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MONTGOMERY COUNTY PLANNING COMMISSION 

box 311 • norristown • pennsylvania • 19404-0311 • 610-278-3722 

office location: suite 201 • one montgomery plaza • swede & airy streets • norristown pa 

FAX 610-278-3941 • Website www.planning.montcopa.org 

June 27, 2013 

Ms. Cindy Bladey 

5/7 I ,;2.t) ):!; 

/<?PIC .2&/,~P ~ 

Chief, Rules, Announcements, and Directives Branch 

Mail Stop: TWB-05-BOIM 

US Nuclear Regulatory Commission 

Washington, DC 20555-0001 

RE: Comments on the Draft Plant Specific Supplement 49 to NUREG-1437 

Limerick Nuclear Generating Station 

Division of License Renewal 

NRC-20 11-0 166 

Dear Ms. Blad~y: 

I 

00 

We have reviewed the· dnift plant specific Supplement 49 to the generic environmental 

impah state'inerit for the license i:eriewalregarding the Limerick Generating Station, 

Units l a.ilct'·2; · bur comments· on the draft are listed below. ' ·>· .. ·.. ' ·' 

We expect the Nuclear Reguliitdry Commission tb do a: full review ofboth 

enVironmental and public sillety issues ·p'erta.ining to the Limerick Generating Station 

as discussed in the Environmental Impaet Statement and we hope that any relicensing 

decision will also address' specific issues pertaining to the plant based upon it's 

conformity t'o the Montgomery County Comprehensive Plan and overall county 

development policies in the area surrounding it. Overall, we are particularly 

concerned about growth around the power plant, transportation and evacuation 

capacity, the Schuylkill River, and future education about the Limerick Generating 

Station. 

Land Use Change and Growth around the Power Plant: 

:::0 

c 

,-

rn 

c.n 

As the Environmental Impact Statement indicates, the population in the 50-mile 

radius of the plant was 6,819,505 in 1980 ahd·is expected to reach 9,499,925 by 

2030, a 39 percent increase in population: It is also noted that according to 2010 

Census, there are 1,365,850 people residing within 20 miles of the Limerick 131-1 -SE l 

Generating Facility.' Limerick Township, where the plant is located; and n:earby · .. · 

Upper Providence Township have been: two of the mosttapidly growing communities in 

the county. This growth occurring along the US Route 422 Expressway has 

dramatically changed the character of the area surrounding the Limerick Generating 

Station. In' fue ·past few years, the Philadelphia'Premium Outlet.Mall, a ·6oo,ooo ·· 

square foot-retail facility, and the adjoining Costco shopping center opened along US 

Route 422 about one mile north of the Limerick Generating Station property. The land 

adjoining those facilities is being considered for various types of retail and residential 

SUNSI Review Complete 

Template= ADM- 013 

E-RIDS= ADM-03 :---, . Add= ,I._, I.LJ<...f<.~ Uff'-:J- / 
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Ms .. Cindy Bladey -2- June 27, 2013 

uses. Other lands iri'Lower Pottsgrove Township near the Lirrierkk Generating' " 

Station have al~o beei1 proposed for similar types of uses. · · · ,.- ;: 

While the county planning·commissiori 'has tried to promote lower densities· of' growth 

in proximity to the Limerick Generating Station, the local communities :a.nd the · · 

marketplace favor this location for significant development due to its proximity to the 31-1-SE 

US Route· 422 interchange at Township Line/ Evergreen Road. The growth that has Cont'd 

taken place in ilie area· around the power•plant,·and in particular the growth taking 

place in the area immediately adjoining the plant and the primary access· to it, as \vell · 

as the projected growth in the future, could complicate evacuation plans and the 

movement of appropriate emergency response personnel to the plant in the event of a 

disaster. Certainly this access could be even more critical in the event of a natural 

disaster when other roads to the plant may be impassable. The Environmental impact 

Statement needs to analyze this growth in the vicinity of the power plant to evaluate 

what impact it would have on plant operations and whether or not safe evacuation can 

take lace from the new! develo ed areas within the extended licensin eriod. 

Transportation and Evacuation Capacity: 

The growth in the whole US Route 422 Corridor has raised numerous proposals for 

expanding the vehicle capacity of the 422 Expressway. Congested traffic conditions• 

are a way of life along the expres~way and raise concern ab_out future viability o~ the lr- ...,..~.._..,....,S--.I 

expressway and other local artenal roads as a safe evacuation routes for the regwn. IL-_-r-_...J 

The county transportation plan recognizes the need :for various road:improvements 

along the US 422 Corridor to address current and future traffic demands. The 

current county comprehensive plan recommends several measures to enhance 

transportation capacity in this portion of the county, though due to funding 

limitations in Pennsylvania, these projects are not likely to move forward at this time , 

Possible mitigation strategies to be considered in the license renewal could include the 

role of Exelon in funding the important road improvements needed in this area to 

ensure safe evacuation and access to the plant in any type of disaster. 

Schuvlkill River: 

The Limerick Plant will depend upon river water for a longer period of time as a result 

of the license renewal. During low flow periods, additional quantities of water are 

released into the river from the Wadesville Mine and Still Creek Reservoir in Schuylkill 

County to compensate for the water withdrawn at the plant through a docket approved 

by the Delaware River Basin Commission (DRBC). Since the relicensing action would 

extend the time period of this flow augmentation system, continued monitoring and 

analysis of the river is vital to ensure that the water quality of the river is not impaired 

by the total dissolved solids in the Wadesville water among other parameters. This il"-:-......,::----. 

particularly important due to the role of the Schuylkill River, a state scenic river, 31-3- I 

which is an important regional water supply source and recreation area. If resumed SW 

use of the Delaware water diversion is anticipated, an evaluation of that system sho··1u""""a r----' 

be undertaken to ensure that the capacity is available in the conveyance system and 

that water quality objectives can be met for discharge into the East Branch of the n. -'·' r'rPPV 

Community Outreach and Education: 

The relicensing process has raised local questions about the Limerick Generating 

Station. It will become more of a permanent element of the community with extensi 
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~ Radiation Levels Reported By Exelon For Limerick's Releases To Air Do Not Reflect 

Risks To The Public From All Limerick's Radionuclides Released Into Our Air. 

)> JUST BECAUSE EXELON ISN'T REQUIRED TO REPORT ALL RADIONUCLIDES LIMERICK 

RELEASES INTO OUR AIR, DOESN'T MEAN THOSE RADIONUCLIDES DO NOT INCREASE 

OUR RISK. 

Radiation Levels identified by monitoring are only reported for Limerick by Exelon when they are 

above an arbitrary background level. Above background reporting is deceptive. Exelon can hide 

actual radiation releases from Limerick and actual risks. 

Radiation Background Levels Are Arbitrary, Deceptive, and Clearly Not Protective: 

• 80 to 100 Millirems Per Year- Natural background BEFORE Chernobyl 

• 360 Millirems Per Year- AFTER Chernobyl 

• 620 Millirems Per Year- AFTER Fukushima, Japan 

The National Academv of Sciences Says There Is NO SAFE DOSE 

March 16, 2011, After Japan's Nuclear Disaster, NRC Legally Sanctioned Increased Radiation 

Harm To Regions Like Ours, Routinely Exposed To Nuclear Plant Radiation Releases. 

Other Deceptive Unprotrective Tactics In Radiation Reporting 

• Exelon, the company with a vested interest in the outcome that has shown it can't be trusted, controls all 

radiation monitoring, testing, and reporting. 

• Exelon is allowed to 'CALCULATE" and "AVERAGE" results. 

• The system fails to report on radiation spikes. 

Examples From Exelon's 2007 Self-Monitoring Report to NRC 

1. Lower Limit Detection (LLD) - ABOVE BACKGROUND IS DECEPTIVE. 

Defined as smallest concentration of radioactive material in a sample that would yield a net 

LLD does not mean the actual level detected - Level detected could be far higher 

2. Positive Results Were "CALCULATED" ·Gamma Spectroscopy 

Standard deviations represent variability of measured results for different samples rather than single 

analysis uncertainty. 

3. Net Activity- Calculated by subtracting background from sample. 

MDC was reported in all cases- but they can claim positive activity was not detected. 

Radioactive Air Particulates • Air particulate samples collected weekly in 2007. 

)> GROSS BETA WAS DETECTED AT ALL LOCATIONS. 

Beta Emissions Can Include Strontium-90, Tritium, and Many Other Radlonuclides 

)> GAMMA WAS DETECTED IN ALL SAMPLES 

Be-7 Beryllium 7: UNstable (1/2 life 53 days) was detected in all samples 

Beta Particles and Gamma Rays Penetrate the Human Body and Environment, 

Causing Biological, Chemical, and/or Physical Damage. 

12-67-HH I 

ICont'd 

• Cancer, Leukemia, Heart Failure, Neuromuscular Diseases and Many Other Health 

Effects Can Result From Long-Term Exposures. 

• Harmful Health Impacts Can Take Many Years To Develop. 

Examples: Harmful Health Impacts To Specific Parts Of The Bodv 

• Thyroid I Ovaries Iodine- 131 Beta I Gamma Emitter 

• Liver I Ovaries Cobalt - 60 Beta I Gamma Emitter 

• Bone I Ovaries Zinc - 65 Beta I Gamma Emitter 

• Muscles I Ovaries Cesium -137 Beta I Gamma Emitter 

• Bones I Teeth Strontium-90 Beta Emitter 29 year half-life 

41 
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>- Strontium 90 {SR-90) Attaches To Particulate Matter - Easily Travels With Air 

SR-90 Masquerades As Calcium -Absorbs Into Bones and Teeth. 

Some of the highest levels of Strontlum-90 were found In the teeth of children 

around Limerick Nuclear Power Plant {Tooth Fairy Study) 

All GAMMA Radiation Emitters Attack REPRODUCTIVE ORGANS 

• Prostate Cancer Increased in Montgomery County 132% Since Limerick Nuclear Power Plant Started 

(Mid 1980s to Mid 1990s) 

Other related cancers also drastically increased above the national average since Limerick started 

operating. 

Radiation Can Cause Birth Defects, Mutations, and Miscarriages, 12-67-HH I 

In 1•• and I or Successive Generations After Exposure. Cont'd 

Infant death and childhood cancer reductions after nuclear plant closings in the United States · .. uu" 

Study - Deaths among infants who had lived downwind and within 64 km of each plant dropped. 

Infant and Neonatal Mortality In The Area Around Limerick Are Far Higher Than State Averages and 

Higher Than Philadelphia or Reading. 

Other radlonuclldes In testing were claimed by Exelon to be less than the MDC 

~ BUT Minimum Detectable Concentration (MDC) Is Only An 

ESTIMATE and Only Reported IF Above Background 

Limerick Nuclear Plant's Air Pollution Summary: 

• 10-26-11 ACE provided NRC with documented details for Limerick's 

EIS public hearing comments. Our analysis of Limerick's Title V air 

pollution permit and other documentation show why Limerick's air 

pollution is a "major" threat to our region. 

~ NRC ignored this evidence in Limerick's DRAFT EIS conclusions or 

NRC could not have concluded Limerick's air pollution impacts are 

"small". NO unbiased person could analyze the evidence and the 

reality and still come to that conclusion! 

Major Points: 

To avoid air pollution permit violations, in 2009, Limerick requested and received a 6-fold INCREASE in 

its Title V Air Pollution Permit limit for dangerous cooling tower air pollution that is considered more 

deadly than ozone by the American Lung Association. 

>- Exelon's request for huge PM-10 permit increases to avoid air pollution permit 

violations alone makes our case. 

limerick's cooling towers release 44 million gallons of steam into the air every day containing massive 

PM-10, which transports into our air limerick's radioactive air particulates, toxic and corrosive chemicals 

added to limerick's cooling towers by Exelon, toxics from the Schuylkill River including heavy metals, and 

pathogens from inside the cooling towers. 

42 
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LIMERICK'S HIGH-LEVEL RADIOACTIVE WASTES 

NRC'S DRAFT EIS HAS FAILED TO ADEQUATELY ADDRESS THE SITE 

SPECIFIC ENVIRONMENTAL IMPACTS OF THE MASSIVE AMOUNTS OF HIGHLEVEL RADIOACTIVE WASTES CURRENTLY STORED IN FUEL POOLS AND 

CASKS ON THE LIMERICK SITE, AND THE IMPACTS OF THE FUTURE 

PRODUCTION OF LIMERICK'S HIGH-LEVEL RADIOACITVE WASTES DURING 

LIMERICK'S RELICENSING PERIOD. 

What could possibly have more of an impact on the future environment of the entire Greater 

Philadelphia Region than storing more and more of the most deadly materials on earth in fuel 

pools (like Fukushima's) and above ground casks that can eventually leak? 

• Devastating Long-Term Environmental Impacts Can Result From Storing Or 

Transporting Limerick's High-Level Radioactive Wastes. 

NRC's DRAFT EIS Falls To Adequately Address Specific Environmental Impacts of 

The Massive Amounts Of High-Level Radioactive Wastes Currently In Limerick's 

Fuel Pools and Casks. 

)> A New Review Of Limerick's Spent Fuel Storage Is Imperative 

BEFORE Limerick's EIS DRAFT Is Finalized. There Are Many 

Unanswered Questions With Serious Implications For Devastating 

Environmental Consequences For Generations, If Not Forever. 

What could have more impact on the future environment of the entire Greater Philadelphia Region than 

storing massive amounts of the most deadly materials on earth, in corroding and thinning fuel pools, 

originally made with substandard cement, and extremely vulnerable to meltdowns from earthquakes and 

terrorist strikes with planes and missiles (like Fukushima's, high above reactors with no containment)? 

• NRC's decision to allow Exelon to avoid an assessment of environmental impacts from all the deadly 

high-level radioactive wastes stored on the Limerick site until after the EIS is approved for relicensing, 

is really about protecting Exelon's interests, not public interests. 

• There is NO NEED to rush Limerick's relicensing, when its original license doesn't expire for over a 

decade, another 11 years. 

• Given the extreme dangers and destruction faced by the entire Greater Philadelphia from Limerick's 

high-level radioactive waste storage at Limerick, NRC would be negligent to ignore the 

unprecedented threats to the environment and population in Limerick's Environmental Impact 

Statement. =-=::!:-=:-:-:-, 12-78-RW I 

Although re-licensing of Limerick was pushed back 2 years by the June 8, 2012 court decision 

requiring NRC to re-think the environmental impact of storing radioactive wastes (spent-fuel) at 

nuclear plants, Neil Sheehan from NRC made the inexplicable statement in an e-mail to the 

Mercury that NRC's new rules about spent fuel storage, ordered by a court decision to be released 

September 2014, are not likely to affect Limerick's Environment Impact Statement. 

• "There is no expectation that Exelon would have to conduct a new review of 

spent fuel storage at Limerick." (Mercury- March 8, 2013) 

• "Limerick nuke plant relicensing unlikely to be affected by new spent fuel rules" 

(Mercury- March 13, 2013) 

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APPENDIX B 

NATIONAL ENVIRONMENTAL POLICY ACT ISSUES FOR LICENSE 

RENEWAL OF NUCLEAR POWER PLANTS

B. NATIONAL ENVIRONMENTAL POLICY ACT ISSUES FOR LICENSE 

RENEWAL OF NUCLEAR POWER PLANTS

According to the National Environmental Policy Act of 1969, as amended (NEPA), all agencies 

of the Federal Government are required to develop a detailed statement on the environmental 

impact of their proposed major Federal actions significantly affecting the quality of the human 

environment. NUREG-1437, “Generic Environmental Impact Statement for License Renewal of 

Nuclear Power Plants (referred to as the GEIS), documents the results of the U.S. Nuclear 

Regulatory Commission (NRC) staff’s (staff's) systematic approach to evaluating the 

environmental impacts of renewing the licenses of individual nuclear power plants. The GEIS 

was originally published in 1996 and Addendum 1 to the GEIS, which only addresses 

transportation issues, was published in 1999. Of the 92 total environmental issues that the staff 

identified in the 1996 GEIS, the staff determined that 69 are generic to all plants (Category 1), 

while 21 issues must be discussed on a site-specific basis (Category 2). Two other issues, 

environmental justice and the chronic effects of electromagnetic fields, are uncategorized and 

must be evaluated on a site-specific basis.

Table B-1 in this appendix lists all 92 environmental issues, including the possible 

environmental significance (SMALL, MODERATE, LARGE, or uncategorized) as appropriate. 

This table is provided in Chapter 9 of the 1996 GEIS. . 

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

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

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

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

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

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

revised GEIS specifically supports the revised list of NEPA issues and associated 

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

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

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

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

license renewal environmental reviews were reexamined to validate existing environmental 

issues and identify new ones.

This SEIS, which discusses the environmental impacts associated with the proposed Federal 

action of renewing the operating licenses for the Limerick Generating Station, Units 1 and 2 

(LGS), is reviewed against the criteria from the 1996 GEIS. However, under NEPA , the NRC 

must now consider and analyze, in its license renewal SEISs, the potential impacts described by 

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

information , the potential significant impacts described by the final rule’s new Category 1 

issues. Therefore, the new issues identified, or re-categorized, in the 2013 GEIS are also 

included in this SEIS. The new Category 1 issues identified in the 2013 GEIS which are 

discussed and evaluated in Chapter 4 of this SEIS are geology and soils, exposure of terrestrial 

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

impact from chemicals, and physical occupational hazards. The new Category 2 issues that are 

addressed in Chapter 4 of this SEIS are radionuclides released to groundwater, effects on 

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

environmental justice), and cumulative impacts.

B-1 
Appendix B

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

Power Plants

Issue Type of Issue Findings

Surface Water Quality, Hydrology, and Use (for all plants)

Impacts of refurbishment

on surface water quality

Generic SMALL. Impacts are expected to be negligible during 

refurbishment because best management practices are 

expected to be employed to control soil erosion and spills.

Impacts of refurbishment

on surface water use

Generic SMALL. Water use during refurbishment will not increase 

appreciably or will be reduced during plant outage.

Altered current patterns 

at intake and discharge

structures

Generic SMALL. Altered current patterns have not been found to be 

a problem at operating nuclear power plants and are not 

expected to be a problem during the license renewal term.

Altered salinity gradients Generic SMALL. Salinity gradients have not been found to be a 

problem at operating nuclear power plants and are not 

expected to be a problem during the license renewal term.

Altered thermal 

stratification of lakes

Generic SMALL. Generally, lake stratification has not been found to 

be a problem at operating nuclear power plants and is not 

expected to be a problem during the license renewal term.

Temperature effects on 

sediment transport 

capacity

Generic SMALL. These effects have not been found to be a problem 

at operating nuclear power plants and are not expected to 

be a problem during the license renewal term.

Scouring caused by 

discharged cooling water

Generic SMALL. Scouring has not been found to be a problem at 

most operating nuclear power plants and has caused only 

localized effects at a few plants. It is not expected to be a 

problem during the license renewal term.

Eutrophication Generic SMALL. Eutrophication has not been found to be a problem 

at operating nuclear power plants and is not expected to be 

a problem during the license renewal term.

Discharge of chlorine or 

other biocides

Generic SMALL. Effects are not a concern among regulatory and 

resource agencies, and are not expected to be a problem 

during the license renewal term.

Discharge of sanitary 

wastes and minor 

chemical spills

Generic SMALL. Effects are readily controlled through National 

Pollutant Discharge Elimination System (NPDES) permit and 

periodic modifications, if needed, and are not expected to be 

a problem during the license renewal term.

Discharge of other 

metals in waste water

Generic SMALL. These discharges have not been found to be a 

problem at operating nuclear power plants with 

cooling-tower-based heat dissipation systems and have 

been satisfactorily mitigated at other plants. They are not 

expected to be a problem during the license renewal term.

Water use conflicts 

(plants with oncethrough cooling systems)

Generic SMALL. These conflicts have not been found to be a 

problem at operating nuclear power plants with 

once-through heat dissipation systems.

Water use conflicts 

(plants with cooling 

ponds or cooling towers 

using make-up water 

from a small river with 

low flow)

Site-specific SMALL OR MODERATE. The issue has been a concern at 

nuclear power plants with cooling ponds and at plants with 

cooling towers. Impacts on in-stream and riparian 

communities near these plants could be of moderate 

significance in some situations. See § 51.53(c)(3)(ii)(A).

B-2 
Appendix B

Issue Type of Issue Findings

Aquatic Ecology (for all plants)

Refurbishment Generic SMALL. During plant shutdown and refurbishment there will 

be negligible effects on aquatic biota because of a reduction 

of entrainment and impingement of organisms or a reduced 

release of chemicals.

Accumulation of 

contaminants in 

sediments or biota

Generic SMALL. Accumulation of contaminants has been a concern 

at a few nuclear power plants but has been satisfactorily 

mitigated by replacing copper alloy condenser tubes with 

those of another metal. It is not expected to be a problem 

during the license renewal term.

Entrainment of 

phytoplankton and 

zooplankton

Generic SMALL. Entrainment of phytoplankton and zooplankton has 

not been found to be a problem at operating nuclear power 

plants and is not expected to be a problem during the 

license renewal term.

Cold shock Generic SMALL. Cold shock has been satisfactorily mitigated at 

operating nuclear plants with once-through cooling systems, 

has not endangered fish populations, or been found to be a 

problem at operating nuclear power plants with cooling 

towers or cooling ponds, and is not expected to be a 

problem during the license renewal term.

Thermal plume barrier to 

migrating fish

Generic SMALL. Thermal plumes have not been found to be a 

problem at operating nuclear power plants and are not 

expected to be a problem during the license renewal term.

Distribution of aquatic 

organisms

Generic SMALL. Thermal discharge may have localized effects but 

is not expected to affect the larger geographical distribution 

of aquatic organisms.

Premature emergence of 

aquatic insects

Generic SMALL. Premature emergence has been found to be a 

localized effect at some operating nuclear power plants but 

has not been a problem and is not expected to be a problem 

during the license renewal term.

Gas supersaturation 

(gas bubble disease)

Generic SMALL. Gas supersaturation was a concern at a small 

number of operating nuclear power plants with once-through

cooling systems but has been satisfactorily mitigated. It has 

not been found to be a problem at operating nuclear power 

plants with cooling towers or cooling ponds and is not 

expected to be a problem during the license renewal term.

Low dissolved oxygen in 

the discharge

Generic SMALL. Low dissolved oxygen has been a concern at one 

nuclear power plant with a once-through cooling system but 

has been effectively mitigated. It has not been found to be a 

problem at operating nuclear power plants with cooling 

towers or cooling ponds and is not expected to be a problem 

during the license renewal term.

Losses from predation, 

parasitism, and disease 

among organisms 

exposed to sublethal 

stresses

Generic SMALL. These types of losses have not been found to be a 

problem at operating nuclear power plants and are not 

expected to be a problem during the license renewal term.

B-3 
Appendix B

Issue Type of Issue Findings

Aquatic Ecology (for all plants) (continued)

Stimulation of nuisance 

organisms 

(e.g., shipworms)

Generic SMALL. Stimulation of nuisance organisms has been 

satisfactorily mitigated at the single nuclear power plant with 

a once-through cooling system where previously it was a 

problem. It has not been found to be a problem at operating 

nuclear power plants with cooling towers or cooling ponds 

and is not expected to be a problem during the license 

renewal term.

Aquatic Ecology (for plants with once-through and cooling pond heat dissipation systems)

Entrainment of fish and 

shellfish in early life 

stages

Site-specific SMALL, MODERATE, OR LARGE. The impacts of 

entrainment are small at many plants but may be moderate 

or even large at a few plants with once-through and 

cooling-pond cooling systems. Further, ongoing efforts in 

the vicinity of these plants to restore fish populations may 

increase the numbers of fish susceptible to intake effects 

during the license renewal period, such that entrainment 

studies conducted in support of the original license may no 

longer be valid. See § 51.53(c)(3)(ii)(B).

Impingement of fish and 

shellfish

Site-specific SMALL, MODERATE, OR LARGE. The impacts of 

impingement are small at many plants but may be moderate 

or even large at a few plants with once-through and 

cooling-pond cooling systems. See § 51.53(c)(3)(ii)(B).

Heat shock Site-specific SMALL, MODERATE, OR LARGE. Because of continuing 

concerns about heat shock and the possible need to modify 

thermal discharges in response to changing environmental 

conditions, the impacts may be of moderate or large 

significance at some plants. See § 51.53(c)(3)(ii)(B).

Aquatic Ecology (for plants with cooling-tower-based heat dissipation systems)

Entrainment of fish and 

shellfish in early life 

stages

Generic SMALL. Entrainment of fish has not been found to be a 

problem at operating nuclear power plants with this type of 

cooling system and is not expected to be a problem during 

the license renewal term.

Impingement of fish and 

shellfish

Generic SMALL. The impingement has not been found to be a 

problem at operating nuclear power plants with this type of 

cooling system and is not expected to be a problem during 

the license renewal term.

Heat shock Generic SMALL. Heat shock has not been found to be a problem at 

operating nuclear power plants with this type of cooling 

system and is not expected to be a problem during the 

license renewal term.

B-4 
Appendix B

Issue Type of Issue Findings

Groundwater Use and Quality

Impacts of refurbishment

on groundwater use and 

quality

Generic SMALL. Extensive dewatering during the original 

construction on some sites will not be repeated during 

refurbishment on any sites. Any plant wastes produced 

during refurbishment will be handled in the same manner as 

in current operating practices and are not expected to be a 

problem during the license renewal term.

Groundwater use 

conflicts (potable and 

service water; plants that 

use <100 gallons per 

minute [gpm])

Generic SMALL. Plants using less than 100 gpm are not expected to 

cause any groundwater use conflicts.

Groundwater use 

conflicts (potable and 

service water, and 

dewatering; plants that 

use >100 gpm)

Site-specific SMALL, MODERATE, OR LARGE. Plants that use more 

than 100 gpm may cause groundwater use conflicts with 

nearby groundwater users. See § 51.53(c)(3)(ii)(C).

Groundwater use 

conflicts (plants using 

cooling towers 

withdrawing makeup 

water from a small river)

Site-specific SMALL, MODERATE, OR LARGE. Water use conflicts may 

result from surface water withdrawals from small water 

bodies during low flow conditions which may affect aquifer 

recharge, especially if other groundwater or upstream 

surface water users come on line before the time of license 

renewal. See § 51.53(c)(3)(ii)(A).

Groundwater use 

conflicts (Ranney wells)

Site-specific SMALL, MODERATE, OR LARGE. Ranney wells can result 

in potential groundwater depression beyond the site 

boundary. Impacts of large groundwater withdrawal for 

cooling tower makeup at nuclear power plants using Ranney 

wells must be evaluated at the time of application for license 

renewal. See § 51.53(c)(3)(ii)(C).

Groundwater quality 

degradation (Ranney 

wells)

Generic SMALL. Groundwater quality at river sites may be degraded 

by induced infiltration of poor-quality river water into an 

aquifer that supplies large quantities of reactor cooling 

water. However, the lower quality infiltrating water would not 

preclude the current uses of groundwater and is not 

expected to be a problem during the license renewal term.

Groundwater quality 

degradation (saltwater 

intrusion)

Generic SMALL. Nuclear power plants do not contribute significantly 

to saltwater intrusion.

Groundwater quality 

degradation (cooling 

ponds in salt marshes)

Generic SMALL. Sites with closed-cycle cooling ponds may degrade 

groundwater quality. Because water in salt marshes is 

brackish, this is not a concern for plants located in salt 

marshes.

Groundwater quality 

degradation (cooling 

ponds at inland sites)

Site-specific SMALL, MODERATE, OR LARGE. Sites with closed-cycle

cooling ponds may degrade groundwater quality. For plants 

located inland, the quality of the groundwater in the vicinity 

of the ponds must be shown to be adequate to allow 

continuation of current uses. See § 51.53(c)(3)(ii)(D).

B-5 
Appendix B

Issue Type of Issue Findings

Terrestrial Resources

Refurbishment impacts Site-specific SMALL, MODERATE, OR LARGE. Refurbishment impacts 

are insignificant if no loss of important plant and animal 

habitat occurs. However, it cannot be known whether 

important plant and animal communities may be affected 

until the specific proposal is presented with the license 

renewal application. See § 51.53(c)(3)(ii)(E).

Cooling tower impacts 

on crops and ornamental 

vegetation

Generic SMALL. Impacts from salt drift, icing, fogging, or increased 

humidity associated with cooling tower operation have not 

been found to be a problem at operating nuclear power 

plants and are not expected to be a problem during the 

license renewal term.

Cooling tower impacts 

on native plants

Generic SMALL. Impacts from salt drift, icing, fogging, or increased 

humidity associated with cooling tower operation have not 

been found to be a problem at operating nuclear power 

plants and are not expected to be a problem during the 

license renewal term.

Bird collisions with 

cooling towers

Generic SMALL. These collisions have not been found to be a 

problem at operating nuclear power plants and are not 

expected to be a problem during the license renewal term.

Cooling pond impacts on 

terrestrial resources

Generic SMALL. Impacts of cooling ponds on terrestrial ecological 

resources are considered to be of small significance at all 

sites.

Power line right-of-way 

management (cutting 

and herbicide 

application)

Generic SMALL. The impacts of right-of-way maintenance on wildlife 

are expected to be of small significance at all sites.

Bird collision with power 

lines

Generic SMALL. Impacts are expected to be of small significance at 

all sites.

Impacts of 

electromagnetic fields on 

flora and fauna

Generic SMALL. No significant impacts of electromagnetic fields on 

terrestrial flora and fauna have been identified. Such effects 

are not expected to be a problem during the license renewal 

term.

Floodplains and wetland 

on power line right-ofway

Generic SMALL. Periodic vegetation control is necessary in forested 

wetlands underneath power lines and can be achieved with 

minimal damage to the wetland. No significant impact is 

expected at any nuclear power plant during the license 

renewal term.

Threatened or Endangered Species (for all plants)

Threatened or 

endangered species

Site-specific SMALL, MODERATE, OR LARGE. Generally, plant 

refurbishment and continued operation are not expected to 

adversely affect threatened or endangered species. 

However, consultation with appropriate agencies would be 

needed at the time of license renewal to determine whether 

threatened or endangered species are present and whether 

they would be adversely affected. See § 51.53(c)(3)(ii)(E).

B-6 
Appendix B

Issue Type of Issue Findings

Air Quality

Air quality during 

refurbishment

(nonattainment and 

maintenance areas)

Site-specific SMALL, MODERATE, OR LARGE. Air quality impacts from 

plant refurbishment associated with license renewal are 

expected to be small. However, vehicle exhaust emissions 

could be cause for concern at locations in or near 

nonattainment or maintenance areas. The significance of 

the potential impact cannot be determined without 

considering the compliance status of each site and the 

numbers of workers expected to be employed during the 

outage. See § 51.53(c)(3)(ii)(F).

Air quality effects of 

transmission lines

Generic SMALL. Production of ozone and oxides of nitrogen is 

insignificant and does not contribute measurably to ambient 

levels of these gases.

Land Use

Onsite land use Generic SMALL. Projected onsite land use changes required during 

refurbishment and the renewal period would be a small 

fraction of any nuclear power plant site and would involve 

land that is controlled by the applicant.

Power line right-of-way Generic SMALL. Ongoing use of power line rights-of-way would 

continue with no change in restrictions. The effects of these 

restrictions are of small significance.

B-7 
Appendix B

Issue Type of Issue Findings

Human Health

Radiation exposures to 

the public during 

refurbishment

Generic SMALL. During refurbishment, the gaseous effluents would 

result in doses that are similar to those from current 

operation. Applicable regulatory dose limits to the public are 

not expected to be exceeded.

Occupational radiation 

exposures during 

refurbishment

Generic SMALL. Occupational doses from refurbishment are 

expected to be within the range of annual average collective 

doses experienced for pressurized-water reactors and 

boiling-water reactors. Occupational mortality risk from all 

causes, including radiation, is in the mid-range for industrial 

settings.

Microbiological 

organisms (occupational 

health)

Generic SMALL. Occupational health impacts are expected to be 

controlled by the continued application of accepted industrial 

hygiene practices to minimize worker exposures.

Microbiological 

organisms (public 

health)(plants using 

lakes or canals, or 

cooling towers or cooling 

ponds that discharge to 

a small river)

Site-specific SMALL, MODERATE, OR LARGE. These organisms are 

not expected to be a problem at most operating plants, 

except possibly at plants using cooling ponds, lakes, or 

canals that discharge to small rivers. Without site-specific 

data, it is not possible to predict the effects generically. 

See § 51.53(c)(3)(ii)(G).

Noise Generic SMALL. Noise has not been found to be a problem at 

operating plants and is not expected to be a problem at any 

plant during the license renewal term.

Electromagnetic fields – 

acute effects (electric 

shock)

Site-specific SMALL, MODERATE, OR LARGE. Electric shock resulting 

from direct access to energized conductors or from induced 

charges in metallic structures has not been found to be a 

problem at most operating plants and generally is not 

expected to be a problem during the license renewal term. 

However, site-specific review is required to determine the 

significance of the electric shock potential at the site. 

See § 51.53(c)(3)(ii)(H).

Electromagnetic fields – 

chronic effects 

Uncategorized UNCERTAIN. Biological and physical studies of 60-Hz 

electromagnetic fields have not found consistent evidence 

linking harmful effects with field exposures. However, 

research is continuing in this area and a consensus scientific 

view has not been reached.

Radiation exposures to 

public (license renewal 

term)

Generic SMALL. Radiation doses to the public will continue at 

current levels associated with normal operations.

Occupational radiation 

exposures (license 

renewal term)

Generic SMALL. Projected maximum occupational doses during the 

license renewal term are within the range of doses 

experienced during normal operations and normal 

maintenance outages, and would be well below regulatory 

limits.

B-8 
Appendix B

Issue Type of Issue Findings

Socioeconomics

Housing impacts Site-specific SMALL, MODERATE, OR LARGE. Housing impacts are 

expected to be of small significance at plants located in a 

medium or high population area and not in an area where 

growth control measures, that limit housing development, 

are in effect. Moderate or large housing impacts of the 

workforce associated with refurbishment may be associated 

with plants located in sparsely populated areas or in areas 

with growth control measures that limit housing 

development. See § 51.53(c)(3)(ii)(I).

Public services: public 

safety, social services, 

and tourism and 

recreation

Generic SMALL. Impacts to public safety, social services, and 

tourism and recreation are expected to be of small 

significance at all sites.

Public services: public 

utilities

Site-specific SMALL OR MODERATE. An increased problem with water 

shortages at some sites may lead to impacts of moderate 

significance on public water supply availability. 

See § 51.53(c)(3)(ii)(I).

Public services: 

education

(refurbishment)

Site-specific SMALL, MODERATE, OR LARGE. Most sites would 

experience impacts of small significance but larger impacts 

are possible depending on site- and project-specific factors. 

See § 51.53(c)(3)(ii)(I).

Public services: 

education (license 

renewal term)

Generic SMALL. Only impacts of small significance are expected

Offsite land use 

(refurbishment)

Site-specific SMALL OR MODERATE. Impacts may be of moderate 

significance at plants in low population areas. 

See § 51.53(c)(3)(ii)(I).

Offsite land use 

(license renewal term)

Site-specific SMALL, MODERATE, OR LARGE. Significant changes in 

land use may be associated with population and tax revenue 

changes resulting from license renewal. 

See § 51.53(c)(3)(ii)(I).

Public services: 

transportation

Site-specific SMALL, MODERATE, OR LARGE. Transportation impacts 

(level of service) of highway traffic generated during plant 

refurbishment and during the term of the renewed license 

are generally expected to be of small significance. 

However, the increase in traffic associated with the 

additional workers and the local road and traffic control 

conditions may lead to impacts of moderate or large 

significance at some sites. See § 51.53(c)(3)(ii)(J).

Historic and 

archaeological resources

Site-specific SMALL, MODERATE, OR LARGE. Generally, plant 

refurbishment and continued operation are expected to have 

no more than small adverse impacts on historic and 

archaeological resources. However, the National Historic 

Preservation Act requires the Federal agency to consult with 

the State Historic Preservation Officer to determine whether 

there are properties present that require protection. See 

§ 51.53(c)(3)(ii)(K).

Aesthetic impacts 

(refurbishment)

Generic SMALL. No significant impacts are expected during 

refurbishment.

B-9 
Appendix B

Issue Type of Issue Findings

Socioeconomics (continued)

Aesthetic impacts 

(license renewal term)

Generic SMALL. No significant impacts are expected during the 

license renewal term.

Aesthetic impacts of 

transmission lines

(license renewal term)

Generic SMALL. No significant impacts are expected during the 

license renewal term.

Postulated Accidents

Design-basis accidents Generic SMALL. The NRC staff has concluded that the 

environmental impacts of design-basis accidents are of 

small significance for all plants.

Severe accidents Site-specific SMALL. The probability weighted consequences of 

atmospheric releases, fallout onto open bodies of water, 

releases to groundwater, and societal and economic impacts 

from severe accidents are small for all plants. However, 

alternatives to mitigate severe accidents must be considered 

for all plants that have not considered such alternatives. 

See § 51.53(c)(3)(ii)(L).

B-10
Appendix B

Issue Type of Issue Findings

Uranium Fuel Cycle and Waste Management

Offsite radiological 

impacts (individual 

effects from other than 

the disposal of spent fuel

and high-level waste)

Generic SMALL. Offsite impacts of the uranium fuel cycle have been 

considered by the Commission in Table S-3 of this part. 

Based on information in the GEIS, impacts on individuals 

from radioactive gaseous and liquid releases, including 

radon-222 and technetium-99, are small.

Offsite radiological 

impacts (collective 

effects)

Generic The 100-year environmental dose commitment to the U.S. 

population from the fuel cycle, high level waste and spent 

fuel disposal is calculated to be about 14,800 person rem, or 

12 cancer fatalities, for each additional 20-year power 

reactor operating term. Much of this, especially the 

contribution of radon releases from mines and tailing piles, 

consists of tiny doses summed over large populations.

This same dose calculation can theoretically be extended to 

include many tiny doses over additional thousands of years, 

as well as doses outside the United States. The result of 

such a calculation would be thousands of cancer fatalities 

from the fuel cycle, but this result assumes that even tiny 

doses have some statistical adverse health effects which will 

not ever be mitigated (for example no cancer cure in the 

next thousand years), and that these doses projected over 

thousands of years are meaningful. However, these 

assumptions are questionable. In particular, science cannot 

rule out the possibility that there will be no cancer fatalities 

from these tiny doses. For perspective, the doses are very 

small fractions of regulatory limits, and even smaller 

fractions of natural background exposure to the same 

populations.

Nevertheless, despite all the uncertainty, some judgment as 

to the regulatory NEPA implications of these matters should 

be made and it makes no sense to repeat the same 

judgment in every case. Even taking the uncertainties into 

account, the Commission concludes that these impacts are 

acceptable in that these impacts would not be sufficiently 

large to require the NEPA conclusion, for any plant, that the 

option of extended operation under 10 CFR Part 54 should 

be eliminated. Accordingly, while the Commission has not 

assigned a single level of significance for the collective 

effects of the fuel cycle, this issue is considered Category 1 

(Generic).

B-11
Appendix B

Issue Type of Issue Findings

Uranium Fuel Cycle and Waste Management (continued)

Offsite radiological 

impacts (spent fuel and 

high-level waste

disposal)

Generic For the high-level waste and spent fuel disposal component 

of the fuel cycle, there are no current regulatory limits for 

offsite releases of radionuclides for the current candidate 

repository site. However, if it is assumed that limits are 

developed along the lines of the 1995 National Academy of 

Sciences (NAS) report, “Technical Bases for Yucca 

Mountain Standards,” and that in accordance with the 

Commission’s Waste Confidence Decision, 10 CFR 51.23, a 

repository can and likely will be developed at some site 

which will comply with such limits, peak doses to virtually all 

individuals will be 100 milliroentgen equivalent man 

(millirem) per year or less. However, while the Commission 

has reasonable confidence that these assumptions will 

prove correct, there is considerable uncertainty since the 

limits are yet to be developed, no repository application has 

been completed or reviewed, and uncertainty is inherent in 

the models used to evaluate possible pathways to the 

human environment. The NAS report indicated that 

100 millirem per year should be considered as a starting 

point for limits for individual doses, but notes that some 

measure of consensus exists among national and 

international bodies that the limits should be a fraction of the 

100 millirem per year. The lifetime individual risk from 

100 millirem annual dose limit is about 3×10-3. 

Estimating cumulative doses to populations over thousands 

of years is more problematic. The likelihood and 

consequences of events that could seriously compromise 

the integrity of a deep geologic repository were evaluated by 

the Department of Energy in the “Final Environmental 

Impact Statement: Management of Commercially 

Generated Radioactive Waste,” October 1980. The 

evaluation estimated the 70-year whole-body dose

commitment to the maximum individual and to the regional 

population resulting from several modes of breaching a 

reference repository in the year of closure, after 1,000 years, 

after 100,000 years, and after 100,000,000 years. 

Subsequently, the NRC and other Federal agencies have

expended considerable effort to develop models for the 

design and for the licensing of a high-level waste repository, 

especially for the candidate repository at Yucca Mountain. 

More meaningful estimates of doses to the population may 

be possible in the future as more is understood about the 

performance of the proposed Yucca Mountain repository. 

Such estimates would involve great uncertainty, especially 

with respect to cumulative population doses over thousands 

of years. The standard proposed by the NAS is a limit on 

maximum individual dose. The relationship of potential new 

regulatory requirements, based on the NAS report, and 

cumulative population impacts has not been determined, 

although the report articulates the view that protection of 

individuals will adequately protect the population for a

repository at Yucca Mountain. However, the Environmental

Protection Agency’s (EPA) generic repository standards in

B-12
Appendix B

Issue Type of Issue Findings

Uranium Fuel Cycle and Waste Management (continued)

Offsite radiological 

impacts (spent fuel and 

high level waste 

disposal) 

[continued from previous 

page] 

Generic 40 CFR Part 191 generally provide an indication of the order 

of magnitude of cumulative risk to the population that could

result from the licensing of a Yucca Mountain repository, 

assuming the ultimate standards will be within the range of 

standards now under consideration. The standards in 

40 CFR Part 191 protect the population by imposing 

“containment requirements” that limit the cumulative amount 

of radioactive material released over 10,000 years. The 

cumulative release limits are based on the EPA’s population 

impact goal of 1,000 premature cancer deaths worldwide for 

a 100,000 metric ton (MTHM) repository.

Nevertheless, despite all the uncertainty, some judgment as 

to the regulatory NEPA implications of these matters should 

be made and it makes no sense to repeat the same 

judgment in every case. Even taking the uncertainties into 

account, the Commission concludes that these impacts are 

acceptable in that these impacts would not be sufficiently 

large to require the NEPA conclusion, for any plant, that the 

option of extended operation under 10 CFR Part 54 should 

be eliminated.

Accordingly, while the Commission has not assigned a 

single level of significance for the impacts of spent fuel and 

high-level waste disposal, this issue is considered 

Category 1 (Generic). 

Nonradiological impacts 

of the uranium fuel cycle

Generic SMALL. The nonradiological impacts of the uranium fuel 

cycle resulting from the renewal of an operating license for 

any plant are found to be small.

Low-level waste storage 

and disposal

Generic SMALL. The comprehensive regulatory controls that are in 

place and the low public doses being achieved at reactors 

ensure that the radiological impacts to the environment will 

remain small during the term of a renewed license. The 

maximum additional onsite land that may be required for 

low-level waste storage during the term of a renewed license 

and associated impacts will be small.

Nonradiological impacts on air and water will be negligible. 

The radiological and nonradiological environmental impacts 

of long-term disposal of low-level waste from any individual 

plant at licensed sites are small. In addition, the 

Commission concludes that there is reasonable assurance 

that sufficient low-level waste disposal capacity will be made 

available when needed for facilities to be decommissioned 

consistent with NRC decommissioning requirements.

B-13
Appendix B

Issue Type of Issue Findings

Uranium Fuel Cycle and Waste Management (continued)

Mixed waste storage and 

disposal

Generic SMALL. The comprehensive regulatory controls and the 

facilities and procedures that are in place ensure proper 

handling and storage, as well as negligible doses and 

exposure to toxic materials for the public and the 

environment at all plants. License renewal will not increase 

the small, continuing risk to human health and the 

environment posed by mixed waste at all plants. The 

radiological and nonradiological environmental impacts of 

long-term disposal of mixed waste from any individual plant 

at licensed sites are small. In addition, the Commission 

concludes that there is reasonable assurance that sufficient 

mixed waste disposal capacity will be made available when 

needed for facilities to be decommissioned consistent with 

NRC decommissioning requirements.

Onsite spent fuel Generic SMALL. The expected increase in the volume of spent fuel

from an additional 20 years of operation can be safely 

accommodated on site with small environmental effects 

through dry or pool storage at all plants if a permanent 

repository or monitored retrievable storage is not available.

Nonradiological waste Generic SMALL. No changes to generating systems are anticipated 

for license renewal. Facilities and procedures are in place to 

ensure continued proper handling and disposal at all plants.

Transportation Generic SMALL. The impacts of transporting spent fuel enriched up 

to 5 percent uranium-235 with average burnup for the peak 

rod to current levels approved by the NRC up to 

62,000 megawatt days per metric ton uranium (MWd/MTU) 

and the cumulative impacts of transporting high-level waste

to a single repository, such as Yucca Mountain, Nevada are 

found to be consistent with the impact values contained in 

10 CFR 51.52(c), Summary Table S-4, “Environmental 

Impact of Transportation of Fuel and Waste to and from One 

Light-Water-Cooled Nuclear Power Reactor.” If fuel 

enrichment or burnup conditions are not met, the applicant 

must submit an assessment of the implications for the 

environmental impact values reported in § 51.52.

B-14
Appendix B

Issue Type of Issue Findings

Decommissioning

Radiation doses Generic SMALL. Doses to the public will be well below applicable 

regulatory standards regardless of which decommissioning 

method is used. Occupational doses would increase no 

more than 1 man-rem caused by the buildup of long-lived 

radionuclides during the license renewal term.

Waste management Generic SMALL. Decommissioning at the end of a 20-year license 

renewal period would generate no more solid wastes than at 

the end of the current license term. No increase in the 

quantities of Class C or greater than Class C wastes would 

be expected.

Air quality Generic SMALL. Air quality impacts of decommissioning are 

expected to be negligible either at the end of the current 

operating term or at the end of the license renewal term.

Water quality Generic SMALL. The potential for significant water quality impacts 

from erosion or spills is no greater whether 

decommissioning occurs after a 20-year license renewal 

period or after the original 40-year operation period, and 

measures are readily available to avoid such impacts.

Ecological resources Generic SMALL. Decommissioning after either the initial operating 

period or after a 20-year license renewal period is not 

expected to have any direct ecological impacts.

Socioeconomic impacts Generic SMALL. Decommissioning would have some short-term 

socioeconomic impacts. The impacts would not be 

increased by delaying decommissioning until the end of a 

20-year license renewal period, but they might be decreased 

by population and economic growth.

Environmental Justice

Environmental justice Uncategorized NONE. The need for and the content of an analysis of 

environmental justice will be addressed in plant-specific 

reviews.

Source: Table B-1 in Appendix B to Subpart A of 10 CFR Part 51 (61 FR 28467, June 5, 1996) 

B-15

APPENDIX C 

APPLICABLE REGULATIONS, LAWS, AND AGREEMENTS

C. APPLICABLE REGULATIONS, LAWS, AND AGREEMENTS

The Atomic Energy Act of 1954, as amended (42 USC § 2011 et seq.), authorizes the 

U.S. Nuclear Regulatory Commission (NRC) to enter into agreement with any state to assume 

regulatory authority for certain activities (see 42 USC § 2021 ). For example, through the 

Agreement State Program, Pennsylvania assumed regulatory responsibility over certain 

byproduct, source, and quantities of special nuclear materials not sufficient to form a critical 

mass. The Bureau of Radiation Protection, Pennsylvania Department of Environmental 

Protection, administers the Pennsylvania State Agreement Program. 

In addition to carrying out some Federal programs, state legislatures develop their own laws. 

State statutes supplement, as well as implement, Federal laws for protection of air, water 

quality, and groundwater. State legislation may address solid waste management programs, 

locally rare and endangered species, and historic and cultural resources.

The Federal Water Pollution Control Act (commonly referred to as the Clean Water Act (CWA)) 

(33 USC § 1251 et seq.) allows for primary enforcement and administration through state 

agencies, given that the state program is at least as stringent as the Federal program. The 

state program must conform to the CWA and to the delegation of authority for the Federal 

National Pollutant Discharge Elimination System (NPDES) program from the U.S. 

Environmental Protection Agency (EPA) to the state. The primary mechanism to control water 

pollution is the requirement for direct dischargers to obtain an NPDES permit, or in the case of 

states where the authority has been delegated from the EPA, a State Pollutant Discharge 

Elimination System permit, under the CWA. In Pennsylvania, the Pennsylvania Department of 

Environmental Protection issues and enforces NPDES permits.

One important difference between Federal regulations and certain state regulations is the 

definition of waters that the state regulates. Certain state regulations may include underground 

waters, whereas the CWA only regulates surface waters. The Delaware River Basin 

Commission regulates the Groundwater Protection Area in Southeastern Pennsylvania. 

C.1 Federal and State Environmental Requirements

Limerick Generating Station, Units 1 and 2 (LGS) is subject to Federal and state requirements 

for its environmental program.

Table C–1 lists the principle Federal and state environmental regulations and laws applicable to 

the review of the environmental resources that could be affected by this project that may affect 

license renewal applications for nuclear power plants. See Table C–2 of this supplemental 

environmental impact statement for LGS’s compliance status with these requirements.

C-1 
Appendix C

Table C–1. Federal and State Environmental Requirements

Law/regulation Requirements

Current operating license and license renewal

Atomic Energy Act 

(42 U.S.C. § 2011 et seq.)

This Act is the fundamental U.S. law on both the civilian and the military 

uses of nuclear materials. On the civilian side, it provides for both the 

development and the regulation of the uses of nuclear materials and 

facilities in the United States. The Act requires that civilian uses of nuclear 

materials and facilities be licensed, and it empowers the NRC to establish 

by rule or order, and to enforce, such standards to govern these uses as 

“the Commission may deem necessary or desirable in order to protect 

health and safety and minimize danger to life or property.”

10 CFR Part 51, Title 10 

Code of Federal 

Regulations (10 CFR) 

Part 51, Energy

“Environmental Protection Regulations for Domestic Licensing and 

Related Regulatory Functions.” This part contains environmental 

protection regulations applicable to the NRC’s domestic licensing and 

related regulatory functions.

10 CFR Part 54 “Requirements for Renewal of Operating Licenses for Nuclear Power 

Plants.” This part focuses on managing adverse effects of aging rather 

than noting all aging mechanisms. The rule is intended to ensure that 

important systems, structures, and components will maintain their 

intended function during the period of extended operation.

10 CFR Part 50 “Domestic Licensing of Production and Utilization Facilities.” Regulations 

that the NRC issues under the Atomic Energy Act of 1954, as amended 

(68 Stat. 919), and Title II of the Energy Reorganization Act of 1974 

(88 Stat. 1242), provide for the licensing of production and utilization 

facilities. This part also gives notice to all persons who knowingly 

supply—to any licensee, applicant, contractor, or subcontractor—

components, equipment, materials, or other goods or services that relate 

to a licensee’s or applicant’s activities subject to this part, that they may be 

individually subject to NRC enforcement action for violation of § 50.5.

Air quality protection

Clean Air Act (CAA) 

(42 USC § 7401 et seq.)

The Clean Air Act (CAA) is a comprehensive Federal law that regulates air 

emissions. Among other things, this law authorizes EPA to establish 

National Ambient Air Quality Standards (NAAQS) to protect public health 

and public welfare and to regulate emissions of hazardous air pollutants. 

EPA has promulgated NAAQS for six criteria pollutants: sulfur dioxide, 

nitrogen dioxide, carbon monoxide (CO), ozone, lead, and particulate 

matter. All areas of the United States must maintain ambient levels of 

these pollutants below the ceilings established by the NAAQS.

Pennsylvania Air Pollution 

Control Act (P.L. 2119)

The Pennsylvania Air Pollution Control Act establishes procedures for the 

protection of health and public safety during emergency conditions, 

creating a stationary air contamination source permit system and providing 

additional remedies for abating air pollution.

C-2 
Appendix C

Law/regulation Requirements

Land use resources protection

Coastal Zone Management 

Act of 1972 (16 USC § 1451 

et seq.), as amended

The Coastal Zone Management Act (CZMA) was established to preserve, 

protect, develop and where possible, restore or enhance, the resources of 

the Nation’s coastal zone. It also encourages and assists the states to 

exercise effectively their responsibilities in the coastal zone through the

development and implementation of management programs to achieve 

wise use of the land and water resources of the coastal zone, giving full 

consideration to ecological, cultural, historic, and esthetic values as well 

as the needs for compatible economic development.

Water resources protection

Federal Water Pollution 

Control Act (commonly 

referred to as the Clean 

Water Act (CWA)) 

(33 USC § 1251 et seq.) 

and the NPDES

(40 CFR 122)

The CWA establishes the basic structure for regulating discharges of 

pollutants into the waters of the United States and regulating quality 

standards for surface waters. 

Wild and Scenic River Act 

(16 USC § 1271 et seq.)

The Wild and Scenic River Act created the National Wild and Scenic 

Rivers System, which was established to protect the environmental values 

of free flowing streams from degradation by affecting activities, including 

water resources projects.

Safe Drinking Water Act

(42 USC § 300f et seq.)

The Safe Drinking Water Act (SDWA) is the principal Federal law that 

ensures safe drinking water for the public. Under the SDWA, EPA is 

required to set standards for drinking water quality and oversees all states, 

localities, and water suppliers that implement these standards.

Pennsylvania Code, 

Title 25, Environmental 

Protection, Part I, 

Department of 

Environmental Protection, 

Chapter 92a, National 

Pollutant Discharge 

Elimination System

Permitting, Monitoring, and 

Compliance (25 

Pa Code 92a). 

The regulatory provisions contained in this Pennsylvania code implement 

the NPDES Program by the Pennsylvania Department of Environmental 

Protection under the Federal Act. 

Pennsylvania Code, Title 

25, Environmental 

Protection, Part 1, 

Department of 

Environmental Protection 

Chapter 93, Water Quality 

Standards (25 Pa Code 93)

This code sets forth water quality standards for surface waters in the State 

of Pennsylvania, including wetlands. These standards are based upon 

water uses that are to be protected and will be considered by the 

Pennsylvania Department of Environmental Protection in implementing its 

authority under the Clean Streams Law and other statutes that authorize 

protection of surface water quality.

Pennsylvania Code, 

Title 25, Environmental 

Protection, Part V, Delaware 

River Basin Commission, 

Chapter 901, General 

Provisions (20 

Pa Code 901)

This code incorporates by reference among other things Parts 401, “Rules 

of Practice and Procedures,” “Basin Regulations; Water Code and 

Administrative Manual Part III Water Quality Regulations,” and 430, 

“Ground Water Protection Area: Pennsylvania,” of 18 CFR containing 

regulations on conservation of power and water resources. 

C-3 
Appendix C

Law/regulation Requirements

Water resources protection (continued)

Pennsylvania’s Clean 

Streams Law 

(35 P.S. Section 691.1 

et seq.)

The Clean Streams Law provides additional remedies for abating pollution 

of waters; regulates discharges of sewage and industrial wastes; regulates 

the operation of mines; and regulates the impact of mining upon water 

quality, supply, and quantity. The law places responsibilities on 

landowners and land occupiers, and maintains primary jurisdiction over 

surface coal mining in Pennsylvania.

Pennsylvania Safe Drinking 

Water Act (P.L. 206, No. 43 

and 25 PA Code 109)

The Pennsylvania Safe Drinking Water Act protects the public health and 

safety by assuring that public water systems provide a safe and adequate 

supply of water for human consumption by establishing drinking water 

quality standards, permit requirements, and design and construction 

standards.

Waste management and pollution prevention

Resource Conservation and 

Recovery Act (RCRA) 

(42 USC § 6901 et seq.)

RCRA gives EPA authority to control hazardous waste. Before a material

can be classified as a hazardous waste, it first must be a solid waste as 

defined under the Resource Conservation and Recovery Act (RCRA). 

Hazardous waste is classified under Subtitle C of the RCRA. Parts 261, 

“Identification and Listing of Hazardous Waste,” and 262, “Standards 

Applicable to Generators of Hazardous Waste,” of 40 CFR contain all 

applicable generators of hazardous waste regulations. 

Pollution Prevention Act 

(42 USC § 13101 et seq.)

The Pollution Prevention Act formally established a national policy to 

prevent or reduce pollution at its source whenever feasible. The Act 

supplies funds for state and local pollution prevention programs through a 

grant program to promote the use of pollution prevention techniques by 

business.

C-4 
Appendix C

Law/regulation Requirements

Protected species

Endangered Species Act of 

1973 (ESA) (16 USC § 1531 

et seq.)

The Endangered Species Act (ESA) forbids any government agency, 

corporation, or citizen from taking (e.g., harming or killing) endangered 

animals without an Endangered Species Permit. The ESA also requires 

Federal agencies to consult with the U.S. Fish and Wildlife Service or 

National Marine Fisheries Service if any Federal action may adversely 

affect any listed species or designated critical habitat.

Magnuson–Stevens Fishery 

Conservation and 

Management Act (MSA) 

(16 USC § 1801 et seq.) 

The Magnuson–Stevens Fishery Conservation and Management Act 

(MSA) includes requirements for Federal agencies to consider the impact 

of Federal actions on essential fish habitat and to consult with the National 

Marine Fisheries Service if any activities may adversely affect essential 

fish habitat.

Marine Mammal Protection 

Act of 1972 (MMPA)

(16 USC § 1361 et seq.)

The Marine Mammal Protection Act (MMPA) prohibits the take of marine 

mammals in U.S. waters or by U.S. citizens on the high seas without an 

MMPA Take Permit issued by the National Marine Fisheries Service. 

MMPA also prohibits importation of marine mammals and marine mammal 

products into the United States.

Fish and Wildlife 

Coordination Act

(16 USC § 661 et seq.)

To minimize adverse impacts of proposed actions on fish and wildlife 

resources and habitat, the Fish and Wildlife Coordination Act requires that 

Federal agencies consult Government agencies regarding activities that 

affect, control, or modify waters of any stream or bodies of water. It also 

requires that justifiable means and measures be used in modifying plans 

to protect fish and wildlife in these waters.

Pennsylvania Code, Title 

58, Recreation, Part II, Fish 

and Boat Commission, 

Chapter 75, Endangered 

Species (58 PA Code 75)

This code provides a lists of endangered, threatened, and candidate 

species in the State of Pennsylvania. The code prohibits the catching, 

taking, killing, possessing, importing or exporting from the 

State of Pennsylvania, selling, or offering to sale or purchase of any 

species listed without a special permit from Executive Director of the 

Pennsylvania Fish and Boat Commission.

Historic preservation

National Historic 

Preservation Act (NHPA) 

(16 USC § 470 et seq.)

The National Historic Preservation Act (NHPA) directs Federal agencies to 

consider the impact of their actions on historic properties. To comply with 

NHPA, Federal agencies must consult with State Historic Preservation 

Officers and, when applicable, tribal historic preservations officers. NHPA 

also encourages state and local preservation societies.

C.2 Operating Permits and Other Requirements

Table C–2 lists the permits and licenses issued by Federal, state, and local authorities for 

activities at LGS.

C-5 
Appendix C

Table C–2. Licenses and Permits

Permit Number Dates Responsible Agency

Operating license NPF-39 Issued: 08/8/1985

Expires: 10/26/2024

NRC

Operating license NPF-85 Issued: 08/25/1989

Expires: 06/22/2029

NRC

NPDES Permit PA0051926 Issued: 03/31/2006

Expires: 03/31/2011

(administratively 

continued)

Pennsylvania 

Department of 

Environmental Protection 

(PADEP)

NPDES Permit PA0052221 Issued: 07/1/2009

Expires: 06/30/2014

PADEP

Submission of project for 

Delaware River Basin 

Commission (DRBC) 

approval and determination 

as to whether project impairs 

or conflicts with the DRBC 

comprehensive plan

D-69-210 CP Issued: 11/7/1975

(Rev. 13–

05/08/2013) 

Expires: 12/31/2018

DRBC

Submission of project for 

DRBC approval and 

determination as to whether 

project impairs or conflicts 

with the DRBC 

comprehensive plan

D-69-52 CP Issued: 02/18/1981

Expires: No 

expiration date 

indicated

DRBC

Submission of project for 

DRBC approval and 

determination as to whether 

project impairs or conflicts 

with the DRBC 

comprehensive plan

D-77-110 CP Issued: 10/24/1984

Expires: No 

expiration date 

indicated

DRBC

Submission of project for 

DRBC approval and 

determination as to whether 

project impairs or conflicts 

with the DRBC 

comprehensive plan

D-65-76 CP Issued: 12/18/1981

Expires: No 

expiration date 

indicated

DRBC

Title V Operating Permit TVOP-46-00038 Issued: 12/07/2009

Expires: 12/07/2014

PADEP

Approval of design 

modifications, operation, and 

maintenance of Bradshaw 

Reservoir Dam

D09-181A Issued: 12/30/1986

Expires: 12/30/2036

PADEP

C-6 
Appendix C

Permit Number Dates Responsible Agency

Maintenance Dredging 

Permit

19616 Issued: 07/16/1976

Expires: No date 

listed on permit

PADEP

Maintenance Dredging 

Permit

19615 Issued: 07/16/1976

Expires: No date 

listed on permit

PADEP

General Permit No. 11 for 

Maintenance Dredging

044610317 Issued: 12/07/2010

Expires: No 

expiration date 

indicated

PADEP

Permit to operate a public 

water system or a 

substantially modified facility

4696508 Issued: 03/25/1997

Expires: No date 

listed on permit

PADEP

Permit to operate a public 

water system or a 

substantially modified facility

4606501 Issued: 06/30/2006

Expires: No date 

listed on permit

PADEP

Permit to operate a public 

water system or a 

substantially modified facility

4609503 Issued: 11/20/2009

Expires: No date 

listed on permit

PADEP

Notification of regulated 

waste activity to obtain an 

EPA identification number for 

hazardous waste

PAD000797951 Issued: 01/01/2001

Expires: N/A

EPA

Certificate of 

registration/permit to operate

storage tanks

None Issued: 02/04/2011

Expires: Renewed 

Annually

PADEP

Hazardous Materials 

Certificate of Registration

051713 550 083VX Issued: 05/17/2013 

Expires: 06/30/2016

U.S. Department of 

Transportation

Fire Marshall approval for 

storage and handling of 

flammable and combustible 

liquid

172,943 Issued: 02/25/1972

Expires: No date 

listed on approval

Pennsylvania 

Department of Labor and 

Industry, Boiler Section

Fire Marshall approval for 

storage and handling of 

flammable and combustible 

liquid

186,609 Issued: 08/15/1977

Expires: No date 

listed on approval

Pennsylvania 

Department of Labor and 

Industry, Boiler Section

Fire Marshall approval for 

storage and handling of 

flammable and combustible 

liquid

186,610 Issued: 08/15/1977

Expires: No date 

listed on approval

Pennsylvania 

Department of Labor and 

Industry, Boiler Section

C-7 
Appendix C

Permit Number Dates Responsible Agency

Fire Marshall approval for 

storage and handling of 

flammable and combustible 

liquid

187,162 Issued: 11/17/1977

Expires: No date 

listed on approval

Pennsylvania 

Department of Labor and 

Industry, Boiler Section

Environmental laboratory 

certificate of accreditation 

under PA Code 252

PA Lab ID 

No. 46-0128, Cert. 003

Issued: 08/31/2010

Expires: Renewed 

Annually

PADEP

Permit to operate 

encroachment

E 09-77A Issued: 02/12/1988

Expires: 02/11/2038

PADEP

Approval for disposal of 

licensed material generated 

by licensee’s activities

N/A Issued: 07/10/1996 

(NRC)

Issued: 03/23/1998 

(PADEP)

Expires: No date 

listed on approvals

NRC and PADEP

Source: Exelon 2011

C.3 Reference

[Exelon] Exelon Generation Company, LLC. 2011. License Renewal Application, Limerick 

Generating Station, Units 1 and 2, Appendix E, Applicant’s Environmental Report, Operating 

License Renewal Stage. Agencywide Documents Access and Management System (ADAMS) 

No. ML11179A104. 

C-8 
APPENDIX D 

CONSULTATION CORRESPONDENCE

D. CONSULTATION CORRESPONDENCE

D.1 Background

The Endangered Species Act of 1973, as amended; the Magnuson Stevens Fisheries 

Management Act of 1996, as amended; and the National Historic Preservation Act of 1966 

(NHPA) require that Federal agencies consult with applicable State and Federal agencies and 

groups before taking action that may affect threatened or endangered species, essential fish 

habitat, or historic and archaeological resources, respectively. This appendix contains 

consultation documentation.

Table D–1 lists the consultation documents sent between the U.S. Nuclear Regulatory 

Commission (NRC) and other agencies. The NRC staff is required to consult with these 

agencies based on the requirements of the statutes listed above.

D-1 
Appendix D

Table D–1. Consultation Correspondence

Author Recipient Date of Letter/email

Wrona, D., NRC M. Roberts, U.S. Fish and Wildlife 

Service (FWS)

September 8, 2011

ML11258A248

Wrona, D., NRC H. Ellis, Absentee-Shawnee Tribe of 

Oklahoma

September 13, 2011

ML112340045

Wrona, D., NRC B. Obermeyer, Delaware Tribe September 13, 2011

ML112340045

Wrona, D., NRC R. Dushane, Cultural Resource Officer, 

Eastern Shawnee Tribe of Oklahoma

September 13, 2011

ML112340045

Wrona, D., NRC C. Halftown, Heron Clan Representative, 

Cayuga Nation

September 13, 2011

ML112340045

Wrona, D., NRC T. Francis, Tribal Historic Preservation 

Office, Delaware Nation

September 13, 2011

ML112340045

Wrona, D., NRC R. Hill, Tonawanda Seneca Nation September 13, 2011

ML112340045

Wrona, D., NRC N. Patterson, Tuscarora Nation September 13, 2011

ML112340045

Wrona, D., NRC J. Bergevin, Oneida Indian Nation September 13, 2011

ML112340045

Wrona, D., NRC C. Burke, Oneida Nation of Wisconsin September 13, 2011

ML112340045

Wrona, D., NRC T. Gonyea, Onondaga Nation September 13, 2011

ML112340045

Wrona, D., NRC L. Watt, Seneca Nation of Indians September 13, 2011

ML112340045

Wrona, D., NRC P. Barton, Seneca-Cayuga Tribe

of Oklahoma

September 13, 2011

ML112340045

Wrona, D., NRC S. White, Stockbridge-Munsee Band 

of the Mohican Nation of Wisconsin

September 13, 2011

ML112340045

Wrona, D., NRC A. Printup, St. Regis Mohawk Tribe September 13, 2011

ML112340045

Wrona, D., NRC K. Jumper, Shawnee Tribe September 13, 2011

ML112340045

Wrona, D., NRC J. Cutler, Pennsylvania Historical and 

Museum Commission

September 15, 2011

ML11221A265

Wrona, D., NRC T. McCulloch, Advisory Council on Historic

Preservation

September 16, 2011

ML11245A083

Obermeyer, B., Delaware Tribe

Historic Preservation Office

D. Wrona, NRC September 23, 2011

ML11279A113

White, S., Stockbridge-Munsee 

Tribal Historic Preservation Office D. Wrona, NRC September 28, 2011ML11279A114

Urban, C., Pennsylvania Fish & 

Boat Commission D. Wrona, NRC October 5, 2011ML11291A077

D-2 
Appendix D

Author Recipient Date of Letter/email

Gonyea, A., Onondaga Nation D. Wrona, NRC October 15, 2011

ML11305A006

McLearen, D., Pennsylvania 

Historical and Museum Commission, 

Bureau for Historic Preservation

D. Wrona, NRC October 26, 2011

ML11307A383

Mowery, O., Pennsylvania Game

Commission D. Wrona, NRC November 17, 2011ML11339A042

Riley, C., FWS D. Wrona, NRC November 22, 2011

ML11339A043

Susco, J., NRC D. Morris, National Marine Fisheries 

Service (NMFS)

May 30, 2012

ML12138A347

Colligan, M., NMFS J. Susco, NRC June 27, 2012

ML12226A163

Wong, M., NRC D. McLearen, Pennsylvania Historical and 

Museum Commission

May 6, 2013

ML13066A492

Wong, M., NRC G. Blanchard, Absentee Shawnee Tribe of 

Oklahoma

May 7, 2013

ML13066A482

Wong, M., NRC C. Halftown, Cayuga Nation May 7, 2013

ML13066A482

Wong, M., NRC T. Francis, Delaware Nation May 7, 2013

ML13066A482

Wong, M., NRC P. Pechonick, Delaware Tribe of Indians May 7, 2013

ML13066A482

Wong, M., NRC G. Wallace, Eastern Shawnee Tribe of 

Oklahoma

May 7, 2013

ML13066A482

Wong, M., NRC R. Halbritter, Oneida Indian Nation May 7, 2013

ML13066A482

Wong, M., NRC E. Delgado, Oneida Nation of Wisconsin May 7, 2013

ML13066A482

Wong, M., NRC T. Gonyea, Onondaga Nation May 7, 2013

ML13066A482

Wong, M., NRC B. Snyder, Seneca Nation of Indians May 7, 2013

ML13066A482

Wong, M., NRC L. Howard, Seneca–Cayuga Tribe of 

Oklahoma

May 7, 2013

ML13066A482

Wong, M., NRC R. Hart, St. Regis Mohawk Tribe May 7, 2013

ML13066A482

Wong, M., NRC R. Sparkman, Shawnee Tribe May 7, 2013

ML13066A482

Wong, M., NRC R. Chicks, Stockbridge–Munsee Band of 

the Mohican Nation

May 7, 2013

ML13066A482

Wong, M., NRC D. Hill, Tonawanda Seneca Nation May 7, 2013

ML13066A482

D-3 
Appendix D

Author Recipient Date of Letter/email

Wong, M., NRC L. Henry, Tuscarora Nation May 7, 2013

ML13066A482

Wong, M., NRC R. Nelson, Advisory Council on Historic 

Preservation

May 7, 2013

ML13066A480

Wong, M., NRC W. Weber, FWS May 7, 2013

ML13107A988

Wong, M., NRC M. Colligan, NMFS May 7, 2013

ML13064A064

Colligan, M., NMFS M. Wong, NRC May 13, 2013

ML13134A134

Smith, C., Delaware Nation E. Larson, NRC May 14, 3013

ML13135A152

Jumper, K., Shawnee Tribe E. Larson, NRC May 20, 2013

ML13141A124

Thees, D., FWS B. Grange, NRC July 2, 2013

ML13196A362

Zimmerman, L., FWS D. Wrona, NRC August 16, 2013

ML13242A072

D-4 
APPENDIX E 

CHRONOLOGY OF ENVIRONMENTAL REVIEW CORRESPONDENCE

E. CHRONOLOGY OF ENVIRONMENTAL REVIEW CORRESPONDENCE

This appendix contains a chronological listing of correspondence between the U.S. Nuclear 

Regulatory Commission (NRC) and external parties as part of its environmental review for 

Limerick Generating Station, Units 1 and 2 (LGS). All documents, with the exception of those 

containing proprietary information, are available electronically from the NRC’s Public Electronic 

Reading Room found on the Internet at the following Web address: 

http://www.nrc.gov/reading-rm.html. From this site, the public can gain access to the NRC’s 

Agencywide Documents Access and Management System (ADAMS), which provides text and 

image files of NRC’s public documents in ADAMS. The ADAMS accession number for each 

document is included in the following list. To locate a reference in ADAMS, click on the “Simple 

Search” tab at the top of the web page, and enter the ADAMS accession number in the search 

box.

E.1 Environmental Review Correspondence

Table E–1 lists the environmental review correspondence in date order beginning with the 

request by Exelon to renew the operating license for LGS.

E-1 
Appendix E

Table E–1. Environmental Review Correspondence

Date Correspondence Description ADAMS No.

June 22, 2011 Letter from Exelon forwarding the LGS license renewal 

application and request to renew operating licenses for 

additional 20 years

ML11179A096

June 30, 2011 NRC press release announcing the availability of license 

renewal application for LGS

ML11181A084

July 13, 2011 Letter to Exelon, “Receipt and Availability of the License 

Renewal Application for the Limerick Generating Station, 

Units 1 and 2” 

ML11180A040

July 26, 2011 Federal Register Notice of Receipt and Availability of 

Application for Renewal of Limerick Generating Station, 

Units 1 and 2 Facility Operating License Nos. NPF-39 and 

NPF-85 for an Additional 20-Year Period (76 FR 44624)

ML11180A178

August 12, 2011 Letter to Exelon, “Determination of Acceptability and Sufficiency 

for Docketing, Proposed Review Schedule, and Opportunity for 

a Hearing Regarding the Application from Exelon Generating 

Station Company, LLC for Renewal of the Operating Licenses 

for Limerick Generating Station, Units 1 and 2”

ML11206A206

August 17, 2011 Letter to Exelon, “Notice of Intent to Prepare an Environmental

Impact Statement and Conduct Scoping Process for License 

Renewal for the Limerick Generating Station, Units 1 and 2”

ML111213A206

August 24, 2011 Federal Register Notice of Acceptance for Docketing of the 

Application and Notice for Opportunity for Hearing Regarding the 

Renewal of Facility Operating License Nos. NPF-39 and NPF-85 

for an Additional 20 Years Period, Exelon Generation Company, 

LLC, Limerick Generating Station (76 FR 52992)

ML11206A206

August 26, 2011 Federal Register Notice of Intent To Prepare an Environmental 

Impact Statement and Conduct Scoping Process for Limerick 

Generating Station, Units 1 and 2 (76 FR 53498)

ML11214A048

September 7, 2011 NRC press release announcing the LGS license renewal

environmental scoping meeting

ML11250A162

September 8, 2011 Letter to Mr. Mark Roberts, U.S. Fish and Wildlife Service ML11258A248

September 8, 2011 Letter to Ms. Olivia Braun, Environmental Planner, Pennsylvania 

Game Commission

ML11234A650

September 8, 2011 Letter to Mr. Chris Urban, Pennsylvania Fish and Boat 

Commission

ML11234A024

September 13, 2011 Letter to Henryetta Ellis, Absentee-Shawnee Tribe of Oklahoma ML112340045

September 13, 2011 Letter to Clint Halftown, Heron Clan Representative, Cayuga 

Nation

ML112340045

September 13, 2011 Letter to Ms. Tamara Francis, Tribal Historic Preservation Office, 

Delaware Nation

ML112340045

September 13, 2011 Letter to Dr. Brice Obermeyer, Delaware Tribe ML112340045

September 13, 2011 Letter to Ms. Robin Dushane, Cultural Resource Officer, 

Eastern Shawnee Tribe of Oklahoma

ML112340045

September 13, 2011 Letter to Chief Rogers Hill, Tonawanda Seneca Nation ML112340045

E-2 
Appendix E

Date Correspondence Description ADAMS No.

September 13, 2011 Letter to Mr. Neil Patterson, Director, Tuscarora Nation ML112340045

September 13, 2011 Letter to Ms. Kim Jumper, Tribal Historic Officer, Shawnee

Tribe

ML112340045

September 13, 2011 Letter to Mr. Arnold Printup, Historic Preservation Officer, 

St. Regis Mohawk Tribe

ML112340045

September 13, 2011 Letter to Ms. Sherry White, Cultural Preservation Officer,

Stockbridge-Munsee Band of the Mohican Nation of Wisconsin

ML112340045

September 13, 2011 Letter to Mr. Paul Barton, Historic Preservation Officer

Seneca-Cayuga Tribe of Oklahoma

ML112340045

September 13, 2011 Letter to Ms. Lane Watt, Tribal Historic Preservation Office

Seneca Nation of Indians

ML112340045

September 13, 2011 Letter to Mr. Tony Gonyea, Faithkeeper, Onondaga Nation ML112340045

September 13, 2011 Letter to Ms. Corina Burke, Tribal Historic Preservation Office

Oneida Nation of Wisconsin

ML112340045

September 13, 2011 Letter to Mr. Jesse Bergevin, Historian, Oneida Indian Nation ML112340045

September 15, 2011 Letter to Ms. Jean Cutler, Deputy State Historic Preservation 

Officer, Pennsylvania Historical and Museum Commission

ML11221A265

September 16, 2011 Letter to Mr. Chris Firestone, Pennsylvania Department of 

Conservation & Natural Resources

ML11230B346

September 16, 2011 Letter to Mr. Tom McCulloch, Advisory Council on Historic 

Preservation

ML11245A083

September 23, 2011 Letter from Dr. Brice Obermeyer, Delaware Tribe Historic 

Preservation Office

ML11279A113

September 28, 2011 Letter from Ms. Sherry White, Tribal Historic Preservation 

Officer, Stockbridge-Munsee Tribal Historic Preservation Office

ML11279A114

October 5, 2011 Letter from Mr. Chris Urban, Pennsylvania Fish and Boat 

Commission

ML11291A077

October 15, 2011 Letter from Mr. Anthony Gonyea, Onondaga Nation ML11305A006

October 26, 2011 Letter from Mr. Douglas McLearen, Pennsylvania Historical and 

Museum Commission

ML11307A383

November 17, 2011 Letter from Ms. Olivia Mowery, Pennsylvania Game Commission ML11339A042

November 22, 2011 Letter from Mr. Clinton Riley, U.S. Fish and Wildlife Service ML11339A043

February 24, 2012 Letter to Exelon, “Request for Additional Information for the 

Review of the Limerick Generating Station, Units 1 and 2, 

License Renewal Application Environmental Review”

ML12041A443

March 27, 2012 Letter from Exelon, “Limerick Generating Station, Units 1 and 

2–Response to NRC Request for Additional Information, Dated 

February 28, 2012, Related to the License Renewal Application”

ML12088A366

April 11, 2012 Memorandum, “Summary of Telephone Conference Call on 

February 23, 2012, Between the U.S. Nuclear Regulatory 

Commission and Exelon Generation Company, LLC, 

Concerning Request for Additional Information Pertaining to the 

Limerick Generating Station License Renewal Application”

ML12083A211

E-3 
Appendix E

Date Correspondence Description ADAMS No.

May 21, 2012 Summary of Site Audit Related to the Environmental Review of 

the License Renewal Application for Limerick Generating 

Station, Units 1 and 2

ML12124A127

May 30, 2012 Letter to Mr. Daniel Morris, National Marine Fisheries Service ML12138A347

June 27, 2012 Letter from Ms. Mary Colligan, National Marine Fisheries Service ML12226A163

March 11, 2013 Letter to Exelon, “Issuance of Environmental Scoping Summary 

Report Associated with the Staff’s Review of the Application by 

Exelon Generation Company, LLC., for Renewal of the 

Operating License for Limerick Generating Station Units 1 

and 2”

ML12131A499

April 30, 2013 Letter to Exelon, “Notice of Availability of Draft Plant-Specific 

Supplement 49 to the Generic Environmental Impact Statement

for License Renewal of Nuclear Plants Regarding Limerick 

Generating Station Units 1 and 2”

ML13058A384

April 30, 2013 Letter to Mr. Shawn M. Garvin, Environmental Protection 

Agency

ML13067A317

May 6, 2013 Letter to Mr. Douglas C. McLearen, Pennsylvania Historical and 

Museum Commission

ML13066A492

May 7, 2013 Federal Register Notice of Availability of Draft Supplement 49 to 

the Generic Environmental Impact Statement for License 

Renewal of Nuclear Plants and Public Meetings for the License 

Renewal of Limerick Generating Station, Units 1 and 2

(78 FR 26663)

ML13058A481

May 7, 2013 Letter to Governor George Blanchard, Absentee Shawnee Tribe 

of Oklahoma

ML13066A482

May 7, 2013 Letter to Mr. Clint Halftown, Heron Clan Representative, Cayuga 

Nation

ML13066A482

May 7, 2013 Letter to Ms. Tamara Francis Cultural Preservation Director,

Delaware Nation

ML13066A482

May 7, 2013 Letter to Chief Paula Pechonick Delaware Tribe Indians ML13066A482

May 7, 2013 Letter to Chief Glenna J. Wallace, Eastern Shawnee Tribe of 

Oklahoma

ML13066A482

May 7, 2013 Letter to Mr. Raymond Halbritter, Nation Representative, Oneida 

Indian Nation

ML13066A482

May 7, 2013 Letter to Mr. Ed Delgado, Chairman, Oneida Nation of 

Wisconsin

ML13066A482

May 7, 2013 Letter to Tony Gonyea, Faithkeeper, Onondaga Nation ML13066A482

May 7, 2013 Letter to Barry E. Snyder, Sr., President, Seneca Nation of 

Indians

ML13066A482

May 7, 2013 Letter to Mr. LeRoy Howard, Chief, Seneca–CayugaTribe of 

Oklahoma

ML13066A482

May 7, 2013 Letter to Chief Randy Hart, St. Regis Mohawk Tribe ML13066A482

May 7, 2013 Letter to Chief Ron Sparkman, Shawnee Tribe ML13066A482

E-4 
Appendix E

Date Correspondence Description ADAMS No.

May 7, 2013 Letter to Robert Chicks, Tribal President, Stockbridge–Munsee 

Band of the Mohican Nation

ML13066A482

May 7, 2013 Letter to Chief Darwin Hill, Tonawanda Seneca Nation ML13066A482

May 7, 2013 Letter to Leo Henry, Chief, Tuscarora Nation ML13066A482

May 7, 2013 Letter to Mr. Reid Nelson, Director, Advisory Council on Historic 

Preservation

ML13066A480

May 7, 2013 Letter to Ms. Wendi Weber, U.S Fish and Wildlife Service ML13107A988

May 7, 2013 Letter to Ms. Mary A. Colligan, National Marine Fisheries

Service

ML13064A064

May 13, 2013 Letter from Ms. Mary A. Colligan, National Marine Fisheries

Service

ML13134A134

May 14, 2013 Letter from Mr. Corey Smith, Delaware Nation ML13135A152

May 20, 2013 Letter from Ms. Kim Jumper, Shawnee Tribe ML13141A124

June 27, 2013 Letter from Ms. Barbara Rudnick, Environmental Protection 

Agency

ML13183A033

July 2, 2013 E-mail from Ms. Dianne Thees, U.S. Fish and Wildlife Service ML13196A362

August 16, 2013 Letter from Ms. Lora L. Zimmerman, U.S. Fish and Wildlife 

Service

ML13242A072

February 12, 2014 Letter to Exelon, “Request for Additional Information for the 

Review of the Limerick Generating Station License Renewal 

Application”

ML14029A162

March 11, 2014 Memorandum, “Summary of Telephone Conference Call on 

January 30, 2014, Between the U.S. Nuclear Regulatory 

Commission and Exelon Generation Company, LLC, 

Concerning Request for Additional Information Pertaining to the 

Limerick Generating Station License Renewal Application”

ML14055A532

March 12, 2104 Letter from Exelon, “Requests for Additional Information for the 

review of the Limerick GeneratingStation, Units 1 and 2, License 

Renewal Application”

ML14071A378

E-5 

APPENDIX F 

DESCRIPTION OF PROJECTS CONSIDERED IN THE CUMULATIVE 

IMPACTS ANALYSIS

F. DESCRIPTION OF PROJECTS CONSIDERED IN THE CUMULATIVE 

IMPACTS ANALYSIS

F.1 Description of Projects Considered

To evaluate cumulative impacts, the incremental impacts of the proposed action, as described 

in Sections 4.1–4.9, are combined with other past, present, and reasonably foreseeable future 

actions regardless of what agency (Federal or non-Federal) or person undertakes such other 

actions. The U.S. Nuclear Regulatory Commission (NRC) staff (staff) used the information in 

the environmental report (ER); responses to requests for additional information (RAIs); 

information from other Federal, State, and local agencies; scoping comments; and information 

gathered during the visits to the Limerick Generating Station, Units 1 and 2 (LGS) site to identify 

other past, present, and reasonably foreseeable actions. Other actions and projects that were 

identified during this review, and considered in the staff’s independent analysis of the potential 

cumulative effects, are described in Table F–1. 

F-1 
Appendix F

Table F–1. Projects and Actions Considered in the Cumulative Impacts Analysis

Project Name Summary of Project Location Status

Moser Generating 

Station Oil Plant

60 MW, 3 unit oil-fired peaking plant Lower 

Pottstown 

Township, 

approximately 

2 miles (mi) 

west (W) of 

LGS

Operational (Exelon 

Corp. 2012); 

(Exelon 2011)

Linfield Energy 

Center 

616 MW, 3 unit natural gas plant 3 mi northwest 

(NW) of LGS

Air-quality permitted 

in 2002, but project 

“withdrawn” and not 

constructed (EJN; 

Enviro 2002)

Schuylkill 

Generating 

Station 

196 MW, 3 unit oil power plant 29 mi NW of 

LGS

Operational (Exelon 

Corp. 2012)

Cromby 

Generation 

Station

2 unit fossil fuel power plant located 

on the Schuylkill River

8 mi south (S) 

of LGS

Both units were 

retired from service in 

2011 (EPA 2012a; 

Exelon 2011)

Titus Coal Plant 261 MW, 5 unit coal power plant 18 mi NW of 

LGS

Expected deactivation 

date is April 2015

(NRG 2012)

Ontelaunee 

Energy Center 

Gas Plant

728 MW, 3 unit gas power plant 23 mi northeast 

(NE) of LGS

Operational 

(GEO 2012b)

Montenay 

Montgomery LP 

Waste Plant

32 MW, 1 unit waste power plant 17 mi southeast

(SE) of LGS

Operational 

(GEO 2012c)

Grays Ferry 

Cogeneration Gas 

Plant

193 MW, 2 unit gas power plant 29 mi SE of 

LGS

Operational 

(GEO 2012d)

Chester 

Generating 

Station Oil Plant

56 MW, 3 unit oil power plant 20 mi 

southwest (SW) 

of LGS

Operational 

(GEO 2012e)

Philadelphia 

Refinery Waste 

Plant

30 MW, 3 unit waste power plant 30 mi SE of 

LGS

Operational 

(GEO 2012f)

Delaware 

Generating 

Station Oil Plant

392 MW, 4 unit oil power plant 30 mi SE of 

LGS

Operational 

(GEO 2012g)

Eddystone 

Generating

Station 

820 MW, 6-unit fossil power plant (2 units 

natural gas or oil; 4 units oil)

20 mi SE of 

LGS

Operational (Exelon

Corp. 2013) 

F-2 
Appendix F

Project Name Summary of Project Location Status

Florida Power & 

Light Energy 

Marcus Hook Gas 

Plant

836 MW, 4 unit gas power plant 30 mi SE of 

LGS

Operational 

(GEO 2012h) 

Chester 

Operational Coal 

Plant

67 MW, 1 unit coal power plant 29 mi SE of 

LGS

Operational 

(GEO 2012i) 

Royersford 

Borough

Sewage/wastewater treatment plant that 

discharges 54 millions of gallons per day 

(mgd) to the Schuylkill River

4 mi SE of LGS Operational 

(EPA 2012b) 

Spring City 

Borough

Sewage/wastewater treatment plant that 

discharges .345 mgd to the Schuylkill 

River

7 mi SE of LGS Operational 

(EPA 2012b) 

Limerick 

Township 

Municipal 

Authority

Sewage/wastewater treatment plant that 

discharges 1.7 mgd to the Schuylkill River

3 mi SE of LGS Operational 

(EPA 2012b) 

East Vincent 

Municipal 

Authority

Sewage/wastewater treatment plant that 

discharges .5 mgd to the Schuylkill River

4 mi S of LGS Operational 

(EPA 2012b) 

North Coventry 

Municipal 

Authority

Sewage/wastewater treatment plant that 

discharges 1.5 mgd to the Schuylkill River

2 mi W of LGS Operational 

(EPA 2012b) 

Phoenixville 

Borough Sewage 

Treatment Plant

Sewage/wastewater treatment plant that 

discharges 4 mgd to the Schuylkill River

9 mi SE of LGS Operational 

(EPA 2012b) 

Lower Frederick 

Township Sewage 

Treatment Plant

Sewage/wastewater treatment plant that 

discharges .2 mgd to the Perkiomen 

Creek

7 mi NE of LGS Operational 

(EPA 2012b) 

Schwenksville 

Borough Authority 

Sewage 

Treatment Plant 

Sewage/wastewater treatment plant that 

discharges .3 mgd to the Perkiomen 

Creek

7 mi NE of LGS Operational 

(EPA 2012b) 

Pottstown Water 

Treatment Plant

Sewage/wastewater treatment plant 

withdraws up to 5 mgd from the Schuylkill 

River

2 mi W of LGS Operational 

(EPA 2012c) 

Pennsylvania 

American Water 

Company, Shady 

Lane Water 

Treatment Plant

Sewage/wastewater treatment plant that 

discharges .111 mgd to the Schuylkill 

River

2 mi S of LGS Operational 

(EPA 2012b) 

JBS Souderton,

Inc., Industrial 

Waste Water 

Treatment Plant

Sewage/wastewater treatment plant that 

discharges .832 mgd to the Skippack 

Creek at River Mile 92.47 – 32.3 – 3.0 – 

12.8 (Delaware River – Schuylkill River – 

Perkiomen Creek – Skippack Creek)

15 mi NE of 

LGS

Operational 

(DRBC 2011)

F-3 
Appendix F

Project Name Summary of Project Location Status

Warwick Drainage 

Company

Public wastewater collection, treatment, 

and disposal that discharges .0135 mgd to 

the French Creek (Schuylkill River 

Tributary)

8 mi NW of 

LGS

Operational 

(EPA 2012b) 

Doehler-Jarvis 

Limited 

Partnership

Aluminum die casting 5 mi W of LGS Operational 

(EPA 2012b) 

Sun Co., Inc. Major gas service station 3 mi NE of LGS Operational 

(EPA 2012b)

Pottstown Trap 

Sanatoga Quarry

Quarry 3,650 feet NW, 

directly 

adjacent to 

Schuylkill River 

and contiguous 

with the LGS 

plant site 

property

Operational 

(Exelon 2011)

Uniform Tubes, 

Inc.

Steel parts manufacturing 6 mi SE of LGS Operational 

(EPA 2012b)

Plotts Oil Co. Heating oil distribution 4 mi SE of LGS Operational 

(EPA 2012b)

Specialty 

Chemical 

Systems

Inorganic chemical production 4 mi SE of LGS Operational 

(EPA 2012b) 

Spring City 

Electric 

Manufacturing 

Company

Iron foundry discharges 4 mi SE of LGS Operational 

(EPA 2012b) 

Unitech Services 

Group, Inc.

Industrial launderer 3 mi SE of LGS Operational 

(EPA 2012b)

Smurfit-Stone 

Container

Paper packaging 9 mi SE of LGS Operational 

(EPA 2012b)

Wyeth 

Pharmaceuticals

Biotechnology research and development 8 mi SE of LGS Operational 

(EPA 2012b)

GlaxoSmithKline Pharmaceutical manufacturing 7 mi SE of LGS Operational 

(EPA 2012b)

Evansburg State 

Park

3,349 acre state park in south-central 

Montgomery County between Norristown 

and Collegeville

10 mi east of 

LGS

Operational 

(DCNR 2012a)

Fort Washington 

State Park

493 acre state park in Springfield and 

Whitemarsh Townships, Montgomery 

County

20 mi SE of 

LGS

Operational 

(DCNR 2012b)

Norristown Farm 

Park

690 acre park in East Norriton and West 

Norriton Townships and the Borough of 

Norristown

14 mi SE of 

LGS

Operational 

(DCNR 2012c)

F-4 
Appendix F

Project Name Summary of Project Location Status

Marsh Creek 

State Park

1,727 acre state park in Chester County 11 mi SW of 

LGS

Operational 

(DCNR 2012d)

Valley Forge 

National Park

3,500 acre national historic park 11 mi SE of 

LGS

Operational

(NPS 2013)

French Creek 

State Park

7,730 acre state park in North Coventry 

and Warwick Townships in Chester 

County and Robeson and Union 

Townships in Berks County

10 mi W of LGS Operational 

(DCNR 2012e)

Ridley Creek 

State Park

2,606 acres of Delaware County 

woodlands and meadows

25 mi SE of 

LGS

Operational 

(DCNR 2012f)

Independent 

Spent Fuel 

Storage 

Installation (ISFSI)

The ISFSI provides dry storage for spent 

fuel at the LGS site

At LGS Operational 

(Exelon 2011)

Recticon/Allied 

Steel Corp.

Comprehensive Environmental Response, 

Compensation, and Liability Act 

(CERCLA) site 

1 mi S of LGS CERCLA site (EPA)

Occidental 

Chemical 

Corporation 

Remediation Site 

(Formerly 

Firestone Tire and 

Rubber 

Manufacturing 

Facility)

Occidental Chemical Corporation is 

remediating under the oversight of EPA

2.5 mi W of 

LGS 

Superfund site 

(Exelon 2011)

F.2 References

[DCNR] Pennsylvania Department of Conservation and Natural Resources. 2012a. Available at 

<http://www.dcnr.state.pa.us/stateparks/findapark/evansburg/index.htm> (accessed 

8 August 2012).

[DCNR] Pennsylvania Department of Conservation and Natural Resources. 2012b. Available at 

<http://www.dcnr.state.pa.us/stateparks/findapark/fortwashington/index.htm> (accessed 

8 August 2012).

[DCNR] Pennsylvania Department of Conservation and Natural Resources. 2012c. Available at 

<http://www.dcnr.state.pa.us/stateparks/findapark/norristown/index.htm> (accessed 

8 August 2012).

[DCNR] Pennsylvania Department of Conservation and Natural Resources. 2012d. Available at 

<http://www.dcnr.state.pa.us/stateparks/findapark/marshcreek/index.htm> (accessed 

8 August 2012).

[DCNR] Pennsylvania Department of Conservation and Natural Resources. 2012e. Available at 

<http://www.dcnr.state.pa.us/stateparks/findapark/frenchcreek/index.htm> (accessed 

8 August 2012).

F-5 
Appendix F

[DCNR] Pennsylvania Department of Conservation and Natural Resources. 2012f. Available at 

<http://www.dcnr.state.pa.us/stateparks/findapark/ridleycreek/index.htm> (accessed 

8 August 2012).

[DRBC] Delaware River Basin Commission. 2012. DOCKET NO. D-1996-021-4, JBS 

Souderton, Inc., Industrial Wastewater Treatment Plant, Franconia Township, Montgomery 

County, Pennsylvania. Available at 

<http://www.state.nj.us/drbc/library/documents/dockets/1996-021-4.pdf> (accessed 

7 July 2012).

[EJN] Energy Justice Network. Linfield Energy Center. Available at 

<http://www.energyjustice.net/map/displayfacility-68986.htm> (accessed 11 July 2012).

[Enviro] Enviro.blr.com. 2002. Environmental Compliance News. “DEP Issues Air Plan Approval 

to Florida Power and Light for Its Linfield Energy Center Project.” April 10, 2002. Available at

<http://enviro.blr.com/environmental-news/air/air-permitting/

DEP-Issues-Air-Plan-Approval-to-Florida-Power-and-/> (accessed 11 July 2012). 

[EPA] U.S. Environmental Protection Agency. 2012a. Envirofacts. Air Facility System (AFS). 

Available at <http://ofmpub.epa.gov/enviro/

afs_reports.detail_plt_view?p_state_county_compliance_src=4202900003> (accessed 

11 July 2012).

[EPA] U.S. Environmental Protection Agency. 2012b. Envirofacts, Permit Compliance System 

(PCS) and Integrated Compliance Information System (ICIS) databases. Available at 

<http://www.epa.gov/enviro/facts/pcs-icis/index.html> (accessed 11 July 2012).

[EPA] U.S. Environmental Protection Agency. 2012c. Envirofacts. Comprehensive 

Environmental Response, Compensation, and Liability Information System (CERCLIS). 

Available at 

<http://ofmpub.epa.gov/enviro/cerclisquery.get_report?pgm_sys_id=PAD002353969> 

(accessed 11 July 2012)

[Exelon] Exelon Generation Company, LLC. 2011. Applicant’s Environmental Report –Operating 

License Renewal Stage, Limerick Generating Station, Units 1 and 2, Docket Numbers 50 352 

and 50-353, License Numbers NPF-39 and NPF-85. Exelon Generation Company, LLC. 

Agencywide Documents Access and Management Systems No. ML11179A104.

[Exelon Corp] Exelon Corporation. 2012. Energy Diversity for Pennsylvania. Available at 

<http://www.exeloncorp.com/community/locations/pennsylvania.aspx> (accessed 11 July 2012).

[Exelon Corp]Exelon Corporation. 2013. “Eddystone Generating Station.” Available at 

<http://www.exeloncorp.com/powerplants/eddystone/Pages/profile.aspx> (accessed 2 July 

2013).

[GEO] Global Energy Observatory. 2012a. Available at 

<http://globalenergyobservatory.org/geoid/1737> (accessed 11 July 2012).

[GEO] Global Energy Observatory. 2012b. Available at 

<http://globalenergyobservatory.org/geoid/4624> (accessed 11 July 2012).

[GEO] Global Energy Observatory. 2012c. Available at 

<http://globalenergyobservatory.org/geoid/4351> (accessed 11 July 2012).

[GEO] Global Energy Observatory. 2012d. Available at 

<http://globalenergyobservatory.org/geoid/3386> (accessed 11 July 2012).

F-6 
Appendix F

[GEO] Global Energy Observatory. 2012e. Available at 

<http://globalenergyobservatory.org/geoid/2651> (accessed 11 July 2012).

[GEO] Global Energy Observatory. 2012f. Available at 

<http://globalenergyobservatory.org/geoid/4778> (accessed 11 July 2012).

[GEO] Global Energy Observatory. 2012g. Available at 

<http://globalenergyobservatory.org/geoid/5080> (accessed 11 July 2012).

[GEO] Global Energy Observatory. 2012h. Available at 

<http://globalenergyobservatory.org/geoid/3221> (accessed 11 July 2012).

[GEO] Global Energy Observatory. 2012i. Available at 

<http://globalenergyobservatory.org/geoid/320> (accessed 11 July 2012).

[NPS] National Parks Service. 2013. Available at <http://www.nps.gov/vafo/index.htm> 

(accessed 22 October 2013)

[NRG] NRG Energy, Inc. 2012 Form 10-K. 2012. Available at 

<http://www.nrgenergy.com/pdf/NRG_10K_2012.pdf> (accessed 22 October 2013)

F-7 




UNITED STATES

NUCLEAR REGULATORY COMMISSION

WASHINGTON, DC 20555-0001

------------------

OFFICIAL BUSINESS
NUREG-1437, 

Supplement 49, Vol. 2

Final

Generic Environmental Impact Statement for License Renewal of Nuclear Plants 

Regarding Limerick Generating Station, Units 1 and 2