

included in the last column of Table 5-17. The water-ingestion dose risk of about 1.4 × 103 9 

person-rem/Ryr is small compared to the total dose risk of 5.6 × 102 10 person-rem/Ryr (PEF 

11 2009a). 

12 PEF based its assessment of the impacts of submersion in water and ingestion of aquatic food 

13 on the analyses presented in NUREG-1437 for license renewals for current-generation reactors 

14 (NRC 1996), which relies on the analysis in the Fermi Final Environmental Statement (NRC 

15 1981, 1982) and the Liquid Pathway Generic Study (NRC 1978). These analyses indicate that 

16 the aquatic-food pathway is about a factor of 20 larger than the water-ingestion pathway dose, 

17 which is slightly larger than the dose from shoreline activities and significantly larger than the 

18 dose from swimming. They also indicate that interdiction can reduce doses by as much as a 

19 factor of 10. The MACCS2 results in Table 5-17 show that the water-ingestion dose is a small 

20 fraction of the air-pathway dose. This indicates that the doses from shoreline activity and 

21 swimming would also be small. The NRC staff concurs that the risks associated with shoreline 

22 activities and swimming would be significantly smaller than the air-pathway dose risk, 

23 particularly if interdiction is considered. 

24 With respect to the aquatic-food dose, the ER states: “For coastal and estuary sites with large 

25 annual aquatic harvests, interdiction can provide dose reductions such that the population dose 

26 is essentially the same as the atmospheric pathway which is considered a SMALL impact.” The 

27 ER then goes on to note that the LNP site is about 8 mi from the coast and therefore the doses 

28 for the LNP would be lower than for a true coastal site. 

29 The NRC staff notes that Table 5.16 of NUREG-1437 contains an estimate of aquatic-food 

doses and dose risks for CREC Unit 3. The food dose is estimated as 1.5 × 108 30 person-rem 

and the dose risk as 1.4 × 103 31 person-rem/Ryr. The relevant CDF for CREC Unit 3 is 

5 × 106 32 /Ryr (PEF 2008b). Adjusting the CREC aquatic-food dose for differences in CDFs and 

33 reactor power levels, the staff estimates that the aquatic-food dose for the LNP would be about 

34 2 person-rem/Ryr if the LNP were located at the CREC site. Finally, the staff notes that the 

35 deposition between the LNP site and the coast and interdiction of aquatic food would 

36 significantly reduce the aquatic-food dose risk. On this basis, the NRC staff believes that the 
Operational Impacts at the Proposed Site 

Draft NUREG-1941 5-116 August 2010 

1 aquatic-food pathway risk with interdiction may be comparable to or larger than the air-pathway 

2 risk, but that it is small compared to the risk of normal operation or a severe accident at CREC 

3 Unit 3. 

4 5.11.2.4 Groundwater Pathway 

5 The groundwater pathway involves a reactor core melt, reactor vessel failure, and penetration of 

6 the floor (basemat) below the reactor vessel. Ultimately, core debris reaches groundwater 

7 where soluble radionuclides are transported with the groundwater. In NUREG-1437, the NRC 

8 staff assumed that the probability of a severe accident with basemat penetration was 

1 × 104 9 /Ryr and concluded that the groundwater-pathway risks were small. The PEF ER 

10 summarizes the discussion in NUREG-1437 and reaches the same conclusion. 

The NRC staff has re-evaluated its assumption of a 1 × 104 11 /Ryr probability of a basemat meltthrough. The NRC staff believes that the 1 × 104 12 probability is too large for new power stations. 

13 Design elements have been included in the AP1000 design to minimize the potential for reactor 

14 core debris to reach groundwater. These elements include external reactor vessel cooling and 

15 ex-vessel core debris cooling. Further, the probability of core melt with a basemat melt-through 

16 should be no larger than the total CDF estimate for the reactor. Table 5-17 gives a total CDF 

estimate of 2.4 × 107 17 /Ryr for the AP1000 reactor. NUREG-1150 indicates that the conditional 

18 probability of a basemat melt-through ranges from 0.05 to 0.25 for current-generation reactors. 

19 If the CDF for AP1000 severe accidents in which containment remains intact are subtracted 

20 from the total AP1000 CDF to get the CDF for severe accidents in which basemat melt-through 

is a possibility, the CDF is on the order of 2 × 108 21 /Ryr. On this basis, the staff believes that a 

basemat melt-through probability of 2 × 108 22 /Ryr is reasonable and still conservative. The 

23 groundwater pathway is also more tortuous and affords more time for implementing protective 

24 actions than the air pathway and, therefore, results in a lower risk to the public. As a result, the 

25 NRC staff concludes that the risks associated with releases to groundwater are sufficiently small 

26 that they would not have a significant effect on the overall plant risk. 

27 5.11.2.5 Externally Initiated Events 

28 The analyses described above are specifically for internally initiated events. The ER states that 

29 the combined CDF for internal fires and floods, which are external initiating events, is about 

30 24 percent of the total CDF for internal initiating events. The ER then states that the CDF for all 

31 events, including internal events, floods, fires, earthquakes, etc., may be estimated by 

32 multiplying the internal events CDF by a factor of 2 (PEF 2009a). 

33 The AP1000 reactor vendor and NRC staff have addressed three externally initiated events 

34 during design certification of the AP1000 reactor: seismic, internal fire, and internal flooding 

35 events. The analyses are described Section 19.1.5 of the Final Safety Evaluation Report 

36 (FSER) for the Revision 15 of the AP1000 reactor design (NRC 2004a). 
Operational Impacts at the Proposed Site 

August 2010 5-117 Draft NUREG-1941 

1 With respect to seismic events, the AP1000 reactor vendor performed a PRA-based seismic 

2 margin analysis. The analysis results indicated that there is high confidence (95 percent) that 

3 safety systems and components would survive a 0.5-g peak acceleration during a seismic 

4 event. The safe-shutdown earthquake for the AP1000 reactor design is 0.3 g. Consequently, 

5 the NRC staff concluded in the FSER that the AP1000 reactor design is acceptable (NRC 

6 2004a). 

7 With respect to internal fires, the AP1000 reactor vendor estimated the fire-induced CDFs to be 

about 5.6 × 108 yr1 during power operation and about 8 × 108 yr1 8 during shutdown, and 

9 considers these estimates to be conservative. While the NRC staff believes that such a 

10 conclusion is not possible without a detailed PRA, the NRC staff, in its safety review, concluded 

11 that the AP1000 reactor design is capable of withstanding severe accident challenges from 

12 internal fires in a manner superior to most, if not all, operating plant designs (NRC 2004a). 

13 With respect to internal flooding, the AP1000 reactor vendor did not perform a detailed PRA to 

14 assess the risk from internal flooding. Instead, the vendor performed an internal flooding PRA 

15 commensurate with the level of detail available and, where detailed information was not 

16 available, made conservative assumptions to bound the flooding analysis. In its safety review, 

17 the NRC staff found that this analysis was adequate to identify potential vulnerabilities and to 

18 lend insight into the design that could be used to support design-certification requirements. 

19 Quantification of potential scenarios with the plant at power resulted in a total CDF from internal 

floods of about 1 × 109 yr1 20 . The CDF from internal floods when the power station is shutdown 

is estimated to be about 3.2 × 109 yr1 21 . The vendor considers these estimates to be 

22 conservative. While the NRC staff believes that such a conclusion is not possible without a 

23 detailed PRA, the NRC staff, in its safety review, concluded that the AP1000 reactor design is 

24 capable of withstanding severe accident challenges from internal floods in a manner superior to 

25 operating plants and is consistent with the conclusions from the vendor’s internal flood risk 

26 analysis (NRC 2004a). 

27 5.11.2.6 Summary of Severe Accident Impacts 

28 The PEF application refers to proposed Revision 17 of the AP1000 reactor certified design 

29 (10 CFR Part 52, Appendix D). The consequence assessment is based on the PRA for 

30 Revision 15 of the AP1000 design (Westinghouse 2005), which is certified in 10 CFR Part 52, 

31 Appendix D. Westinghouse subsequently upgraded and updated the PRA; however, 

32 Westinghouse reviewed the AP1000 PRA report submitted with Revision 15 of the DCD and 

33 concluded that the reported results and insights remain valid for proposed revisions of the DCD 

34 (Westinghouse 2007a). The NRC staff evaluated the current PRA model and its results using 

35 DC/COL-ISG-3 (NRC 2008b), “Probabilistic Risk Assessment Information to Support Design 

36 Certification and Combined License Applications,” and concluded that the Revision 15 results 

37 remain conservative and are an acceptable basis for evaluating severe accidents and strategies 

38 for mitigating them. PEF is required by regulation to upgrade and update the PRA prior to fuel 
Operational Impacts at the Proposed Site 

Draft NUREG-1941 5-118 August 2010 

1 loading. At that time, the NRC staff expects the PRA to be site-specific and that it will no longer 

2 use the bounding assumptions of the design-specific PRA. The NRC staff considers it unlikely 

3 that the PRA would change sufficiently to cause the staff to materially change its conclusions 

4 related to severe accident risks. 

5 The NRC staff reviewed the risk analysis in the ER and conducted a confirmatory analysis of the 

6 probability-weighted consequences of severe accidents for the proposed LNP Units 1 and 2 

7 using the MACCS2 code. The results of both the PEF analysis and the NRC evaluation indicate 

8 that the environmental risks associated with severe accidents if an AP1000 reactor were to be 

9 located at the LNP site would be small compared with risks associated with operation of the 

10 current-generation reactors at other sites. These risks are below the NRC safety criteria. On 

11 these bases, the NRC staff concludes that the probability-weighted consequences of severe 

12 accidents at the LNP site would be SMALL for an AP1000 reactor. 

13 5.11.3 Severe Accident Mitigation Alternatives 

14 The purpose of the evaluation of severe accident mitigation alternatives (SAMAs) is to 

15 determine whether there are severe accident mitigation design alternatives (SAMDAs), 

16 procedural modifications, or training activities that can be justified to further reduce the risks of 

17 severe accidents (NRC 2000b). PEF based its COL application on the AP1000 reactor design 

18 (see Appendix D of 10 CFR Part 52 – Design Certification Rule for the AP1000 Design), which 

19 incorporates many features intended to reduce severe accident CDFs and the risks associated 

20 with severe accidents. The effectiveness of the AP1000 reactor design features is evident in 

21 Table 5-18 and Table 5-19, which compare CDFs and severe accident risks for the AP1000 

22 reactor with CDFs and risks for current-generation reactors. The CDFs and risks have generally 

23 been reduced considerably when compared to the existing current-generation reactors. 

24 Consistent with the direction from the Commission to consider the SAMDAs at the time of 

25 certification, the AP1000 reactor vendor (Westinghouse 2005) and the NRC staff 

26 (NRC 2004b, 2005), considered a number of design alternatives for an AP1000 reactor at a 

27 generic site. The conclusion of the NRC staff’s review was 

28 ...that none of the potential design modifications evaluated are justified on the 

29 basis of cost-benefit considerations. NRC further concludes that it is unlikely that 

30 any other design changes would be justified in the future on the basis of person–

31 rem exposure because the estimated CDFs are very low on an absolute scale. 

32 Westinghouse reviewed the AP1000 PRA for Revision 15 and concluded that the PRA remains 

33 valid for the proposed revisions to the DCD (Westinghouse 2007a); this is unchanged for 

34 Revision 17. Furthermore, the NRC staff evaluated the current PRA using DC/COL-ISG-3 

35 (NRC 2008b), “Probabilistic Risk Assessment Information to Support Design Certification and 

36 Combined License Applications,” and concluded that the PRA submitted with Revision 15 is a 
Operational Impacts at the Proposed Site 

August 2010 5-119 Draft NUREG-1941 

1 conservative and acceptable basis for evaluating severe accidents and strategies for mitigating 

2 them. Therefore, the NRC staff considers the PRA for DCD Revision 15 to be an adequate 

3 basis for a SAMDA analysis for an application referencing DCD Revision 17. Consequently, the 

4 NRC staff incorporates by reference the environmental assessment accompanying the design5 certification rulemaking for Appendix D to 10 CFR Part 52 (NRC 2006a, b, c). 

6 Section 5.11.2 presents the environmental risks from various classes of severe accidents for the 

7 LNP site. Site-specific information appears in SAMDA evaluations as population dose risk 

8 (person-rem/Ryr) and offsite economic costs ($/Ryr). The staff considers these two elements to 

9 be the appropriate metrics to use to determine whether the site characteristics are bounded by 

10 the site parameters because they are calculated from the site-specific meteorology, population 

11 distribution, and land-use data. Appendix 1B of the AP1000 DCD lists the population dose risk 

12 (person-rem/Ryr) used in the DCD generic SAMDA review. While it does not list the offsite 

13 economic costs, it does include a maximum attainable benefit that considers offsite economic 

14 costs, onsite exposure costs, onsite cleanup costs, and replacement power costs, in addition to 

15 the cost associated with the offsite population dose risk. To perform a like-kind comparison, the 

16 NRC staff used the maximum attainable benefit cost for the LNP site characteristic. The 

17 probability-weighted, mean population dose risks from Table B1-1 in Appendix 1B and the base18 case maximum attainable benefit listed in Table B1-4 are the metrics used by the NRC staff to 

19 determine whether the LNP site characteristics are within the site parameters specified in 

20 Appendix 1B. 

21 Table 5-20 presents the comparison of LNP site-specific metric values (PEF 2009a) with the 

22 generic values from Appendix 1B of the AP1000 DCD (Westinghouse 2008). Table 5-20 shows 

23 that the population dose risk for the LNP site is about 33 percent larger than the DCD 

24 Appendix 1B value, while the maximum attainable benefit for the LNP site is only about 

25 60 percent of the DCD Appendix 1B value. 

26 Table 5-20. Comparison of LNP SAMDA Site Characteristics with Site Parameters Specified in 

27 AP1000 DCD Appendix 1B 

Population Dose Risk, 

person-rem/Ryr

Maximum Attainable

Benefit 

DCD Appendix 1B (internal events) 4.3 × 102 $21,000 

LNP site (internal events) 5.6 × 102 $12,700 

LNP site risk as fraction of DCD risk 133 percent 60 percent

28 The generic AP1000 SAMDA analysis is presented in Appendix 1B of the DCD (Westinghouse 

29 2008). Design alternatives considered by Westinghouse and their estimated implementation 

30 costs are presented in Table 5-21 (Westinghouse 2008). In the base-case analysis, the benefit31 cost methodology of NUREG/BR-0184 (NRC 1997) is used to calculate the maximum attainable 

32 benefit. The analysis assumes that the implementation of the design alternative completely 
Operational Impacts at the Proposed Site 

Draft NUREG-1941 5-120 August 2010 

1 eliminates all potential for core damage. For the AP1000, the maximum attainable benefit was 

2 valued at $21,000 in Appendix 1B, Section 1B.1.8 of the AP1000 CDC Revision 17 

3 (Westinghouse 2008). Only one design alternative in Table 5-21 – the self-actuating 

4 containment isolation valves – has a cost ($33,000) that is comparable to the maximum 

5 attainable benefit. To evaluate the benefit of this SAMDA, the design change was assumed to 

6 eliminate the containment isolation severe accident release category, which is only a small 

7 contributor to the total CDF. Therefore, this design alternative provides almost no benefit in 

8 reducing the AP1000 CDF. 

9 Table 5-21. Design Alternatives Considered for SAMDA in the AP1000 DCD

No. Design Alternative Cost ($) 

1 Upgrade chemical, volume, and control system for small loss-of-coolant accident 

(LOCA) 

1,500,000 

2 Containment filtered vent 5,000,000 

3 Self-actuating containment isolation valves 33,000 

4 Safety grade passive containment spray 3,900,000 

6 Steam generator shell-side heat removal 1,300,000 

7 Steam generator relief flow to in-containment refueling water storage tank (IRWST) 620,000 

8 Increased steam generator pressure capability 8,200,000 

9 Secondary containment ventilation with filtration 2,200,000 

10 Diverse IRWST injection valves 570,000 

12 Ex-vessel core catcher 1,660,000 

13 High-pressure containment design 50,000,000 

14 More reliable diverse actuation system 470,000

Source: Westinghouse 2008 

10 The PEF ER updates the SAMDA analysis conducted for AP1000 design certification using the 

11 results of the LNP site-specific consequence analysis (MACCS2) discussed in Section 7.2 of the 

12 ER. The results of the PEF analysis indicate that the maximum potential benefit if the total risk 

13 for the LNP could be reduced to zero has a value of about $26,000. Similar to the finding in the 

14 AP1000 DCD SAMDA analysis, only the self-actuating containment isolation valves design 

15 alternative (Table 5-21) has a value comparable to the maximum attainable benefit for the LNP 

16 site. 

17 Table 5-17, which lists the mean environmental risks from an AP1000 reactor severe accident at 

18 the LNP site, shows that the containment isolation severe accident category only contributes a 

19 small fraction to the total population dose (approximately 1 percent) and cost risk (approximately 

20 0.1 percent) at the LNP site. Assuming that implementation of the self-actuating containment 

21 isolation valves completely eliminates the risks associated with this release category, then the 

22 value of the reduction in risk would only be about $260. Thus, the site-specific SAMDA review 

23 conducted by PEF confirms the results of the design-certification SAMDA review. Although the 
Operational Impacts at the Proposed Site 

August 2010 5-121 Draft NUREG-1941 

1 dose risk for the LNP site exceeds the DCD value, the site-specific SAMDA analysis for the LNP 

2 site shows that the resulting design alternative (self-actuating containment isolation valves) 

3 would only reduce this total risk by a small fraction. The next lowest cost design alternative has 

4 more than an order-of-magnitude higher cost than the self-actuating containment isolation 

5 valves. On this basis, the NRC staff concludes that, in fact, there are no potential design 

6 modifications that are justified on the basis of benefit-cost considerations, and it is unlikely that 

7 any other design changes would be justified in the future on the basis of person-rem exposure 

8 because the estimated CDFs are very low on an absolute scale. 

9 The PRA upon which the AP1000 and LNP severe accident reviews are based was conducted 

10 for Revision 15 of the AP1000 design. Westinghouse subsequently upgraded and updated the 

11 PRA; however, Westinghouse reviewed the AP1000 PRA report submitted with Revision 15 of 

12 the DCD and concluded that the reported results and insights remain valid for proposed 

13 revisions of the DCD (Westinghouse 2007a). The NRC staff evaluated the current PRA model 

14 and its results using DC/COL-ISG-3 (NRC 2008b), “Probabilistic Risk Assessment Information 

15 to Support Design Certification and Combined License Applications,” and concluded that the 

16 Revision 15 results remain conservative and are an acceptable basis for evaluating severe 

17 accidents and strategies for mitigating them. PEF is required by regulation to update the PRA 

18 prior to fuel loading. The NRC staff expects the PRA to be site-specific rather than use the 

19 bounding assumptions used for the design-specific PRA. The NRC staff considers it unlikely 

20 that the PRA would change sufficiently to cause the NRC staff to conclude that any SAMDA 

21 considered in the design-certification process would become cost beneficial. 

22 The SAMDA issue is a subset of the SAMA review. The other attributes of the SAMA review, 

23 namely procedural modifications and training activities, have not yet been addressed by PEF. 

24 However, PEF has stated (PEF 2009a) that risk insights would be considered in the 

25 development of plant procedures and training. Because the maximum attainable benefit is so 

26 low, a SAMA based on procedures or training for an AP1000 reactor at the LNP site would have 

27 to reduce the CDF or risk to near zero to become cost beneficial. Based on its evaluation, the 

28 staff concludes that it is unlikely that any of the SAMAs based on procedures or training would 

29 reduce the CDF or risk that much. Therefore, the staff further concludes it is unlikely that these 

30 SAMAs would be cost effective. In addition, based on statements by PEF in the ER (PEF 

31 2009a), the staff expects that PEF will consider risk insights in the development of procedures 

32 and training. However, this expectation is not crucial to the staff’s conclusions because the staff 

33 already concluded procedural and training SAMAs would be unlikely to be cost effective. 

34 Therefore, the NRC staff concludes that SAMAs have been appropriately considered. 

35 5.11.4 Summary of Postulated Accident Impacts 

36 The NRC staff evaluated the environmental impacts from DBAs and severe accidents for 

37 AP1000 reactors at the LNP site. Based on the information provided by PEF and the NRC’s 

38 independent review, the NRC staff concludes that the potential environmental impacts (risks) 
Operational Impacts at the Proposed Site 

Draft NUREG-1941 5-122 August 2010 

1 from a postulated accident from the operation of the proposed LNP Units 1 and 2 would be 

2 SMALL, and no further mitigation would be warranted. 

3 5.12 Measures and Controls to Limit Adverse Impacts During 

4 Operation 

5 In its evaluation of environmental impacts during operation of proposed Units 1 and 2, the 

6 review team relied on PEF’s compliance with the following measures and controls that would 

7 limit adverse environmental impacts: 

8 compliance with applicable Federal, State, and local laws, ordinances, and regulations 

9 intended to prevent or minimize adverse environmental impacts 

10 compliance with applicable requirements of permits or licenses required for operation of the 

11 new units (e.g., National Pollutant Discharge Elimination System permit) 

12 compliance with existing CREC processes and/or procedures applicable to proposed LNP 

13 Units 1 and 2 operational environmental compliance activities for the LNP site 

14 compliance with existing CREC procedures for environmental control and management 

15 applicable to proposed LNP Units 1 and 2 

16 Compliance with FDEP Conditions of Certification 

17 implementation of BMPs. 

18 The review team considered these measures and controls in its evaluation of the impacts of 

19 plant operation. Table 5-22, which is the staff’s adaptation from sections of PEF’s ER 

20 Table 5.10-1 (PEF 2009a), lists a summary of measures and controls to limit adverse impacts 

21 during operation proposed by PEF. 
Operational Impacts at the Proposed Site 

August 2010 5-123 Draft NUREG-1941 

1 Table 5-22. Summary of Proposed Measures and Controls to Limit Adverse Impacts During 

2 Operation 

Resource Category Specific Measures and Controls

Land Use Onsite land-use impacts from operation of LNP Units 1 and 2 

are expected to be minimal because minimal additional land 

would be affected other than the land disturbed during erection 

of the plant. Stormwater controls would be maintained during 

operations to minimize erosion and sedimentation onsite. 

Land-use impacts during transmission-line operations would be 

associated with corridor maintenance activities for actions such 

as vegetation management, tower repairs, and habitat 

maintenance. Maintenance practices are designed to be both 

preventative and corrective. No ground-disturbing activities are 

planned to occur during the maintenance of transmission lines. 

Stormwater controls would be maintained during operations to 

minimize erosion and sedimentation in the offsite areas. 

Water-Related

Hydrologic Alterations The FDEP conditions of certification require PEF to develop an 

environmental monitoring plan, which includes a hydraulic 

testing program during drilling and construction of the 

proposed water-supply wells to obtain site-specific hydraulic 

property estimates and determine whether the wellfield can 

meet groundwater-usage impacts without significantly affecting 

water levels in the surficial aquifer. Conditions of certification 

require that operational impacts of the LNP wellfield limit 

drawdowns in the surficial aquifer to levels that ensure no 

adverse impacts on wetlands. 

Water-Use Impacts No mitigation would be required for pumping water from the 

Gulf of Mexico via the CFBC. 

Water-Quality Impacts PEF would obtain a new NPDES permit or seek modifications 

to the CREC NPDES permit to allow LNP blowdown discharge 

to the Gulf of Mexico via the CREC discharge canal. PEF 

would comply with the NPDES permit limits and monitoring 

requirements for discharges to the Gulf of Mexico. 

No mitigation would be required for changes in water 

movement and temperature changes associated with the 

operation of the LNP intake. 

A groundwater quality monitoring program would be instituted 

to detect any detrimental impacts, and wellfield operations 

would be managed to mitigate any significant decreases in 

water quality. 

3 
Operational Impacts at the Proposed Site 

Draft NUREG-1941 5-124 August 2010 

Table 5-22. (contd) 

Impact Category Specific Measures and Controls

Ecology

Terrestrial Ecosystems Light pollution during facility operation could affect wildlife 

residing on or migrating through the LNP site. Possible 

mitigation measures could include the use of lower-wattage 

lights, hooded or down-turned lights, and turning unnecessary 

lights off at night. 

A condition of certification by the FDEP would require the 

applicant to develop an Avian Protection Plan for the 

transmission lines that would include measures to reduce the 

potential for bird collisions with structures and lines. 

Vegetation control for transmission-line maintenance within 

wetlands would follow restrictive vegetation-clearing practices 

(hand clearing with chain saws or use of low-ground pressure 

shear or rotary machines to reduce soil compaction and limit 

vegetation damage). Whenever maintenance is required in 

wetlands and other environmentally sensitive areas not served 

by access roads or fill pads, temporary matting would be used 

as necessary to minimize damage to wetland soils during 

repairs. 

Chemical methods of vegetation control within transmission 

lines would only include the use of herbicides registered by the 

EPA and approved by the State of Florida. Herbicide use 

would be in accordance with manufacturer specifications and 

carried out by licensed applicators. 

Stormwater from the newly developed facilities would be 

collected through a stormwater-drainage system and directed 

into three stormwater-retention and/or infiltration ponds for 

treatment. Stormwater runoff from roadways would be 

managed using a series of roadside swales. These 

stormwater facilities would minimize impacts on wetlands from 

stormwater runoff and would allow for aquifer recharge of 

stormwater via infiltration. 

Uncertainty exists regarding the potential for wetland impacts 

from groundwater withdrawal. Hydrological monitoring to 

ensure that groundwater withdrawals do not adversely affect 

wetlands would be required under the State-imposed 

conditions of certification. If wellfield aquifer performance 

testing, revised groundwater modeling, or environmental 

monitoring of wetlands should detect adverse wetland 

impacts, PEF would be required to mitigate the impacts or 

implement an approved alternative water-supply project. 
Operational Impacts at the Proposed Site 

August 2010 5-125 Draft NUREG-1941 

Table 5-22. (contd) 

Impact Category Specific Measures and Controls

Unavoidable wetland impacts would be mitigated in 

compliance with Federal and State permitting processes. PEF 

has prepared a mitigation plan that would compensate for the 

loss or impairment of wetland functions affected by operation 

of the LNP site and the associated offsite facilities. PEF has 

committed to providing at least as many Uniform Mitigation 

Assessment Methodology functional lift units as the actual 

LNP project losses incurred. 

A condition of certification by the FDEP would require protocol 

surveys for listed species (excluding plants) that may occur on 

the LNP site and associated offsite facilities prior to land 

“clearing and construction”. If listed species are detected and 

operational impacts cannot be avoided, appropriate mitigation 

may be required on a case-by-case basis as determined 

through consultation with the FFWCC. Under wetland 

mitigation planning, several hundred acres of low-value pine 

plantations and degraded wetlands would be rehabilitated and 

restored to native upland and wetland plant communities. The 

higher-quality habitat provided by these restored communities 

would likely be beneficial to many listed species. 

Aquatic Ecosystems Closed-cycle cooling, intake screens parallel with canal flow, 

and low approach velocity of traveling screens minimize 

impingement and entrainment. 

Discharges to the Gulf of Mexico are expected to meet 

NPDES permitting requirements. Chemical discharges would 

be monitored and concentrations are expected to be below 

criteria that are protective of aquatic life. 

Aquatic resources in transmission-line corridors are protected 

during maintenance by maintaining 25-ft buffer zones of 

existing vegetation with mature heights not exceeding 12 ft at 

locations where the transmission-line corridor crosses a 

navigable waterway with limited use of herbicides near these 

buffer zones following PEF’s Transmission Vegetation 

Management Program. 

Socioeconomic Impacts 

Physical Impacts PEF would obtain air permits and operate systems within 

permit limits and monitor emissions as required, and would 

employ BMPs in operating and maintaining the facility and 

site. 

Community Impacts PEF would stagger outages and outage-workforce schedules 

to moderate traffic congestion and reduce extreme fluctuation 

in the number of temporary workers seeking short-term 

housing. 
Operational Impacts at the Proposed Site 

Draft NUREG-1941 5-126 August 2010 

Table 5-22. (contd) 

Impact Category Specific Measures and Controls

Environmental Justice There are no disproportionate and adverse impacts on 

minorities or low-income populations from any potential 

pathways or practices of these populations. 

Historic and Cultural Resources Take appropriate actions as required by site procedures 

following discovery of potential historic or archaeological 

resources and Florida State site certification process. 

Air Quality PEF would obtain air permits and operate systems within 

permit limits and monitor emissions as required. 

Operation of the proposed Units 1 and 2 cooling towers would 

result in water vapor plumes that would occur in each direction 

of the compass and would be spread over a wide area, 

reducing the time that the plume would be visible from any 

particular location. The average plume lengths would be short 

and would not be long enough to reach the site boundary in 

most directions. No mitigation would be required. 

Operation of the cooling towers could lead to minor 

shadowing, very small increase in precipitation, increases in 

ground-level humidity in the immediate vicinity, and salt 

deposition that is a fraction of the level needed to have visible 

effects on vegetation outside the site boundaries (greater than 

1300 ft). No mitigation would be required.

Radiological Impacts of Normal Operation

Radiation Doses to Members of the 

Public 

Calculated radiation doses to members of the public within 

NRC and EPA standards (10 CFR Part 20, Appendix I of 

10 CFR Part 50, and 40 CFR Part 190). 

Radiological effluent and environmental monitoring programs 

would be implemented. 

Occupational Radiation Doses Estimated occupation doses are within NRC standards 

(10 CFR Part 20). 

Program would be implemented to maintain occupational 

doses ALARA (10 CFR Part 20). 

Radiation Doses to Biota Other Than 

Humans 

Calculated doses for biota are well within NCRP and IAEA 

guidelines. 

Radiological environmental monitoring program would be 

implemented. 
Operational Impacts at the Proposed Site 

August 2010 5-127 Draft NUREG-1941 

Table 5-22. (contd) 

Impact Category Specific Measures and Controls

Nonradioactive Waste

Nonradioactive Waste System Impacts Nonhazardous, nonradioactive, solid waste generated during 

operation would be segregated and recycled to the extent 

practicable. All solid wastes would be transported offsite by 

licensed contractors to existing, licensed, disposal facilities 

operating in compliance with all applicable Federal, State and 

local requirements. No solid wastes would be burned or 

disposed of onsite during operation. 

All nonradioactive liquid wastes from the LNP facility would be 

combined into a single, permitted, and monitored stream that 

would discharge via the CREC discharge canal into the Gulf of 

Mexico. PEF would comply with the NPDES permit, including 

implementing a stormwater pollution prevention plan. 

Nonradioactive gaseous emissions from operations would be 

limited in magnitude. PEF would install equipment with 

appropriate emission controls and comply with all applicable 

Federal, State and local air quality requirements. 

The small quantities of expected nonradioactive hazardous 

waste would be managed and disposed of in accordance with 

Federal, State, and local requirements. PEF has corporate 

programs in place to manage hazardous wastes. 

Mixed Waste Impacts The mixed waste from the LNP facility would be handled and 

managed in accordance with the applicable Federal, State, 

and local requirements. The packaged waste would be stored 

in the auxiliary and radwaste buildings until it is shipped offsite 

to a licensed disposal facility. 

Accidents

Design Basis Accidents Calculated dose consequences of design basis accidents for 

the AP1000 at the LNP site were found to be within regulatory 

limits. 

Severe Accidents Calculated probability-weighted consequences of severe 

accidents for the AP1000 at the LNP site were found to be 

lower than the probability- weighted consequences for current 

operating reactors.

The LNP site parameters are within the site parameters 

considered in the design-certification review of severe 

accident mitigation design alternatives. Therefore, issues 

related to severe accident mitigation design alternatives are 

resolved. Procedural and training alternatives would be 

considered when procedures are developed. 
Operational Impacts at the Proposed Site 

Draft NUREG-1941 5-128 August 2010 

Table 5-22. (contd) 

Impact Category Specific Measures and Controls

Nonradiological Health Impacts Exposure to etiological agents (thermophilic organisms) would 

be limited because discharge is in a control area and 

recreational use of area is prohibited. Noise during operation 

would be maintained below Levy County standards (PEF 

2009a). The potential for acute effects of electromagnetic 

fields from transmission lines would be reduced by 

conformance to National Electric Safety Code standards (PEF 

2009a). Occupational injury and fatality risks would be 

reduced by strict adherence to PEF’s industrial safety program 

and NRC, OSHA, and State safety standards, practices, and 

procedures (FDEP 2010). To mitigate potential transportation 

fatalities, PEF could develop and implement a trafficmanagement plan. 

1 5.13 Summary of Operational Impacts 

2 The review team’s evaluation of the environmental impacts of operations of proposed LNP 

3 Units 1 and 2 is summarized in Table 5-23. Impact levels are denoted in the table as SMALL, 

4 MODERATE, or LARGE as a measure of their expected adverse impacts. Socioeconomic 

5 categories for which the impacts are likely to be beneficial are noted as such in the Impact Level 

6 column. 

7 Table 5-23. Summary of Operational Impacts at the Proposed LNP Site 

Resource Category Comments Impact Level

Land-Use Impacts

Site No adverse impacts projected. SMALL 

Transmission Lines and Offsite 

Areas 

No adverse impacts projected. SMALL 

Water-Related Impacts

Water Use – Surface Water Operational activities would have negligible impacts 

on surface-water availability. 

SMALL 

Water Use – Groundwater Operational activities would have negligible impacts 

on groundwater availability. 

SMALL 

Water Quality – Surface Water Operational activities would have negligible impacts 

on surface-water quality. 

SMALL 

Water Quality – Groundwater Operational activities would have negligible impacts 

on groundwater quality. 

SMALL 

8 
Operational Impacts at the Proposed Site 

August 2010 5-129 Draft NUREG-1941 

Table 5-23. (contd)

Resource Category Comments Impact Level

Ecological Impacts

Terrestrial Ecosystems A range is provided to account for the uncertainty 

that exists regarding the potential effects of 

groundwater withdrawal on wetlands and associated 

biota. 

SMALL to 

MODERATE 

Aquatic Ecosystems Impacts on aquatic ecosystems onsite and at offsite 

facilities would be negligible. Impacts on aquatic 

ecosystems from operation of the CWIS and 

dredging would be minor. Impacts on aquatic 

organisms from operations of the CREC would be 

minor. 

SMALL 

Socioeconomic Impacts 

Physical Limited impacts, because most activities would be 

conducted within enclosed facilities, would be further 

reduced by use of BMPs, use of site buffering, and 

traffic management for the smaller workforce. 

SMALL 

Aesthetics MODERATE aesthetic impacts created along 

transmission-line corridors would continue 

throughout the life of the project. 

MODERATE 

Demography In-migrating workers and their families would 

contribute less than a one-half of 1 percent increase 

to projected populations for 50-mi region or any 

economic impact area county 

SMALL 

Economic Impacts on 

Community 

Added jobs and associated earnings would cause a 

SMALL positive impact on the economy of the three 

counties in the socioeconomic impact area 

Impacts on commercial and recreational fishing 

would be SMALL. 

SMALL 

Beneficial 

Taxes Tax base impacts would be SMALL except in Levy 

County, where they would be LARGE and beneficial. 

SMALL to 

LARGE 

Beneficial 

Infrastructure and Community 

Services 

The operations workforce and in-migrating 

population would be fewer than during site 

preparation activities and would have a minor 

impact. 

SMALL 

Environmental Justice No environmental pathways or health and other 

preconditions of the minority and low-income 

populations were found that would lead to adverse 

and disproportionate impacts. 

SMALL 
Operational Impacts at the Proposed Site 

Draft NUREG-1941 5-130 August 2010 

Table 5-23. (contd)

Resource Category Comments Impact Level

Historic and Cultural Resources Based on PEF procedures and commitments to 

follow those procedures and Florida State site 

certification conditions, if historical and cultural 

resources are discovered, the impacts would be 

SMALL. 

SMALL 

Meteorology and Air Quality 

Impacts

Operation of the cooling tower and intermittent 

operation of various diesel generators would be the 

primary emissions sources for air pollutants. 

SMALL 

Nonradiological Health Impacts Risks from etiological agents would be reduced 

below current low level. Noise impacts would-be 

minimal, complying with all Federal, State, and 

county regulations. Occupational safety and health 

impacts would be limited by compliance with PEF’s 

industrial safety program, and NRC, OSHA, and 

State regulations. Acute effects of electromagnetic 

fields would be avoided by compliance with NESC 

standards. Transportation impacts would be 

minimal. 

SMALL 

Radiological Health Impacts 

 Members of the Public Doses to members of the public would be below 

NRC and EPA standards and there would be no 

observable health impacts (10 CFR Part 20, 

Appendix I to 10 CFR Part 50, 40 CFR Part 190). 

SMALL 

 Plant Workers Occupational doses to plant workers would be below 

NRC standards and program to maintain doses 

ALARA would be implemented. 

SMALL 

 Biota other than Humans Doses to biota other than humans would be well 

below NCRP and IAEA guidelines. 

SMALL 

Nonradioactive Waste Impacts Proposed practices for recycling, minimizing, 

managing, and disposing of wastes and the 

requirement to obtain regulatory approvals for waste 

disposal and discharges would help minimize 

impacts from waste generation at LNP Units 1 and 

2. 

SMALL 

Impacts of Postulated Accidents 

Design Basis Accidents Impacts of design basis accidents would be well 

below regulatory limits. 

SMALL 

Severe Accidents Probability-weighted consequences of severe 

accidents would be lower than the probabilityweighted consequences for currently operating 

reactors. 

SMALL 
Operational Impacts at the Proposed Site 

August 2010 5-131 Draft NUREG-1941 

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32 Sheet, Levy County, Florida. Accessed August 21, 2009 at 
Operational Impacts at the Proposed Site 

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1 http://www.factfinder.census.gov/servlet/ACSSAFFFacts?_event=Search&geo_id=05000US120

2 17&_geoContext=01000US%7C04000US12%7C05000US12017&_street=&_county=Levy&_cit

3 yTown=Levy&_state=04000US12&_zip=&_lang=en&_sse=on&ActiveGeoDiv=geoSelect&_useE

4 V=&pctxt=fph&pgsl=050&_submenuId=factsheet_1&ds_name=ACS_2007_3YR_SAFF&_ci_nbr

5 =null&qr_name=null®=null%3Anull&_keyword=&_industry=. Accession No. ML101960356 

6 U.S. Census Bureau (USCB). 2009b. United States Census Bureau, American Factfinder Fact 

7 Sheet, Citrus County, Florida. Accessed August 21, 2009 at 

8 http://www.factfinder.census.gov/servlet/ACSSAFFFacts?_event=ChangeGeoContext&geo_id=

9 05000US12017&_geoContext=01000US%7C04000US12%7C05000US12075&_street=&_coun

10 ty=Citrus&_cityTown=Citrus&_state=04000US12&_zip=&_lang=en&_sse=on&ActiveGeoDiv=ge

11 oSelect&_useEV=&pctxt=fph&pgsl=010&_submenuId=factsheet_1&ds_name=ACS_2007_3YR

12 _SAFF&_ci_nbr=null&qr_name=null®=null%3Anull&_keyword=&_industry=. Accession No. 

13 ML101960358. 

14 U.S. Census Bureau (USCB). 2009c. United States Census Bureau, American Factfinder Fact 

15 Sheet, Marion County, Florida. Accessed August 21, 2009 at 

16 http://www.factfinder.census.gov/servlet/ACSSAFFFacts?_event=&geo_id=05000US12083&_g

17 eoContext=01000US%7C04000US12%7C05000US12083&_street=&_county=marion&_cityTo

18 wn=marion&_state=04000US12&_zip=&_lang=en&_sse=on&ActiveGeoDiv=geoSelect&_useEV

19 =&pctxt=fph&pgsl=050&_submenuId=factsheet_1&ds_name=DEC_2000_SAFF&_ci_nbr=null&

20 qr_name=null®=null%3Anull&_keyword=&_industry=. Accession No. ML101960361. 

21 U.S. Department of Labor, Bureau of Labor Statistics (BLS). 2005. Local Area Unemployment 

22 Statistics. Labor Force Data By County, 2005 Annual Averages. Accessed June 19, 2010 at 

23 ftp://ftp.bls.gov/pub/special.requests/la/laucnty05.txt. Accession No. ML101930603. 

24 U.S. Department of Labor, Bureau of Labor Statistics (BLS). 2010. Table 1. Incidence Rates 

25 of Nonfatal Occupational Injuries and Illnesses by Industry and Case Types, 2008. U.S. 

26 Department of Labor. Accessed March 1, 2010 at 

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28 U.S. Department of Transportation (DOT). 2003. “From Home to Work, the Average Commute 

29 is 256.4 Minutes.” Omnistats, Volume 3, Issue 4, October 2003. Accession No. ML100621425. 

30 U.S. Environmental Protection Agency (EPA). 2010a. Green Book – Currently Designated 

31 Nonattainment Areas for All Criteria Pollutants. Accessed June 23, 2010 at 

32 http://www.epa.gov/air/oaqps/greenbk/ancl3.html. Accession No. ML101930586. 

33 U.S. Environmental Protection Agency (EPA). 2010b. Climate Change – Greenhouse Gas 

34 Emissions – U.S. Greenhouse Gas Inventory. Accessed February 26, 2010 at 
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3 U.S. Fish and Wildlife Service (FWS). 2002. Migratory Bird Mortality. Prepared by the Division 

4 of Migratory Bird Management, Arlington, Virginia. 

5 U.S. Fish and Wildlife Service (FWS). 2007. National Bald Eagle Management Guidelines. 

6 Available at http://www.fws.gov/pacific/eagle/NationalBaldEagleManagementGuidelines.pdf. 

7 Accession No. ML101960349. 

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9 Hatchett, NRC, dated February 9, 2009, regarding Response to Scoping. Accession No. 

10 ML090720063. 

11 U.S. Fish and Wildlife Service (FWS). 2010. Atlantic Flyway. Accessed May 12, 2010 at 

12 http://www.pacificflyway.gov/Documents/Atlantic_map.pdf. Accession No. ML101930596. 

13 U.S. Geological Survey (USGS). 2009. Streamflow for Old Withlacoochee River near Inglis 

14 Dam recorded by the U.S. Geological Survey (USGS) from October 1, 1969 through September 

15 5, 2009. 

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17 Annual Doses to Man from Routine Releases of Reactor Effluents for the Purpose of Evaluating 

18 Compliance with 10 CFR Part 50, Appendix I. Rev.1, Washington, D.C. 

19 U.S. Nuclear Regulatory Commission (NRC). 1978. Liquid Pathway Generic Study: Impacts of 

20 Accidental Radioactive Releases to the Hydrosphere from Floating and Land-Based Nuclear 

21 Power Plants. NUREG-0440, Washington, D.C. 

22 U.S. Nuclear Regulatory Commission (NRC). 1980. Criteria for Preparation and Evaluation of 

23 Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power 

24 Plants. NUREG-0654/FEMA-REP-1, Revision 1, Washington, D.C. 

25 U.S. Nuclear Regulatory Commission (NRC). 1981. Final Environmental Impact Statement 

26 Related to the Operation of Enrico Fermi Atomic Power Plant, Unit 2. NUREG-0769, 

27 Washington, D.C. 

28 U.S. Nuclear Regulatory Commission (NRC). 1982. Final Environmental Impact Statement 

29 Related to the Operation of Enrico Fermi Atomic Power Plant, Addendum No. 1. NUREG-0769, 

30 Addendum No. 1, Washington, D.C. 
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1 U.S. Nuclear Regulatory Commission (NRC). 1983. Atmospheric Dispersion Models for 

2 Potential Accident Consequence Assessments at Nuclear Power Plants. Regulatory Guide 

3 1.145, Rev. 1, Washington, D.C. 

4 U.S. Nuclear Regulatory Commission (NRC). 1990. Severe Accident Risks: An Assessment 

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6 D.C. 

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

8 for License Renewal of Nuclear Plants. NUREG-1437. Washington, D.C. 

9 U.S. Nuclear Regulatory Commission (NRC). 1997. Regulatory Analysis Technical Evaluation 

10 Handbook: Final Report. NUREG/BR-0184, Washington, D.C. 

11 U.S. Nuclear Regulatory Commission (NRC). 1999. Generic Environmental Impact Statement 

12 for License Renewal of Nuclear Plants. NUREG-1437, Vol. 1, Addendum 1, Washington, D.C. 

13 U.S. Nuclear Regulatory Commission (NRC). 2000a. Environmental Standard Review Plan— 

14 Standard Review Plans for Environmental Reviews for Nuclear Power Plants. NUREG-1555, 

15 Vol. 1, Washington, D.C. Includes 2007 revisions. 

16 U.S. Nuclear Regulatory Commission (NRC). 2000b. Alternative Radiological Source Terms 

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18 Washington, D.C. 

19 U.S. Nuclear Regulatory Commission (NRC). 2002. Final Generic Environmental Impact 

20 Statement on Decommissioning of Nuclear Facilities. NUREG-0586, Supplement 1, Vols. 1 and 

21 2, Washington, D.C. 

22 U.S. Nuclear Regulatory Commission (NRC). 2004a. Final Safety Evaluation for AP1000 

23 Related to Certification of the AP1000 Standard Design. Chapter 19, “Severe Accidents, 

24 AP1000 Standard Design.” Washington, D.C. 

25 U.S. Nuclear Regulatory Commission (NRC). 2004b. Environmental Assessment by the 

26 U.S. Nuclear Regulatory Commission Relating to the Certification of the AP1000 Standard Plant 

27 Design Docket No.52-006. Enclosure 2 to SECY-05-0227, December 14, 2005, Washington, 

28 D.C. 

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30 SECY-05-0277, December 14, 2005, Washington, D.C. 

31 U.S. Nuclear Regulatory Commission (NRC). 2006a. Environmental Impact Statement for an 

32 Early Site Permit (ESP) at the North Anna ESP Site. NUREG-1811, Vol. 1, Washington, D.C. 
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1 U.S. Nuclear Regulatory Commission (NRC). 2006b. Environmental Impact Statement for an 

2 Early Site Permit (ESP) at the Exelon ESP Site. NUREG-1815, Vol. 1, Washington, D.C. 

3 U.S. Nuclear Regulatory Commission (NRC). 2006c. Environmental Impact Statement for an 

4 Early Site Permit (ESP) at the Grand Gulf ESP Site. NUREG-1817, Vol. 1, Washington, D.C. 

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6 Safety Analysis Reports for Nuclear Power Plants, LWR Edition. NUREG-0800, Washington, 

7 D.C. 

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10 ML072120368. 

11 U.S. Nuclear Regulatory Commission (NRC). 2008b. Interim Staff Guidance, Probabilistic Risk 

12 Assessment Information to Support Design Certification and Combined License Applications. 

13 CD/COL-ISG-3. Washington, D.C. Accession No. ML081430675. 

14 U.S. Nuclear Regulatory Commission (NRC). 2008c. Final Environmental Impact Statement for 

15 an Early Site Permit (ESP) at the Vogtle ESP Electric Generating Plant Site. NUREG-1872, 

16 Washington, D.C. 

17 U.S. Nuclear Regulatory Commission (NRC). 2009. Socioeconomic Field Notes for August 20-

18 21, 2007 and December 2-3, 2008 Visits to Levy County and Surrounding Communities. 

19 Accession No. ML091290001. 

20 Young, B. and E. Ciammaichella. 2008. “Cooling Towers.” Section 11.4 in Bay Area Air 

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24 Revision 15. APP-GW-GL-700, Pittsburg, Pennsylvania. 

25 Westinghouse Electric Company (Westinghouse). 2007a. AP1000 Design Control Document, 

26 Revision 16. APP-GW-GL-700, Pittsburg, Pennsylvania. 

27 Westinghouse Electric Company (Westinghouse). 2007b. AP1000 Design Change Proposal 

28 Review for RPRA and Severe Accident Impact. APP-PRA-GER-001 (TER-135), Pittsburg, 

29 Pennsylvania. 

30 Westinghouse Electric Company (Westinghouse). 2008. AP1000 Design Control Document, 

31 Revision 17. APP-GW-GL-700, Pittsburg, Pennsylvania. 
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1 World Health Organization (WHO). 2007. Extremely Low Frequency Fields. Environmental 

2 Health Criteria Monograph No. 238. Geneva, Switzerland. Accession No. ML082880728.