NUREG-1437 

Supplement 41 

Generic Environmental 

Impact Statement for 

License Renewal of 

Nuclear Plants 

Supplement 41 

Regarding Cooper Nuclear 

Station, Unit 1 

Draft Report for Comment 

Office of Nuclear Reactor Regulation 
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Generic Environmental 

Impact Statement for 

License Renewal of 

Nuclear Plants 

Supplement 41 

Regarding Cooper Nuclear 

Station, Unit 1 

Draft Report for Comment 

Manuscript Completed: January 2010 

Date Published: February 2010 

Office of Nuclear Reactor Regulation 

NUREG-1437 

Supplement 41 

February 2010 iii Draft NUREG-1437, Supplement 41 

1 Proposed Action Issuance of renewed operating license DPR-46 for Cooper 

2 Nuclear Station, Unit 1, in the city of Brownville, Nemaha County, 

3 Nebraska. 

4 

5 Type of Statement Draft Supplemental Environmental Impact Statement 

6 

7 Agency Contact Bennett Brady 

8 U.S. Nuclear Regulatory Commission 

9 Office of Nuclear Reactor Regulation 

10 Mail Stop O-11F1 

11 Washington, D.C. 20555-0001 

12 Phone: 301-415-2981 

13 Email: Bennett.Brady@nrc.gov 

14 

15 Comments Any interested party may submit comments on this supplemental 

16 environmental impact statement. Please specify NUREG-1437, 

17 Supplement 41, draft, in your comments. Comments must be 

18 received by April 6, 2010. Comments received after the expiration 

19 of the comment period will be considered if it is practical to do so, 

20 but assurance of consideration of late comments will not be given. 

21 Comments may be emailed to CooperEIS@nrc.gov or mailed to: 

22 

23 Chief, Rulemaking, Directives, and Editing Branch 

24 U.S. Nuclear Regulatory Commission 

25 Mail Stop T6-D59 

26 Washington, D.C. 20555-0001 

27 

28 Please be aware that any comments that you submit to the NRC 

29 will be considered a public record and entered into the 

30 Agencywide Documents Access and Management System 

31 (ADAMS). Do not provide information you would not want to be 

32 publicly available. 

33 

February 2010 v Draft NUREG-1437, Supplement 41 

1 ABSTRACT 

2 This draft supplemental environmental impact statement (SEIS) has been prepared in response 

3 to an application submitted by Nebraska Public Power District (NPPD) to renew the operating 

4 license for Cooper Nuclear Station, Unit 1, for an additional 20 years. 

5 This draft SEIS includes the preliminary analysis that evaluates the environmental impacts of 

6 the proposed action and alternatives to the proposed action. Alternatives considered include 

7 replacement power from new supercritical coal-fired generation; natural gas combined-cycle 

8 generation; a combination of alternatives that include natural gas combined-cycle generation, 

9 energy conservation, and wind; and not renewing the license (the no-action alternative). 

10 The preliminary recommendation is that the U.S. Nuclear Regulatory Commission (NRC) 

11 determines that the adverse environmental impacts of license renewal for Cooper Nuclear 

12 Station, Unit 1, are not so great that preserving the option of license renewal for energy13 planning decision makers would be unreasonable.

February 2010 vii Draft NUREG-1437, Supplement 41 

1 TABLE OF CONTENTS 

2 Abstract......................................................................................................................................... v

3 Table of Contents........................................................................................................................ vii

4 Figures........................................................................................................................................xiii

5 Tables ........................................................................................................................................ xiv

6 Executive Summary ...................................................................................................................xvii

7 Background ............................................................................................................................xvii

8 Proposed Action .....................................................................................................................xvii

9 Purpose And Need For Action...............................................................................................xviii

10 Environmental Impacts of License Renewal..........................................................................xviii

11 Land Use .......................................................................................................................xviii

12 Air Quality ........................................................................................................................ xix

13 Ground Water Use and Quality........................................................................................... xix

14 Surface Water Use and Quality .......................................................................................... xix

15 Aquatic Resources.............................................................................................................. xix

16 Terrestrial Resources ......................................................................................................... xix

17 Threatened and Endangered Species................................................................................. xx

18 Human Health...................................................................................................................... xx

19 Socioeconomics................................................................................................................... xx

20 Severe Accident Mitigation Alternatives ............................................................................. xxi

21 Alternatives.............................................................................................................................xxii

22 Comparison of Alternatives ....................................................................................................xxii

23 Recommendation ..................................................................................................................xxiii

24 Abbreviations and Acronyms .................................................................................................... xxv

25 1.0 Purpose and Need for Action.............................................................................................1-1

26 1.1 Proposed Federal Action................................................................................................1-1

27 1.2 Purpose And Need for the Proposed Federal Action .....................................................1-1

28 1.3 Major Environmental Review Milestones........................................................................1-2

29 1.4 Generic Environmental Impact Statement......................................................................1-3

30 1.5 Supplemental Environmental Impact Statement ............................................................1-5

31 1.6 Cooperating Agencies ....................................................................................................1-6

32 1.7 Consultations..................................................................................................................1-6

33 1.8 Correspondence.............................................................................................................1-7

34 1.9 Status of Compliance .....................................................................................................1-9

35 1.10 References .................................................................................................................1-11

36 2.0 Affected Environment.........................................................................................................2-1 

37 2.1 Facility Description .........................................................................................................2-1 

38 2.1.1 Reactor and Containment Systems.........................................................................2-1 

39 2.1.2 Radioactive Waste Management.............................................................................2-5 

40 2.1.2.1 Radioactive Liquid Waste..................................................................................2-6 

41 2.1.2.2 Radioactive Gaseous Waste.............................................................................2-6 

42 2.1.2.3 Radioactive Solid Waste ...................................................................................2-7 

43 2.1.3 Nonradiological Waste Management.......................................................................2-8 
Table of Contents 

Draft NUREG-1437, Supplement 41 viii February 2010 

1 2.1.3.1 Nonradioactive Waste Steams..........................................................................2-8 

2 2.1.3.2 Pollution Prevention and Waste Minimization ...................................................2-9 

3 2.1.4 Plant Operation and Maintenance .........................................................................2-10 

4 2.1.5 Power Transmission System .................................................................................2-10 

5 2.1.6 Cooling and Auxiliary Water Systems....................................................................2-12 

6 2.1.7 Facility Water Use and Quality ..............................................................................2-17 

7 2.1.7.1 Ground Water Use and Quality.......................................................................2-17 

8 2.1.7.2 Surface Water Use and Quality.......................................................................2-18 

9 2.1.7.3 National Pollutant Discharge Elimination System ...........................................2-18 

10 2.1.7.4 Dredging..........................................................................................................2-20 

11 2.2 Surrounding Environment.............................................................................................2-20 

12 2.2.1 Land Use ...............................................................................................................2-20 

13 2.2.2 Climate and Meteorology.......................................................................................2-23 

14 2.2.2.1 Air Quality Impacts..........................................................................................2-24 

15 2.2.3 Ground Water Resources......................................................................................2-25 

16 2.2.4 Surface Water Resources......................................................................................2-25 

17 2.2.5 Description of Aquatic Resources..........................................................................2-26 

18 2.2.5.1 Ecosystem Services Provided by Missouri River Aquatic Ecosystems...........2-26 

19 2.2.5.2 Conceptual Model of Midwestern Rivers.........................................................2-27 

20 2.2.5.3 Description of the Missouri River Basin ..........................................................2-28 

21 2.2.5.4 Physical Features of the Missouri River near the Cooper Nuclear Station .....2-30 

22 2.2.5.5 Potentially Affected Aquatic Resources ..........................................................2-31 

23 2.2.5.6 Primary Producers: Phytoplankton, Periphyton, and Aquatic 

24 Macrophytes .................................................................................................2-31 

25 2.2.5.7 Invertebrates: Zooplankton and Benthos ........................................................2-32 

26 2.2.5.8 Larval Fish.......................................................................................................2-34 

27 2.2.5.9 Fish .................................................................................................................2-35 

28 2.2.6 Terrestrial Resources ............................................................................................2-36 

29 2.2.7 Protected Species..................................................................................................2-39

30 2.2.7.1 Aquatic Species ..............................................................................................2-48 

31 2.2.7.2 Terrestrial Species ..........................................................................................2-51 

32 2.2.8 Socioeconomic Factors .........................................................................................2-55 

33 2.2.8.1 Housing...........................................................................................................2-56 

34 2.2.8.2 Public Services................................................................................................2-57 

35 2.2.8.3 Offsite Land Use .............................................................................................2-61 

36 2.2.8.4 Visual Aesthetics and Noise............................................................................2-62 

37 2.2.8.5 Demography....................................................................................................2-63 

38 2.2.8.6 Economy .........................................................................................................2-69 

39 2.2.9 Historic and Archaeological Resources.................................................................2-72 

40 2.2.9.1 Cultural Background........................................................................................2-72 

41 2.2.9.2 Prehistoric Periods..........................................................................................2-72 

42 2.2.9.3 Historic Period.................................................................................................2-73 

43 2.2.10 Historic and Archaeological Resources at the Cooper Nuclear Station, 

44 Unit 1 Site......................................................................................................2-74 

45 2.3 Related Federal and State Activities ............................................................................2-75 

46 2.4 References ...................................................................................................................2-76 

47 3.0 Environmental Impacts of Refurbishment ..........................................................................3-1 

48 3.1 References .....................................................................................................................3-4 
Table of Contents 

February 2010 ix Draft NUREG-1437, Supplement 41 

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

2 4.1 Land Use ........................................................................................................................4-1 

3 4.2 Air Quality.......................................................................................................................4-1 

4 4.3 Ground Water.................................................................................................................4-2 

5 4.3.1 Generic Ground Water Issues .................................................................................4-2 

6 4.3.2 Ground Water Use Conflicts....................................................................................4-2 

7 4.4 Surface Water ................................................................................................................4-2 

8 4.4.1 Generic Surface Water Issues.................................................................................4-2 

9 4.4.2 Water Use Conflicts.................................................................................................4-4

10 4.5 Aquatic Resources .........................................................................................................4-4 

11 4.5.1 Generic Aquatic Ecology Issues..............................................................................4-4 

12 4.5.2 Entrainment and Impingement.................................................................................4-5 

13 4.5.2.1 Introduction .......................................................................................................4-5 

14 4.5.2.2 History of Cooper Nuclear Station’s 316(b) Compliance...................................4-5 

15 4.5.2.3 Analysis.............................................................................................................4-6 

16 4.5.3 Thermal Effects........................................................................................................4-9 

17 4.5.4 Total Impacts on Aquatic Resources.......................................................................4-9 

18 4.6 Terrestrial Resources ...................................................................................................4-11 

19 4.7 Protected Species ........................................................................................................4-11 

20 4.7.1 Aquatic Species.....................................................................................................4-11 

21 4.7.2 Terrestrial Species.................................................................................................4-12 

22 4.8 Human Health ..............................................................................................................4-14 

23 4.8.1 Generic Human Health Issues...............................................................................4-14 

24 4.8.2 Microbiological Organisms.....................................................................................4-16 

25 4.8.3 Electromagnetic Fields – Acute Shock ..................................................................4-17 

26 4.8.4 Electromagnetic Fields–Chronic Effects................................................................4-18 

27 4.9 Socioeconomics ...........................................................................................................4-18 

28 4.9.1 Generic Socioeconomic Issues .............................................................................4-19 

29 4.9.2 Housing Impacts....................................................................................................4-20

30 4.9.3 Public Services: Public Utility Impacts...................................................................4-20 

31 4.9.4 Offsite Land Use – License Renewal Period .........................................................4-20 

32 4.9.4.1 Population-Related Impacts............................................................................4-21 

33 4.9.4.2 Tax Revenue-Related Impacts........................................................................4-21 

34 4.9.5 Public Services: Transportation Impacts ...............................................................4-22 

35 4.9.6 Historic and Archaeological Resources.................................................................4-22 

36 4.9.7 Environmental Justice............................................................................................4-24 

37 4.9.7.1 Minority Population in 2000.............................................................................4-26 

38 4.9.7.2 Low-Income Population in 2000......................................................................4-28 

39 4.9.7.3 Analysis of Impacts .........................................................................................4-32 

40 4.9.7.4 Subsistence Consumption of Fish and Wildlife...............................................4-32 

41 4.10 Evaluation of New and Potentially Significant Information .........................................4-34 

42 4.11 Cumulative Impacts....................................................................................................4-34 

43 4.11.1 Cumulative Impacts on Water Resources ...........................................................4-35 

44 4.11.2 Cumulative Impacts on Electromagnetic Fields and Thermophilic 

45 Microbiological Organisms ............................................................................4-35 

46 4.11.3 Cumulative Impacts on Aquatic Resources.........................................................4-36 

47 4.11.4 Cumulative Impacts on Terrestrial Resources.....................................................4-40 

48 4.11.5 Cumulative Air Quality Impacts............................................................................4-43 

49 4.11.6 Cumulative Human Health Impacts .....................................................................4-45 

50 4.11.7 Cumulative Socioeconomic Impacts....................................................................4-45 

51 4.11.8 Summary of Cumulative Impacts.........................................................................4-46 
Table of Contents 

Draft NUREG-1437, Supplement 41 x February 2010 

1 4.12 References .................................................................................................................4-48 

2 5.0 Environmental Impacts of Postulated Accidents................................................................5-1 

3 5.1 Design-Basis Accidents..................................................................................................5-1 

4 5.2 Severe Accidents ...........................................................................................................5-2 

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

6 5.3.1 Introduction..............................................................................................................5-3 

7 5.3.2 Estimate of Risk.......................................................................................................5-4 

8 5.3.3 Potential Plant Improvements..................................................................................5-5 

9 5.3.4 Evaluation of Risk Reduction and Costs of Improvements......................................5-5 

10 5.3.5 Cost-Benefit Comparison.........................................................................................5-6 

11 5.3.6 Conclusions .............................................................................................................5-7 

12 5.4 References .....................................................................................................................5-8 

13 6.0 Environmental Impacts of the Uranium Fuel Cycle, and Solid Waste Management, 

14 and Greenhouse Gaseous Emissions.............................................................................6-1 

15 6.1 The Uranium Fuel Cycle.................................................................................................6-1 

16 6.2 Greenhouse Gas Emissions...........................................................................................6-2 

17 6.2.1 Existing Studies .......................................................................................................6-2 

18 6.2.1.1 Qualitative Studies ............................................................................................6-3 

19 6.2.1.2 Quantitative.......................................................................................................6-3 

20 6.2.1.3 Summary of Nuclear Greenhouse Gas Emissions Compared to Coal .............6-5 

21 6.2.1.4 Summary of Nuclear Greenhouse Gas Emissions Compared to Natural 

22 Gas .................................................................................................................6-5 

23 6.2.1.5 Summary of Nuclear Greenhouse Gas Emissions Compared to 

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

25 6.2.2 Conclusions: Relative GHG Emissions....................................................................6-7 

26 6.3 References .....................................................................................................................6-9 

27 7.0 Environmental Impacts of Decommissioning .....................................................................7-1 

28 7.1 Decommissioning ...........................................................................................................7-1 

29 7.2 References .....................................................................................................................7-2 

30 8.0 Environmental Impacts of Alternatives...............................................................................8-1 

31 8.1 Supercritical Coal-Fired Generation ...............................................................................8-3 

32 8.1.1 Air Quality ................................................................................................................8-4 

33 8.1.1.1 Sulfur Oxides.....................................................................................................8-5

34 8.1.1.2 Nitrogen Oxides ................................................................................................8-6 

35 8.1.1.3 Particulates .......................................................................................................8-6 

36 8.1.1.4 Carbon Monoxide..............................................................................................8-6 

37 8.1.1.5 Carbon Dioxide .................................................................................................8-6 

38 8.1.1.6 Summary of Air Quality .....................................................................................8-7 

39 8.1.2 Ground Water Use and Quality................................................................................8-7 

40 8.1.3 Surface Water Use and Quality ...............................................................................8-7 

41 8.1.4 Aquatic and Terrestrial Ecology...............................................................................8-7 

42 8.1.4.1 Aquatic Ecology ................................................................................................8-7 

43 8.1.4.2 Terrestrial Ecology ............................................................................................8-8 

44 8.1.5 Human Health..........................................................................................................8-8 

45 8.1.6 Socioeconomics.......................................................................................................8-9 

46 8.1.6.1 Land Use...........................................................................................................8-9 

47 8.1.6.2 Socioeconomics..............................................................................................8-10 
Table of Contents 

February 2010 xi Draft NUREG-1437, Supplement 41 

1 8.1.6.3 Transportation.................................................................................................8-10 

2 8.1.6.4 Aesthetics........................................................................................................8-11 

3 8.1.6.5 Historic and Archaeological Resources ..........................................................8-11 

4 8.1.6.6 Environmental Justice.....................................................................................8-12 

5 8.1.7 Waste Management...............................................................................................8-12 

6 8.2 Natural Gas-Fired Combined-Cycle Generation...........................................................8-13 

7 8.2.1.1 Air Quality........................................................................................................8-14 

8 8.2.1.2 Sulfur and Nitrogen Oxides .............................................................................8-15 

9 8.2.1.3 Particulates .....................................................................................................8-15

10 8.2.1.4 Hazardous Air Pollutants.................................................................................8-15 

11 8.2.1.5 Construction Impacts ......................................................................................8-15 

12 8.2.2 Ground Water Use and Quality..............................................................................8-16 

13 8.2.3 Surface Water Use and Quality .............................................................................8-16 

14 8.2.4 Aquatic and Terrestrial Ecology.............................................................................8-16 

15 8.2.4.1 Aquatic Ecology ..............................................................................................8-16 

16 8.2.4.2 Terrestrial Ecology ..........................................................................................8-17 

17 8.2.5 Human Health........................................................................................................8-17 

18 8.2.6 Socioeconomics.....................................................................................................8-18

19 8.2.6.1 Land Use.........................................................................................................8-18

20 8.2.6.2 Socioeconomics..............................................................................................8-18 

21 8.2.6.3 Transportation.................................................................................................8-19 

22 8.2.6.4 Aesthetics........................................................................................................8-19 

23 8.2.6.5 Historic and Archaeological Resources ..........................................................8-20 

24 8.2.6.6 Environmental Justice.....................................................................................8-20 

25 8.2.7 Waste Management...............................................................................................8-20 

26 8.3 Combination Alternative ...............................................................................................8-21 

27 8.3.1 Air Quality ..............................................................................................................8-21 

28 8.3.2 Ground Water Use and Quality..............................................................................8-23 

29 8.3.3 Surface Water Use and Quality .............................................................................8-24 

30 8.3.4 Aquatic and Terrestrial Ecology.............................................................................8-24 

31 8.3.4.1 Aquatic Ecology ..............................................................................................8-24 

32 8.3.4.2 Terrestrial Ecology ..........................................................................................8-24 

33 8.3.5 Human Health........................................................................................................8-25 

34 8.3.6 Socioeconomics.....................................................................................................8-25

35 8.3.6.1 Land Use.........................................................................................................8-25

36 8.3.6.2 Socioeconomics..............................................................................................8-26 

37 8.3.6.3 Transportation.................................................................................................8-27 

38 8.3.6.4 Aesthetics........................................................................................................8-27 

39 8.3.6.5 Historic and Archaeological Resources ..........................................................8-28 

40 8.3.6.6 Environmental Justice.....................................................................................8-28 

41 8.3.7 Waste Management...............................................................................................8-29 

42 8.4 Alternatives Considered but Dismissed........................................................................8-30 

43 8.4.1 Offsite Coal- and Gas-Fired Capacity....................................................................8-30 

44 8.4.2 Coal-Fired Integrated Gasification Combined-Cycle .............................................8-30 

45 8.4.3 New Nuclear ..........................................................................................................8-31 

46 8.4.4 Energy Conservation and Energy Efficiency .........................................................8-31 

47 8.4.5 Purchased Power ..................................................................................................8-31 

48 8.4.6 Solar Power ...........................................................................................................8-32 

49 8.4.7 Biomass Waste......................................................................................................8-32

50 8.4.8 Hydroelectric Power...............................................................................................8-32 

51 8.4.9 Wave and Ocean Energy.......................................................................................8-33 
Table of Contents 

Draft NUREG-1437, Supplement 41 xii February 2010 

1 8.4.10 Geothermal Power...............................................................................................8-33 

2 8.4.11 Municipal Solid-Waste .........................................................................................8-33 

3 8.4.12 Biofuels................................................................................................................8-34 

4 8.4.13 Oil-Fired Power....................................................................................................8-34 

5 8.4.14 Fuel Cells.............................................................................................................8-34 

6 8.4.15 Delayed Retirement.............................................................................................8-35 

7 8.5 No-Action Alternative....................................................................................................8-35 

8 8.5.1 Air Quality ..............................................................................................................8-35 

9 8.5.2 Ground Water Use and Quality..............................................................................8-35 

10 8.5.3 Surface Water Use and Quality .............................................................................8-36 

11 8.5.4 Aquatic and Terrestrial Resources ........................................................................8-36 

12 8.5.4.1 Aquatic Ecology ..............................................................................................8-36 

13 8.5.4.2 Terrestrial Ecology ..........................................................................................8-36 

14 8.5.5 Human Health........................................................................................................8-36 

15 8.5.6 Socioeconomics.....................................................................................................8-36

16 8.5.6.1 Land Use.........................................................................................................8-36

17 8.5.6.2 Socioeconomics..............................................................................................8-36 

18 8.5.6.3 Transportation.................................................................................................8-37 

19 8.5.6.4 Aesthetics........................................................................................................8-37 

20 8.5.6.5 Historic and Archaeological Resources ..........................................................8-37 

21 8.5.6.6 Environmental Justice.....................................................................................8-37 

22 8.5.7 Waste Management...............................................................................................8-37 

23 8.6 Alternatives Summary ..................................................................................................8-38 

24 8.7 References ...................................................................................................................8-40 

25 9.0 Conclusion .........................................................................................................................9-1 

26 9.1 Environmental Impacts of License Renewal...................................................................9-1 

27 9.2 Comparison of Environmental Impacts of License Renewal and Alternatives ...............9-2 

28 9.3 Resource Commitments.................................................................................................9-2 

29 9.3.1 Unavoidable Adverse Environmental Impacts.........................................................9-2 

30 9.3.2 The Relationship between Local Short-Term Uses of the Environment and 

31 the Maintenance and Enhancement of Long-Term Productivity .....................9-3 

32 9.3.3 Irreversible and Irretrievable Commitments of Resources.......................................9-3 

33 9.4 Recommendations .........................................................................................................9-4 

34 10.0 List of Preparers.............................................................................................................10-1 

35 11.0 Index ..............................................................................................................................11-1 

36 12.0 List of agencies, organizations, and persons to whom copies of the supplemental 

37 environmental impact statement are sent .....................................................................12-1 

38 Appendix A. Comments Received on the Cooper Nuclear Station, Unit 1, 

39 Environmental Review .................................................................................................. A-1 

40 Appendix B. National Environmental Policy Act Issues for License Renewal of Nuclear 

41 Power Plants.................................................................................................................. B-1 

42 Appendix C. Applicable Regulations, Laws, and Agreements .................................................. C-1
Table of Contents 

February 2010 xiii Draft NUREG-1437, Supplement 41 

1 Appendix D. Consultation Correspondence.............................................................................. D-1

2 Appendix D.2 Biological Assessment Cooper Nuclear Station License Renewal Date 

3 2009 Docket No. 50-298 U.S. Nuclear Regulatory Commission Rockville, 

4 Maryland ..................................................................................................................... D.2-1

5 Appendix E. Chronology of Environmental Review .................................................................. E-1

6 Appendix F. U.S. Nuclear Regulatory Commission Staff Evaluation of Severe Accident 

7 Mitigation Alternatives for Cooper Nuclear Station, Unit 1 In Support of License 

8 Renewal Application Review.......................................................................................... F-1

9 FIGURES 

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

11 Figure 1-2. Environmental Issues Evaluated During License Renewal. ...................................1-5

12 Figure 2.1-1. Location of Cooper Nuclear Station, Unit 1, 50-mile (80-kilometer) Region.........2-2

13 Figure 2.1-2. Location of Cooper Nuclear Station, Unit 1, 6-mile (10-kilometer) Region...........2-3

14 Figure 2.1-3. Cooper Nuclear Station, Unit 1, General Site Layout ...........................................2-4

15 Figure 2.1.5-1. Cooper Nuclear Station, Unit 1 Transmission Line Corridor............................2-12

16 Figure 2.1.6-1. Cooper Nuclear Station, Unit 1, Intake Structure Plan ....................................2-14

17 Figure 2.1.6-2. Cooper Nuclear Station, Unit 1, Intake Structure Section................................2-15

18 Figure 2.1.6-3. Cooper Nuclear Station, Unit 1, Typical Dual Flow Screen .............................2-16

19 Figure 2.2.1-1. Cooper Nuclear Station Facility Location ........................................................2-21

20 Figure 2.2.1-2. Cooper Nuclear Station, Unit 1, Site Boundary Map .......................................2-22

21 Figure 2.2.5-1. Conceptual model showing primary external and internal variables with 

22 their interactions that govern the integrity of the aquatic biota of 

23 Midwestern streams............................................................................................2-28

24 Figure 2.2.6-1. Nontidal Wetlands Located on the Cooper Nuclear Station, Unit 1, Site.........2-38

25 Figure 4-1. Minority Blocks in 2000 within a 50-Mile Radius of Cooper Nuclear Station 

26 (Individual State).................................................................................................4-27

27 Figure 4-2. Minority Blocks in 2000 within a 50-Mile Radius of Cooper Nuclear Station 

28 (Combined State)................................................................................................4-28

29 Figure 4-3. Low-Income Block Groups with a 50-Mile Radius of Cooper Nuclear Station 

30 (Individual States) ...............................................................................................4-30

31 Figure 4-4. Low-Income Block with a 50-Mile Radius of Cooper Nuclear Station 

32 (Combined States)..............................................................................................4-31
Table of Contents 

Draft NUREG-1437, Supplement 41 xiv February 2010 

1 TABLES 

2 Summary of Environmental Impacts of Proposed Action and Alternatives...............................xxiii

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

4 Table 2.1.7-1. Effluent Limitations (mg/L) – National Pollutant Discharge Elimination 

5 System Permit for Cooper Nuclear Station, Unit 1..............................................2-19

6 Table 2.2.7-1. Listed Aquatic and Terrestrial Species .............................................................2-39

7 Table 2.2.8-1. Cooper Nuclear Station, Unit 1 Employee Residence by County.....................2-56

8 Table 2.2.8.1-1. Housing in Nemaha, Otoe, and Richardson Counties in Nebraska and 

9 Atchison County in Missouri ...............................................................................2-57

10 Table 2.2.8.2–1. Public Water Supply Systems (thousand gallons per day) ...........................2-59

11 Table 2.2.8.2-2. Major Commuting Routes in the Vicinity of Cooper Nuclear Station, 

12 Unit 1 in 2006 Average Annual Daily Traffic Count ............................................2-61

13 Table 2.2.8.5-1. Population and Percent Growth in Nemaha, Otoe, and Richardson 

14 County, Nebraska, and Atchison County, Missouri, from 1970 to 2000 

15 and projected for 2006 to 2050...........................................................................2-63

16 Table 2.2.8.5-2. Demographic Profile of the Population in the Cooper Nuclear Station 

17 Unit 1 Four-County Socioeconomic Region of Influence in 2000 .......................2-64

18 Table 2.2.8.5-3. Demographic Profile of the Population in the Cooper Nuclear Station 

19 Four-County Socioeconomic Region of Influence in 2007, Estimated................2-65

20 Table 2.2.8.5-4. Seasonal Housing in Counties Located within 50 Miles of the Cooper 

21 Nuclear Station, Unit 1........................................................................................2-66

22 Table 2.2.8.5-5. Migrant Farm Workers and Temporary Farm Labor in Counties 

23 Located within 50 Miles of the Cooper Nuclear Station, Unit 1...........................2-68

24 Table 2.2.8.6-1. Major Employers in Nemaha County .............................................................2-69

25 Table 2.2.8.6-2. Estimated Income Information for the Cooper Nuclear Station Region 

26 of Influence in 2007 ............................................................................................2-70

27 Table 2.2.8.6-3. Cooper Nuclear Station, Unit 1 Estimated Tax Distribution, 2005–2007 .......2-71

28 Table 3-1. Category 1 Issues for Refurbishment Evaluation .....................................................3-2

29 Table 3-2. Category 2 Issues for Refurbishment Evaluation .....................................................3-3

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

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

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

33 Table 4-5. Human Health Issues .............................................................................................4-14

34 Table 4-6. Category 1 Issues Applicable to Socioeconomics during the Renewal Term.........4-19

35 Table 4-7. Category 1 Issues Applicable to Socioeconomics and Environmental Justice 

36 during the Renewal Term ...................................................................................4-19

37 Table 4-8. Intakes ....................................................................................................................4-39

38 Table 4-9. Stastny 2004...........................................................................................................4-40

39 Table 4-10. Summary of Cumulative Impacts on Resources Areas ........................................4-47

40 Table 5-1. Cooper Nuclear Station, Unit 1, Core Damage Frequency for Internal 

41 Events...................................................................................................................5-4

42 Table 5-2. Breakdown of Population Dose by Containment Release Mode ..............................5-5

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

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

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

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

47 Sources.................................................................................................................6-7

48 Table 7-1. Category 1 Issues Applicable to the Decommissioning of CNS-1 Following 

49 the Renewal Term ................................................................................................7-1 
Table of Contents 

February 2010 xv Draft NUREG-1437, Supplement 41 

1 Table 8-1. Summary of Environmental Impacts of the Supercritical Coal-Fired 

2 Alternative Compared to Continued Operation of CNS-1 ...................................8-13 

3 Table 8-2. Summary of Environmental Impacts of the Natural Gas-Fired Combined4 Cycle Generation Alternative Compared to Continued Operation of CNS5 1 .........................................................................................................................8-21

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

7 to Continued Operation of CNS-1.......................................................................8-30 

8 Table 8-4. Summary of Environmental Impacts of the No Action Alternative Compared 

9 to Continued Operation of CNS-1.......................................................................8-37 

10 Table 8-5. Summary of Environmental Impacts Proposed Action and Alternatives.................8-39 

11 B-1 

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

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

14 Table B-1. Summary of Issues and Findings. This table is taken from Table B-1 in 

15 Appendix B, Subpart A, to 10 CFR Part 51 ......................................................... B-1 

16 Table C-1. Federal Environmental Requirements..................................................................... C-1

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

18 Table F-1. Cooper Nuclear Station Core Damage Frequency for Internal Events.................... F-3

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

20 Table F-3. Cooper Nuclear Station Probabilistic Safety Assessment Historical 

21 Summary ............................................................................................................. F-5

22 Table F-4. Cooper Nuclear Station Fire Compartments and Their Contributions to Fire 

23 Core Damage Frequency .................................................................................... F-8

24 Table F-5. Severe Accident Mitigation Alternatives Cost/Benefit Screening Analysis for 

25 Cooper Nuclear Station ..................................................................................... F-21

26 

February 2010 xvii Draft NUREG-1437, Supplement 41 

1 EXECUTIVE SUMMARY 

2 BACKGROUND 

3 By letter dated September 24, 2008, Nebraska Public Power District (NPPD) submitted an 

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

5 license for Cooper Nuclear Station, Unit 1 (CNS-1), for an additional 20-year period. 

6 Pursuant to 10 CFR 51.20(b)(2), the Commission indicates that a renewal of a power reactor 

7 operating license requires preparation of an environmental impact statement (EIS) or a 

8 supplement to an existing EIS. In addition, 10 CFR 51.95(c) states that the Commission shall 

9 prepare an environmental impact statement, which is a supplement to the Commission’s 

10 NUREG–1437, "Generic Environmental Impact Statement (GEIS) for License Renewal of 

11 Nuclear Plants" (May 1996), (NRC, 1996). 

12 Upon acceptance of NPPD’s application, the NRC staff began the environmental review process 

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

14 conduct scoping. In preparation of this SEIS for CNS-1, the NRC staff performed the following: 

15 ● Conducted public scoping meetings on February 25, 2009, in Brownville 

16 and Auburn, NE 

17 ● Conducted a site audit at the plant in late March 2009 

18 ● Reviewed NPPD’s environmental report (ER) and compared it to the GEIS 

19 ● Consulted with other agencies 

20 ● Conducted a review of the issues following the guidance set forth in 

21 NUREG-1555, Standard Review Plans for Environmental Reviews for 

22 Nuclear Power Plants, Supplement 1: Operating License Renewal (NRC, 

23 2000) 

24 ● Considered public comments received during the scoping process. 

25 PROPOSED ACTION 

26 NPPD initiated the proposed Federal action—issuing a renewed power reactor operating 

27 license—by submitting an application for license renewal of CNS-1, for which the existing 

28 license DPR-46 will expire on January 18, 2014. The NRC’s Federal action is the decision 

29 whether or not to renew the license for an additional 20 years. 
Executive Summary 

Draft NUREG-1437, Supplement 41 xviii February 2010 

1 PURPOSE AND NEED FOR ACTION 

2 The purpose and need for the proposed action (issuance of a renewed license) is to provide an 

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

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

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

6 purpose and need for action reflects the recognition that, unless there are findings in the safety 

7 review required by the Atomic Energy Act of 1954 (AEA) or findings in the NEPA environmental 

8 analysis that would lead to the rejection of a license renewal application, the NRC does not 

9 have a role in the energy-planning decisions of State regulators and utility officials as to whether 

10 a particular nuclear power plant should continue to operate. 

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

12 expiration date of the current operating license, January 18, 2014. 

13 ENVIRONMENTAL IMPACTS OF LICENSE RENEWAL 

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

15 environmental impacts from the proposed action are designated as SMALL, MODERATE, or 

16 LARGE. As set forth in the GEIS, Category 1 issues are those that meet all of the following 

17 criteria: 

18 (1) The environmental impacts associated with the issue is determined to apply either to all 

19 plants or, for some issues, to plants having a specific type of cooling system or other 

20 specified plant or site characteristics. 

21 (2) A single significance level (i.e., SMALL, MODERATE, or LARGE) has been assigned to 

22 the impacts, except for collective offsite radiological impacts from the fuel cycle and from 

23 high-level waste and spent fuel disposal. 

24 (3) Mitigation of adverse impacts associated with the issue is considered in the analysis and 

25 it has been determined that additional plant-specific mitigation measures are likely not to 

26 be sufficiently beneficial to warrant implementation. 

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

28 new and significant information is identified. Chapter 4 of this report presents the process for 

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

30 not meet one or more of the criterion for Category 1 issues; therefore, an additional 

31 site-specific review for these nongeneric issues is required, and the results are documented in 

32 the SEIS. The NRC staff has reviewed NPPD’s established process for identifying and 

33 evaluating the significance of any new and significant information on the environmental impacts 

34 of license renewal of CNS-1. Neither NPPD nor NRC identified information that is both new and 

35 significant related to Category 1 issues that would call into question the conclusions in the 

36 GEIS. Similarly, neither the scoping process nor the NRC staff has identified any new issue 

37 applicable to CNS-1 that has a significant environmental impact. The NRC staff, therefore, relies 

38 upon the conclusions of the GEIS for all Category 1 issues applicable to CNS-1. 

39 LAND USE 

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

41 identify any new and significant information during the environmental review. Therefore, there 
Executive Summary 

February 2010 xix Draft NUREG-1437, Supplement 41 

1 would be no impacts beyond those discussed in the GEIS. As stated in the GEIS, the impacts 

2 associated with these Category 1 issues were determined to be SMALL, and plant-specific 

3 mitigation measures are not sufficiently beneficial to be warranted. 

4 AIR QUALITY 

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

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

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

8 GEIS. 

9 GROUND WATER USE AND QUALITY 

10 SMALL. The staff did not identify any new and significant information in regard to Category 1 or 

11 generic ground water issues. Ground water use conflicts: potable and service water—plants 

12 using greater than 100 gallons per minute (gpm) is a Category 2 issue related to license 

13 renewal at CNS-1. Because of the limited radius of influence of CNS-1 wells in the unconfined 

14 aquifer, no public ground water supplies are close enough to CNS-1 to be impacted by ground 

15 water use at the station. There are no well-head protection areas or Environmental Protection 

16 Agency (EPA) designated sole source aquifers in the vicinity of CNS-1. Therefore, the impact of 

17 ground water use by CNS-1 is SMALL. 

18 SURFACE WATER USE AND QUALITY 

19 SMALL. The staff did not identify any new information and issues during its review. Therefore, 

20 no Category 2 surface water issues were identified for the CNS-1 license renewal term. The 

21 surface water issues related to CNS-1 are Category 1. Therefore, no impacts are related to 

22 these issues beyond those discussed in the GEIS. For these issues, the NRC staff concludes in 

23 the GEIS that the impacts are SMALL. 

24 AQUATIC RESOURCES 

25 SMALL. With regard to operation of CNS-1 during the license renewal term, the NRC staff 

26 identified the following Category 2 issues for aquatic resources: entrainment and impingement 

27 of fish and shellfish, and heat shock. The NRC staff reviewed the available information and 

28 concludes that the weight of evidence indicates a SMALL level of impact on aquatic resources 

29 due to impingement and entrainment at CNS-1. NPPD has implemented some impingement 

30 mitigation measures and plans to implement others. After reviewing the available information, 

31 the NRC staff concludes that the level of thermal impact on the aquatic community by renewing 

32 CNS-1’s operating license is SMALL. 

33 In addition to the impact on aquatic resources due to entrainment and impingement of fish and 

34 shellfish and heat shock, the NRC staff reviewed field studies on the total impact of CNS-1’s 

35 cooling water system operation on aquatic resources. The NRC staff concludes that the level of 

36 impact on aquatic resources due to all aspects of CNS-1’s cooling system operation is SMALL. 

37 TERRESTRIAL RESOURCES 

38 SMALL. The NRC staff identified no Category 2 issues related to terrestrial resources for license 

39 renewal. The NRC staff did not identify any additional new and significant information during 

40 review of the NPPD’s ER, the site audit, the scoping process, or the evaluation of other 

41 available information. Therefore, the NRC staff concludes that there are no additional impacts 

42 related to these issues beyond those discussed in the GEIS. The GEIS further concludes that 
Executive Summary 

Draft NUREG-1437, Supplement 41 xx February 2010 

1 since the impacts are SMALL, additional site-specific mitigation measures are not likely to be 

2 sufficiently beneficial to implement. 

3 THREATENED AND ENDANGERED SPECIES 

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

5 includes one Category 2 issue, the conservation of pallid sturgeon. NPPD has been involved 

6 with several organizations in a conservation agreement regarding pallid sturgeon, which could 

7 have a positive impact on the pallid sturgeon population. Operation of the CNS-1 site and its 

8 associated transmission lines has not been known, nor is expected, to adversely affect any 

9 threatened or endangered species during the license renewal term. The NRC staff, therefore, 

10 concludes that adverse impacts to threatened or endangered species during the license renewal 

11 term would be SMALL. 

12 HUMAN HEALTH 

13 SMALL. The NRC staff’s review of the historical radioactive releases from CNS-1 and the 

14 resultant dose calculation demonstrate that CNS-1 is operating in compliance with Federal 

15 radiation protection standards. Continued compliance with regulatory requirements is expected 

16 during the license renewal term. Therefore, the impacts from radioactive effluents are not 

17 expected to change during the license renewal term. 

18 The NRC staff did not identify any new and significant information during its review. Therefore, 

19 there are no impacts related to these issues beyond those discussed in the GEIS. For these 

20 issues, the NRC’s conclusion in the GEIS was that the impacts are SMALL and additional site21 specific mitigation measures are not likely to be sufficiently beneficial to be warranted. 

22 Microbiological organisms (public health) and electromagnetic fields— acute effects (electric 

23 shock) are Category 2 human health issues. The NRC staff reviewed all documents applicable 

24 to the microbiological organisms issue and concludes that thermophilic microbiological 

25 organisms are not likely to present a public health hazard as a result of CNS-1 discharges to the 

26 Missouri River. The NRC staff concludes that impacts on public health from thermophilic 

27 microbiological organisms from continued operation of CNS-1 in the license renewal period are 

28 SMALL. 

29 The NRC staff has reviewed the available information, including the applicant’s evaluation and 

30 computational results. Based on this information, the NRC staff evaluated the potential impacts 

31 for electric shock resulting from operation of CNS-1 and its associated transmission lines. The 

32 staff concludes that the potential impacts from electric shock during the renewal period are 

33 SMALL. 

34 SOCIOECONOMICS 

35 SMALL. For Category 1 issues (public services and aesthetic impacts), the NRC staff identified 

36 no new and significant information during the environmental review. Therefore, there would be 

37 no impacts beyond those discussed in the GEIS. Category 2 socioeconomic impacts include 

38 housing impacts, public services (public utilities), offsite land use, public services (public 

39 transportation), and historic and archaeological resources. 

40 Since NPPD has no plans to add additional employees during the license renewal period except 

41 during outages, employment levels at CNS-1 would remain relatively constant with no additional 

42 demand for permanent housing during the license renewal term. Based on this information, 

43 there would be no impact on housing during the license renewal term beyond what has already 

44 been experienced. 
Executive Summary 

February 2010 xxi Draft NUREG-1437, Supplement 41 

1 For the same reason, demand for public water services will remain relatively unchanged with no 

2 additional demand. Public water systems in the region would be adequate to meet the demands 

3 of residential and industrial customers in the area. Therefore, there would be no additional 

4 impact to public water services during the license renewal term beyond what is currently being 

5 experienced. 

6 Since non-outage employment levels at CNS-1 would remain relatively constant during the 

7 license renewal period, there would be no land use impacts related to population or tax 

8 revenues, and no transportation impacts. Therefore, offsite land use and transportation issues 

9 would remain relatively unchanged. 

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

11 operation of CNS-1 during the license renewal term. The CNS-1 site is situated in an area 

12 where historic and archaeological resources could be located several feet beneath the ground 

13 surface. NPPD has instituted a stop work order within its Cultural Resource Protection Plan to 

14 ensure that proper notification is taken to protect these resources should they be discovered. 

15 Based on review of Nebraska State Historical Society (NSHS) files (archaeological surveys, 

16 assessments, and other information), the potential impacts of continued operations and 

17 maintenance on historic and archaeological resources at CNS-1 would be SMALL. 

18 In reviewing potential social environmental justice impacts(i.e., potential disproportionately high 

19 and adverse human health and environmental impacts on minority and low-income populations), 

20 an analysis of minority and low-income populations residing within a 50-mile (80-km) radius of 

21 CNS-1 indicated there would be no disproportionately high and adverse impacts to these 

22 populations from the continued operation of CNS-1 during the license renewal period. Based on 

23 recent monitoring results, concentrations of contaminants in native leafy vegetation, soils and 

24 sediments, surface water, and fish in areas surrounding CNS-1 have been low (at or near the 

25 threshold of detection) and seldom above background levels. Consequently, no 

26 disproportionately high and adverse human health impacts are expected in special pathway 

27 receptor populations in the region as a result of subsistence consumption of fish and wildlife. 

28 SEVERE ACCIDENT MITIGATION ALTERNATIVES 

29 Since CNS-1 had not previously considered alternatives to reduce the likelihood or potential 

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

31 regulation 10 CFR 51.53(c)(3)(ii)(L) requires that CNS-1 evaluate Severe Accident Mitigation 

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

33 reduce the risk or potential impacts of uncommon but potentially severe accidents, and may 

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

35 NRC staff reviewed the ER’s evaluation of potential SAMAs. Subsequent to the ER, a problem 

36 with the process used to numerically average the site-specific meteorological data was 

37 identified. NPPD performed a re-analysis of the population dose risk and offsite economic cost 

38 risk using corrected meteorological data, and found that the population dose and offsite 

39 economic cost values for each of the release categories would be slightly less than reported in 

40 the ER, and that the conclusions of the SAMA remain valid. 

41 NRC staff reviewed NPPD’s re-analysis and the methods used by NPPD as submitted by NPPD 

42 and agrees that the error was conservative relative to the average population dose and offsite 

43 economic cost and that no SAMAs were inappropriately excluded from consideration in the LRA 

44 as a result of the error. 
Executive Summary 

Draft NUREG-1437, Supplement 41 xxii February 2010 

1 Based on the staff’s review and the supplemental information provided by NPPD, the NRC staff 

2 concluded that none of the potentially cost-beneficial SAMAs relate to adequately managing the 

3 effects of aging during the period of extended operation. Therefore, they need not be 

4 implemented as part of the license renewal pursuant to 10 CFR Part 54. 

5 ALTERNATIVES 

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

7 renewal. These alternatives include other methods of power generation and not renewing the 

8 CNS-1 operating license (the no-action alternative). Replacement power options considered 

9 were supercritical coal-fired generation, natural gas combined-cycle generation, and a 

10 combination alternative that includes a portion of the combined-cycle gas-fired capacity, a 

11 conservation capacity component, and a wind power component. The NRC staff initially 

12 considered a number of additional alternatives for analysis as alternatives to license renewal of 

13 CNS-1; these were later dismissed due to technical, resource availability, or commercial 

14 limitations that currently exist and that the NRC staff believes are likely to continue to exist when 

15 the existing CNS-1 license expires. The no-action alternative by the NRC staff and the effects it 

16 would have were also considered. 

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

18 located both at the CNS-1 site and at some other unspecified alternate location. Energy 

19 conservation and energy efficiency; purchased power, and a combination alternative, which 

20 included natural gas combined-cycle generation, energy conservation and wind power were 

21 also considered. The NRC staff evaluated each alternative using the same impact areas that 

22 were used in evaluating impacts from license renewal. The results of this evaluation are 

23 summarized in the table on the following page. 

24 COMPARISON OF ALTERNATIVES 

25 The coal-fired alternative is the least environmentally favorable alternative, due to its impacts to 

26 air quality from nitrogen oxides (NOx), sulfur oxides (SOx), particulate matter (PM), polycyclic 

27 aromatic hydrocarbons (PAHs), carbon monoxide (CO), carbon dioxide (CO2), and mercury—

28 and the corresponding human health impacts; construction impacts to aquatic, terrestrial, and 

29 potentially historic and archaeological resources are also factors that make the coal-fired 

30 alternative the least environmentally favorable alternative. 

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

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

33 plant. Purchased power would likely have operational impacts that would include aspects of 

34 coal-fired, gas-fired, and existing nuclear generation. 

35 All other alternatives capable of meeting the energy needs currently served by CNS-1 entail 

36 potentially greater impacts than the proposed action of license renewal of CNS-1. The no-action 

37 alternative does not meet the needs currently served by CNS-1. However, if the no-action 

38 alternative was selected and this was to trigger the energy conservation and energy efficiency 

39 action to replace the capacity currently supplied by CNS-1, it could result in an overall SMALL 

40 impact. 
Executive Summary 

February 2010 xxiii Draft NUREG-1437, Supplement 41 

1 Summary of Environmental Impacts of Proposed Action and Alternatives. 

Impact Area 

Alternative 

Air Quality 

Ground Water 

Surface Water 

Aquatic and Terrestrial 

Resources 

Human Health 

Socioeconomics 

Waste Management 

License renewal SMALL SMALL SMALL SMALL SMALL SMALL SMALL 

Supercritical coalfired alternative at the 

CNS-1 site 

MODERATE SMALL SMALL SMALL to 

MODERATE SMALL 

SMALL to 

LARGE MODERATE 

Gas-fired alternative 

at the CNS-1 site 

SMALL TO 

MODERATE SMALL SMALL SMALL to 

MODERATE SMALL 

SMALL to 

MODERATE SMALL 

Combination of 

alternatives 

SMALL TO 

MODERATE SMALL SMALL SMALL to LARGE 

SMALL to 

MODERATE 

SMALL to 

MODERATE SMALL 

No-action alternative SMALL SMALL SMALL SMALL SMALL 

SMALL to 

MODERATE SMALL 

2 RECOMMENDATION 

3 Our preliminary recommendation is that the Commission determines that the adverse 

4 environmental impacts of license renewal for CNS-1 are not so great that preserving the option 

5 of license renewal for energy planning decision makers would be unreasonable. This 

6 recommendation is based on: 

7 (1) the analysis and findings in the GEIS 

8 (2) information submitted in the NPPD’s ER 

9 (3) consultation with other Federal, State, and local agencies 

10 (4) review of other pertinent studies and reports 

11 (5) consideration of public comments received during the scoping process. 

February 2010 xxv Draft NUREG-1437, Supplement 41 

1 ABBREVIATIONS AND ACRONYMS 

2 AADT average annual daily traffic 

3 ACC averted cleanup and decontamination costs 

4 ADV atmospheric dump valve 

5 AEA Atomic Energy Act of 1954 

6 AEC U.S. Atomic Energy Commission 

7 AEO Annual Energy Outlook 

8 ALARA as low as reasonably achievable 

9 AMSL above mean sea level 

10 APE area of potential effect 

11 

12 BA biological assessment 

13 BACT best available control technology 

14 Btu/kWh British thermal units/kilowatt hours 

15 BWR boiling water reactor 

16 BWST borated water storage tank 

17 

18 CAA Clean Air Act 

19 CAFTA cutest and fault tree analysis 

20 CAMR Clean Air Mercury Rule 

21 CDC Center for Disease Control 

22 CDF core damage frequency 

23 CDM Clean Development Mechanism 

24 CENRAP Central Regional Air Planning Association 

25 CEQ Council on Environmental Quality 

26 CESQG Conditionally Exempt Small Quantity Generator 

27 CET containment event tree 

28 CFR Code of Federal Regulations

29 cfs cubic feet per second 

30 CH4 methane 

31 CNS-1 Cooper Nuclear Station, Unit 1 

32 CO carbon monoxide 

33 CO2 carbon dioxide 

34 CRA Conestoga Rover Associates 
Abbreviations and Acronyms 

Draft NUREG-1437, Supplement 41 xxvi February 2010 

1 CRT cathode ray tube 

2 CWA Clean Water Act 

3 CWERCLA Comprehensive Environmental Response, Compensation, and 

4 Liability 

5 

6 DBA design-basis accident 

7 DDE insecticide, dichlorodiphenyldichloroethylene 

8 DDT insecticide, dichlorodiphenyltrichloroethane 

9 DHCCW decay heat closed cooling water 

10 DHHS Department of Health and Human Services 

11 DHR decay heat removal 

12 DHRW decay heat river water system

13 DNR Department of Natural Resources 

14 DOE Department of Energy 

15 DOT Department of Transportation 

16 DPR demonstration power reactor 

17 DPS Department of Public Safety 

18 DSEIS draft supplemental environmental impact statement 

19 DSM demand-side management 

20 

21 EDG emergency diesel generator 

22 EFW emergency feedwater 

23 EIA Energy Information Administration 

24 EIS environmental impact statement 

25 ELF-EMF extremely low frequency-electromagnetic field 

26 EMF electromagnetic fields 

27 EMS environmental management system 

28 E.O. Executive Order 

29 ER environmental report 

30 EPA Environmental Protection Agency 

31 EPCRA Emergency Planning and Community Right-to-Know Act 

32 EPRI Electric Power Research Institute 

33 EPZ emergency planning zone 

34 ESA Endangered Species Act 

35 ESAS engineered safeguards actuation signal 
Abbreviations and Acronyms 

February 2010 xxvii Draft NUREG-1437, Supplement 41 

1 ESRP Environmental Standard Review Plan 

2 

3 F&O fact and observation 

4 FCS Fort Calhoun Station 

5 FES final environmental statement 

6 FIVE fire-induced vulnerability evaluation 

7 FR Federal Register

8 FSAR final safety analysis report 

9 

10 g Ceq/kWh grams of CO2 equivalents per kilowatt-hour 

11 GEIS generic environmental impact statement 

12 GHG greenhouse gas 

13 gpm gallons per minute 

14 

15 HAP hazardous air pollutant 

16 HCLPF high confidence in low probability of failure 

17 HFC hydrofluorocarbons 

18 HFE hydrofluorinated ethers 

19 HID high intensity discharge (light) 

20 HLW high-level waste 

21 HPI high-pressure injection 

22 HRA human reliability analysis 

23 

24 ICCW immediate closed cooling water 

25 IEEE Institute of Electrical and Electronics Engineers 

26 IGCC integrated gasification combined-cycle 

27 Inc. incorporated 

28 IPCC Intergovernmental Panel on Climate Change 

29 IPE individual plant examination 

30 IPEEE individual plant examination of external events 

31 ISFSI independent spent fuel storage installation 

32 ISLOCA interfacing-systems loss-of-coolant accident 

33 

34 J joule 

35 JHEP joint human error probability 
Abbreviations and Acronyms 

Draft NUREG-1437, Supplement 41 xxviii February 2010 

1 

2 LERF large early release frequency 

3 LLC limited liability corporation 

4 LLMW low level mixed waste 

5 LLNL Lawrence Livermore National Laboratory 

6 LLW low-level radioactive waste 

7 LOCA loss of coolant accident 

8 LOOP loss of offsite power 

9 LPI low pressure injection 

10 LQG Large Quantity Generator 

11 

12 MAAP modular accident analysis program 

13 MACCS2 MELCOR Accident Consequence Code System 2 

14 MCR main control room 

15 MDC Missouri Department of Conservation 

16 MDNR Missouri Department of Natural Resources 

17 MOV motor operated valve 

18 mrad milliradiation absorbed dose 

19 mrem milliroentgen equivalent man (mrem) 

20 MSA Magnuson-Stevens Fishery Conservation and Management Act of 

21 1996 

22 msl mean sea level 

23 MT metric tonnes 

24 MW megawatt 

25 MWd/MTU megawatt-days per metric ton uranium 

26 MWe megawatt-electric 

27 MWt megawatt-thermal 

28 

29 N2O nitrous oxide 

30 NA not applicable 

31 NAAQS National Ambient Air Quality Standards 

32 NAC Nebraska Administrative Code 

33 NAQR Nebraska Air Quality Regulations 

34 NAS National Academy of Sciences 

35 NCDC National Climatic Data Center 
Abbreviations and Acronyms 

February 2010 xxix Draft NUREG-1437, Supplement 41 

1 NDED Nebraska Department of Education 

2 NDEQ Nebraska Department of Environmental Quality 

3 NDOR Nebraska Department of Roads 

4 NDNR Nebraska Department of Natural Resources 

5 NEPA National Environmental Policy Act of 1969 

6 NESC National Electric Safety Code 

7 NF3 nitrogen triflouride 

8 ng nanograms 

9 NGPC Nebraska Game and Parks Commission 

10 NHHS Nebraska Department of Health and Human Services 

11 NHPA National Historic Preservation Act 

12 NIEHS National Institute of Environmental Health Sciences 

13 NMFS National Marine Fisheries Service 

14 NNRD Nemaha Natural Resources District 

15 NOAA National Oceanic and Atmospheric Administration 

16 NO2 nitrogen dioxide 

17 NOx nitrogen oxide(s) 

18 NPDES National Pollutant Discharge Elimination System 

19 NPPD Nebraska Public Power District 

20 NRC U.S. Nuclear Regulatory Commission 

21 NRCC National Research Council 

22 NRHP National Register of Historic Places 

23 NSCCW nuclear service closed cooling water 

24 NSHS Nebraska State Historical Society 

25 NSR New Source Review 

26 NWPCC Nebraska Water Pollution Control Council 

27 NWS National Weather Service 

28 

29 ODAM Offsite Dose Assessment Manual 

30 ODCM Offsite Dose Calculation Manual 

31 ODNR Ohio Department of Natural Resources 

32 OMB Office of Management and Budget 

33 OPPD Omaha Public Power District 

34 

35 PAH polycyclic aromatic hydrocarbon 
Abbreviations and Acronyms 

Draft NUREG-1437, Supplement 41 xxx February 2010 

1 PCB polychlorinated biphenyl 

2 pCi/L picocuries per liter 

3 PDS plant damage state 

4 PFC perfluorocarbons 

5 PILOT payments in lieu of taxes 

6 PM particulate matter 

7 PM2.5 particulate matter, 2.5 microns or less in diameter 

8 PM10 particulate matter, 10 microns or less in diameter 

9 PMF probably maximum flood 

10 PRA probabilistic risk assessment 

11 PWR pressurized water reactor 

12 

13 RAI request for additional information 

14 RBEC reactor building emergency cooling 

15 RBWMD Rainwater Basin Wetland Management District 

16 RCP reactor coolant pump 

17 RCRA Resource Conservation and Recovery Act 

18 RCS reactor coolant system 

19 REMP radiological environmental monitoring program 

20 RKm river kilometer 

21 RM river mile 

22 rms root mean square 

23 ROI region of influence 

24 ROW(s) right-of-way(s) 

25 RPMA recovery priority management area 

26 RPO regional planning organization 

27 RPV reactor pressure vessel 

28 RRW risk reduction worth 

29 RWD Rural Water District 

30 

31 SAMA Severe Accident Mitigation Alternative 

32 SAR safety analysis report 

33 SBO station blackout 

34 SC species of concern 

35 SCDHEC South Carolina Department of Health and Environmental Control 
Abbreviations and Acronyms 

February 2010 xxxi Draft NUREG-1437, Supplement 41 

1 SCR selective catalytic reduction 

2 SEIS supplemental environmental impact statement 

3 SER safety evaluation report 

4 SF6 sulfur hexafluoride 

5 SGTR steam generator tube rupture 

6 SHPO State Historic Preservation Office 

7 SO2 sulfur dioxide 

8 SO3 sulfur trioxide 

9 SOx sulfur oxide(s) 

10 SPDES State Pollutant Discharge Elimination System 

11 SQG Small Quantity Generator 

12 Sv sievert 

13 

14 TDEC Tennessee Department of Environment and Conservation 

15 TSP total suspended particles 

16 TSS total suspended solids 

17 

18 U Uranium 

19 UDEQ Utah Department of Environmental Quality 

20 UNL University of Nebraska-Lincoln 

21 U.S. United States 

22 USFWS U.S. Fish and Wildlife Service 

23 USACE United States Army Corps of Engineers 

24 U.S.C. United States Code

25 USCB U.S. Census Bureau 

26 USDA U.S. Department of Agriculture 

27 USGCRP United States Global Change Research Program 

28 USGS U.S. Geological Survey 

29 USI unresolved safety issue 

30 

31 VOC volatile organic compound 

32 

33 WGA Western Governors Association 

34 WHO World Health Organization

February 2010 1-1 Draft NUREG-1437, Supplement 41 

1 1.0 PURPOSE AND NEED FOR ACTION 

2 Issuance of a renewal of a nuclear power plant operating license requires the preparation of a 

3 supplemental environmental impact statement (SEIS) under the U.S. Nuclear Regulatory 

4 Commission’s (NRC’s) environmental protection regulations in Title 10, Part 51, “Environmental 

5 Protection Regulations for Domestic Licensing and Related Regulatory Functions,” of the Code 

6 of Federal Regulations (10 CFR Part 51.20). 

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

8 reactors be granted for up to 40 years, but permitted license renewal. The 40-year licensing 

9 period was based on economic and antitrust considerations rather than on technical limitations 

10 of the nuclear facility. 

11 The decision to seek a license renewal rests with the nuclear power facility owners and typically 

12 is based on the facility’s economic viability and the investment necessary to continue to meet 

13 NRC safety and environmental requirements. The NRC grants or denies a license renewal 

14 application based on whether or not the applicant demonstrates that agency regulations for 

15 environmental and safety requirements can be met during the period of extended operation. 

16 1.1 PROPOSED FEDERAL ACTION 

17 Nebraska Public Power District (NPPD) initiated the proposed Federal action by submitting an 

18 application for license renewal of the Cooper Nuclear Station, Unit 1 (CNS-1), for which the 

19 existing license, DPR-46, expires January 18, 2014. The NRC’s Federal action is the proposed 

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

21 1.2 PURPOSE AND NEED FOR THE PROPOSED FEDERAL ACTION 

22 The purpose and need for the proposed Federal action (i.e., the issuance of a renewed license) 

23 is to provide an option that allows for power generation capability, beyond the term of a current 

24 nuclear power plant operating license, to meet future system generating needs, as such needs 

25 may be determined by State, utility, and, where authorized, Federal decisionmakers (other than 

26 NRC). This definition of purpose and need for the proposed Federal action reflects the NRC's 

27 recognition that, unless there are findings in the safety review required by the AEA or findings in 

28 the National Environmental Policy Act (NEPA) environmental analysis that would lead the NRC 

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

30 regulators and utility officials as to whether or not a particular nuclear power plant should 

31 continue to operate. 

32 If the NRC renews the operating license, State regulatory agencies and NPPD decide whether 

33 or not the plant will continue to operate based on factors such as the need for power within the 

34 State’s jurisdiction or the purview of the owners. If the NRC does not renew CNS-1's DPR-46 

35 operating license, the facility must be shut down on or before the expiration date of the current 

36 operating license, January 18, 2014. 
Purpose and Need for Action 

Draft NUREG-1437, Supplement 41 1-2 February 2010 

1 1.3 MAJOR ENVIRONMENTAL REVIEW MILESTONES 

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

3 opportunities for public involvement. 

4 
Purpose and Need for Action 

February 2010 1-3 Draft NUREG-1437, Supplement 41 

1 NPPD submitted an environmental report (ER) as part of its license renewal application (NPPD, 

2 2008a) in September 2008. After reviewing the application and the ER for sufficiency, the NRC 

3 staff published a Notice of Acceptability and Opportunity for Hearing on December 30, 2008, in 

4 the Federal Register (73 FR 79921). On January 26, 2009, the NRC published another notice in 

5 the Federal Register (74 FR 4476) on its intent to conduct scoping, thereby beginning the 60-

6 day scoping period. 

7 The agency held two public scoping meetings on February 25, 2009, in Brownville, Nebraska, 

8 and Auburn, Nebraska. The NRC report entitled “Environmental Impact Statement Scoping 

9 Process Summary Report for Cooper Nuclear Station, Unit 1,” dated May 29, 2009, presents the 

10 comments received during the scoping process in their entirety (NRC, 2009a). Appendix A to 

11 this SEIS presents the comments considered to be within the scope of the environmental 

12 license renewal review and the associated NRC responses. 

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

14 CNS-1 from March 30 through April 3, 2009. During the site audit, staff met with plant 

15 personnel, reviewed specific documentation, toured the facility, and met with interested Federal, 

16 State, and local agencies. The agency published a summary of that site audit and a list of the 

17 attendees in a report entitled, “Summary of Site Audit Related to the Review of the License 

18 Renewal Application for Cooper Nuclear Station, Unit 1,” dated April 30, 2009 (NRC, 2009b). 

19 Figure 1-1 shows the major milestones in the public review of the EIS. Upon completion of the 

20 scoping period and site audit, the staff compiled its findings in this draft SEIS, which is being 

21 made available for public comment for 75 days. During this comment period, NRC staff will host 

22 public meetings and collect public comments. Based on the information gathered, the staff will 

23 amend the draft SEIS findings as necessary, and publish a final SEIS. 

24 The NRC has established a license renewal process that can be completed in a reasonable 

25 period of time with clear requirements to ensure safe plant operations for up to an additional 20 

26 years of plant life. The safety review is conducted simultaneously with the environmental review. 

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

28 Commission considers the findings in both the SEIS and the SER in its decision to either grant 

29 or deny the issuance of a new license. 

30 1.4 GENERIC ENVIRONMENTAL IMPACT STATEMENT 

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

32 license renewal to improve the efficiency of the license renewal. NUREG-1437, Generic 

Environmental Impact Statement (GEIS) for License Renewal of Nuclear Power Plants,1 33 

34 documents the results of the NRC staff’s systematic approach to evaluating the environmental 

35 consequences of renewing licenses of individual nuclear power plants and operating them for 

36 an additional 20 years (NRC 1996, 1999). The NRC staff analyzed and dispositioned those 

37 environmental issues that could be dispositioned generically in the GEIS. 

38 The GEIS includes a determination of whether or not the analysis of the environmental issue 

39 could be applied to all plants and if additional mitigation measures are warranted (Figure 1-2). 

 

1

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

Volume 1 and 2, May 1996, Washington, D.C. 
Purpose and Need for Action 

Draft NUREG-1437, Supplement 41 1-4 February 2010 

1 Issues are assigned a designation: a Category 1 (generic to all plants) or a Category 2 (not 

2 generic to all plants). As set forth in the GEIS, Category 1 issues are those that meet all of the 

3 following criteria: 

4 (1) The environmental impacts associated with the issue is determined to apply either to all 

5 plants or, for some issues, to plants having a specific type of cooling system or other 

6 specified plant or site characteristics. 

7 (2) A single significance level (i.e., SMALL, MODERATE, or LARGE) has been assigned to 

8 the impacts, except for collective offsite radiological impacts from the fuel cycle and from 

9 high-level waste and spent fuel disposal. 

10 (3) Mitigation of adverse impacts associated with the issue is considered in the analysis and 

11 it has been determined that additional plant-specific mitigation measures are likely not to 

12 be sufficiently beneficial to warrant implementation. 

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

14 new and significant information is identified. Chapter 4 of this report presents the process for 

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

16 not meet one or more of the criterion for Category 1 issues; therefore, an additional 

17 site-specific review for these nongeneric issues is required, and the results are documented in 

18 the SEIS. 

19 The GEIS establishes 92 issues for the NRC staff to independently verify. Of these 92, the staff 

20 determined that 69 are Category 1, while 21 issues do not lend themselves to generic 

21 consideration (Category 2). Two other issues remained uncategorized and must be evaluated 

22 on a site-specific basis: environmental justice and the chronic effects of electromagnetic fields. 

23 Refer to Appendix B of this draft SEIS for a list of all 92 issues. 

24 For each potential environmental issue, the GEIS 

25 (1) describes the activity that affects the 

26 environment, (2) identifies the population or 

27 resource that is affected, (3) assesses the nature 

28 and magnitude of the impact on the affected 

29 population or resource, (4) characterizes the 

30 significance of the effect for both beneficial and 

31 adverse effects, (5) determines whether or not the 

32 results of the analysis apply to all plants, and (6) 

33 considers whether or not additional mitigation 

34 measures are warranted for impacts that would 

35 have the same significance level for all plants. 

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

37 Environmental Quality (CEQ) terminology for “significant.” The NRC established three levels of 

38 significance for potential impacts—SMALL, MODERATE, and LARGE, as defined below: 

39 SMALL – Environmental effects are not detectable or are so minor that they will neither 

40 destabilize nor noticeably alter any important attribute of the resource. 

41 MODERATE – Environmental effects are sufficient to alter noticeably, but not to destabilize, 

42 important attributes of the resource. 

Significance indicates the importance 

of likely environmental impacts and is 

determined by considering two 

variables: context and intensity. 

Context is the geographic, biophysical, 

and social context in which the effects 

will occur. 

Intensity refers to the severity of the 

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

February 2010 1-5 Draft NUREG-1437, Supplement 41 

1 LARGE – Environmental effects are clearly noticeable and are sufficient to destabilize important 

2 attributes of the resource. 

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

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

5 

6 1.5 SUPPLEMENTAL ENVIRONMENTAL IMPACT STATEMENT 

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

8 operation of CNS-1, alternatives to license renewal, and mitigation measures for minimizing 

9 adverse environmental impacts. Chapters 5, 6, and 7 analyze the environmental impact of 

10 postulated accidents, the uranium fuel cycle and greenhouse gas emissions, and 

11 decommissioning, respectively. Chapter 8 analyzes and compares the potential environmental 

12 impacts from alternatives, and Chapter 9 presents the preliminary recommendation to the 

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

14 preserving the option of license renewal would be unreasonable. The recommendation will be 

15 made after consideration of the draft SEIS. 
Purpose and Need for Action 

Draft NUREG-1437, Supplement 41 1-6 February 2010 

1 In preparation of this draft SEIS for CNS-1, the staff undertook the following activities: 

2 ● reviewed information provided in the NPPD ER 

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

4 ● conducted an independent review of the issues during site audit 

5 ● considered public comments received during the scoping process 

6 New information can be identified from a 

7 number of sources, including the applicant, 

8 the NRC, other agencies, or public 

9 comments. If a new issue is revealed, then 

10 it is first analyzed to determine whether it is 

11 within the scope of the license renewal 

12 evaluation. If the issue is not addressed in 

13 the GEIS, then the NRC determines its 

14 significance and documents its analysis in 

15 the SEIS. 

16 1.6 COOPERATING AGENCIES 

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

18 agencies in the preparation of this SEIS. 

19 1.7 CONSULTATIONS 

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

21 Conservation and Management Act of 1996, as amended; and the National Historic 

22 Preservation Act of 1966, require that Federal agencies consult with applicable State and 

23 Federal agencies and groups before taking action that may affect endangered species, 

24 fisheries, or historic and archaeological resources, respectively. Below are the agencies and 

25 groups with whom the NRC consulted; Appendix D to this report includes copies of consultation 

26 documents. 

27 Advisory Council on Historic Preservation 

28 Department of Health and Human Services 

29 Iowa Tribe of Kansas and Nebraska 

30 Iowa Tribe of Oklahoma 

31 Kickapoo Tribe in Kansas 

32 Nebraska Game and Parks Commission 

33 Nebraska Department of Natural Resources 

34 Nebraska State Historic Society 

35 Missouri State Historic Society 

36 Omaha Tribe of Nebraska 

New and significant information either: 

(1) identifies a significant environmental issue 

not covered in the GEIS, or (2) was not 

considered in the analysis in the GEIS and 

leads to an impact finding that is different from 

the finding presented in the GEIS. 
Purpose and Need for Action 

February 2010 1-7 Draft NUREG-1437, Supplement 41 

1 Otoe-Missouria Tribe of Indians 

2 Prairie Band of Potawatomi Indians 

3 Sac and Fox Nation of Missouri 

4 Sac and Fox Tribe of the Mississippi in Iowa 

5 Sac and Fox Nation of Oklahoma 

6 U.S. Army Corps of Engineers 

7 U.S. Fish and Wildlife Service, Grand Island, NE Field Office 

8 1.8 CORRESPONDENCE 

9 During the course of the environmental review, the NRC staff contacted the following Federal, 

10 State, regional, local, and tribal agencies. Appendix E to this report contains a chronological list 

11 of all documents sent and received during the environmental review. 

12 Advisory Council on Historic Preservation 

13 Department of Health and Human Services 

14 Iowa Tribe of Kansas and Nebraska 

15 Iowa Tribe of Oklahoma 

16 Kickapoo Tribe in Kansas 

17 Nebraska Game and Parks Commission 

18 Nebraska Department of Health and Human Services 

19 Nebraska Department of Natural Resources 

20 Nebraska State Historic Preservation Office 

21 Missouri State Historic Preservation Office 

22 Omaha Tribe of Nebraska 

23 Otoe-Missouria Tribe of Indians 

24 Prairie Band of Potawatomi Indians 

25 Sac and Fox Nation of Missouri 

26 Sac and Fox Tribe of the Mississippi in Iowa 

27 Sac and Fox Nation of Oklahoma 

28 U.S. Army Corps of Engineers 

29 U.S. Environmental Protection Agency, Kansas City, KS Field Office 

30 U.S. Fish and Wildlife Service, Grand Island, NE Field Office 
Purpose and Need for Action 

Draft NUREG-1437, Supplement 41 1-8 February 2010 

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

Mr. Ronald D. Asche 

President and Chief Executive 

Officer 

Nebraska Public Power District 

1414 15th Street 

Columbus, NE 68601 

Mr. Gene Mace 

Nuclear Asset Manager 

Nebraska Public Power District 

P.O. Box 98 

Brownville, NE 68321 

Mr. John C. McClure 

Vice President and General Counsel 

Nebraska Public Power District 

P.O. Box 499 

Columbus, NE 68602-0499 

Mr. David Van Der Kamp 

Licensing Manager 

Nebraska Public Power District 

P.O. Box 98 

Brownville, NE 68321 

Mr. Michael J. Linder, Director 

Nebraska Department of 

Environmental 

Quality 

P.O. Box 98922 

Lincoln, NE 68509-8922 

Chairman 

Nemaha County Board of 

Commissioners 

Nemaha County Courthouse 

1824 N Street 

Auburn, NE 68305 

Mr. Stewart B. Minahan 

Vice President 

Nuclear and Chief Nuclear Officer 

Cooper Nuclear Station 

72676 – 648A Avenue 

Brownville, NE 68321 

Ms. Julia Schmitt, Manager 

Radiation Control Program 

Nebraska Health & Human Services 

R&L 

Public Health Assurance 

301 Centennial Mall, South 

P.O. Box 95007 

Lincoln, NE 68509-5007 

Deputy Director for Policy 

Missouri Department of Natural 

Resources 

P.O. Box 176 

Jefferson City, MO 65102-0176 

Senior Resident Inspector 

U.S. Nuclear Regulatory 

Commission 

P.O. Box 218 

Brownville, NE 68321 

Regional Administrator, Region IV 

U.S. Nuclear Regulatory 

Commission 

612 E. Lamar Blvd, Suite 400 

Arlington, TX 76011-4125 

Director, Missouri State Emergency 

Management Agency 

P.O. Box 116 

Jefferson City, MO 65102-0116 

Chief, Radiation and Asbestos 

Control Section 

Kansas Department of Health 

and Environment 

Bureau of Air and Radiation 

1000 SW Jackson, Suite 310 

Topeka, KS 66612-1366 

Ms. Melanie Rasmussen 

Radiation Control Program Director 

Bureau of Radiological Health 

Iowa Department of Public Health 

Lucas State Office Building, 5th Floor 

321 East 12th Street 

Des Moines, IA 50319 

Mr. Keith G. Henke, Planner 

Division of Community and Public 

Health 

Office of Emergency Coordination 

930 Wildwood Drive 

P.O. Box 570 

Jefferson City, MO 65102 

Mr. Art Zaremba, Director of Nuclear 

Safety Assurance 

Nebraska Public Power District 

P.O. Box 98 

Brownville, NE 68321 

Mr. John F. McCann, Director 

Licensing, Entergy Nuclear 

Northeast 

Entergy Nuclear Operations, Inc. 

440 Hamilton Avenue 

White Plains, NY 10601-1813 

Mr. Mike Boyce 

Cooper Strategic Initiatives Manager 

Cooper Nuclear Station 

72676 – 648A Avenue 

Brownville, NE 68321 

Mr. Garry Young 

License Renewal Manager 

Entergy Nuclear 

1448 S.R. 333, N-GSB-45 

Russellville, AR 72802 

Mr. Alan Cox 

License Renewal Technical Manager 

Entergy Nuclear 

1448 S.R. 333, N-GSB-45 

Russellville, AR 72802 

Mr. Dave Lach 

LRP Entergy Project Manager 

Entergy Nuclear 

1448 S.R. 333, N-GSB-45 

Russellville, AR 72802 

Mr. Jerry Perry 

500 S. Main Street 

Rock Port, MO 64482 

Ms. Yolanda Peck 

1008 Central Avenue 

Auburn, NE 68305 

Ms. Kendall Neiman 

830 Central Avenue 

Auburn, NE 68305 

Ms. Annie Thomas 

1522 I Street 

Auburn, NE 8305 

Mr. John Chaney 

1101 17th Street 

Auburn, NE 68305 

Mr. Darrell Kruse 

2415 McConnell Avenue 

Auburn, NE 68305 
Purpose and Need for Action 

February 2010 1-9 Draft NUREG-1437, Supplement 41 

Ms. Daryl J. Obermeyer 

64381 727A Road 

Brownville, NE 68321 

Ms. Sherry Black, Director 

Auburn Memorial Library 

1810 Courthouse Avenue 

Auburn, NE 68305 

Board of Brownville, NE 

Attn: Chairman Marty Hayes 

P.O. Box 67 

223 Main Street 

Brownville, NE 68321 

Mr. Bob Engles 

Mayor of Auburn, NE 

1101 J Street 

Auburn, NE 68305 

Ms. Jo Stevens 

Mayor of Rock Port, MO 

500 S. Main Street 

Rock Port, MO 64482 

Mr. John Cochnar 

U.S. Fish and Wildlife Service 

Ecological Services 

Nebraska Field Office 

203 West Second Street 

Grand Island, NE 68801 

Mr. John Askew 

Regional Administrator 

U.S. EPA Region 7 

901 N. 5th Street 

Kansas City, KS 66101 

Ms. Joann Scheafer, Director 

Nebraska Department of Health & 

Human Services 

301 Centennial Mall South 

Lincoln, NE 68509 

Mr. Doyle Childers, Director 

Missouri Department of Natural 

Resources 

P.O. Box 176 

Jefferson City, MO 65102 

Mr. Mark Miles 

State Historic Preservation Officer 

Department of Natural Resources 

P.O. Box 176 

Jefferson City, MO 65102 

Mr. Michael J. Smith 

State Historic Preservation Officer 

Nebraska State Historical Society 

P.O. Box 82554 

Lincoln, NE 68501 

Mr. Robert Puschendorf 

Nebraska State Historical Society 

1500 R Street 

P.O. Box 82554 

Lincoln, NE 68501-2554 

Mr. Seth Greenburg 

Environment, Planning, and 

Infrastructure 

Research Assistant 

ICF International 

9300 Lee Highway 

Fairfax, VA 22031 

Mr. Matthew Leaf 

KTNC/KLZA Radio 

1602 Stone St 

Falls City, NE 68335 

Mr. Daryl J. Obermeyer 

ADC 

64381 727A Road 

Brownville, NE 68321 

Mr. Ron Asche 

NPPD 

1414 15th St. 

Columbus, NC 68601 

Ms. Carla Mason 

ADC 

820 Central Avenue 

Auburn, NE 68305 

Mr. Jim Thomas 

Enercon 

5100 E. Skelton Street, 450 

Tulsa, OK 74135 

1 1.9 STATUS OF COMPLIANCE 

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

3 and local requirements. Appendix H to the GEIS describes some of the major Federal statutes. 

4 Table 1-1 on the following page lists the numerous permits and licenses issued by Federal, 

5 State, and local authorities for activities at CNS-1. 
Purpose and Need for Action 

Draft NUREG-1437, Supplement 41 1-10 February 2010 

1 Table 1-1. Licenses and Permits. Existing environmental authorizations for CNS-1 operations. 

Permit Number Dates Responsible Agency 

Operating License DPR-46 Issued: 1/18/1974 

Expires: 1/18/2014 NRC 

National Pollutant 

Discharge Elimination 

System (NPDES) Permit 

NE0001244 Expires: 6/30/2012 Nebraska Department of 

Environmental Quality 

(NDEQ) 

General NPDES Permit NER000059 Expires: 9/17/2012 NDEQ 

Permit to Construct an Air 

Contaminant Source 

Not Applicable (NA) NA NDEQ 

Hazardous Waste 

Generator Identification NED1055071064-2 NA NDEQ 

Class V Well Underground 

Injection NE0208256 Expires: 11/16/2010 NDEQ 

Well Registration G-030088 NA 

Nebraska Department of 

Natural Resources 

(NDNR) 

Well Registration G-030089 NA NDNR 

Well Registration G-040718 NA NDNR 

Well Registration G-100339 NA NDNR 

Well Registration G-100340 NA NDNR 

Well Registration G-149001A NA NDNR 

Well Registration G-149001B NA NDNR 

Well Registration G-149001C NA NDNR 

Well Registration G-149001D NA NDNR 

Well Registration G-149001E NA NDNR 

Well Registration G-149001F NA NDNR 

Well Registration G-149001G NA NDNR 

Well Registration G-149001H NA NDNR 

Well Registration G-149001I NA NDNR 

Well Registration G-149001J NA NDNR 

Well Registration G-149001K NA NDNR 

Water withdrawal permit D-1071 NA NDNR 

Class III Public Water 

Supply System Permit NE3150505 NA 

Nebraska Health and 

Human Services (NHHS) 

System 

401 Certification NA NA Nebraska Water Pollution 

Control Council (NWPCC) 

CNS-1 Radioactive Waste 

Transport Permit 

0218-26-08-X 12/31/2008 South Carolina 

Department of Health and 

Environmental Control 

(SCDHEC) 
Purpose and Need for Action 

February 2010 1-11 Draft NUREG-1437, Supplement 41 

Permit Number Dates Responsible Agency 

CNS-1 Radioactive Waste 

License for Delivery 

T-NE002-L08 12/31/2008 Tennessee Department of 

Environment and 

Conservation (TDEC), 

Division of Radiological 

Health 

Generator Site Access 

Permit 

0111000042 1/3/2009 Utah Department of 

Environmental Quality 

(UDEQ), Division of 

Radiological Health 

1 1.10 REFERENCES 

2 10 CFR Part 51. Code of Federal Regulations, Title 10, Energy, Part 51, “Environmental 

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

4 Atomic Energy Act of 1954 (AEA). 42 U.S.C. 2011, et seq. 

5 Endangered Species Act of 1973 (ESA). 16 U.S.C. 1531, et seq. 

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

7 Sustainable Fisheries Act of 1996. 16 U.S.C. 1855, et seq. 

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

9 National Historic Preservation Act (NHPA). 16 U.S.C. 470, et seq. 

10 Nebraska Public Power District (NPPD). 2008. License Renewal Application, Cooper Nuclear 

11 Station, “Appendix E, Applicant’s Environmental Report, Operating License Renewal Stage.” 

12 ADAMS Accession No. ML083030246. 

13 Nebraska Public Power District (NPPD). 2008a. Cooper Nuclear Station, License Renewal 

14 Application. ADAMS Accession No. ML083030227. 

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

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

17 ADAMS Accession Nos. ML040690705 and ML040690738. 

18 U.S. Nuclear Regulatory Commission (NRC). 1999. Generic Environmental Impact Statement 

19 for License Renewal of Nuclear Plants, Main Report, “Section 6.3 – Transportation, Table 9.1, 

20 Summary of findings on NEPA issues for license renewal of nuclear power plants, Final Report.” 

21 NUREG-1437, Volume 1, Addendum 1, Washington, D.C. ADAMS Accession No. 

22 ML0400690720. 

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

24 Scoping Process, Summary Report, Cooper Nuclear Station, Unit 1.” Brownville, Nebraska. 

25 ADAMS Accession No. ML091200017. 

26 U.S. Nuclear Regulatory Commission (NRC). 2009b. “Summary of Site Audit Related to the 

27 Review of the License Renewal Application for Cooper Nuclear Station, Unit 1 (TAC NOS. 

28 MD9763 and MD9737).” ADAMS Accession No. ML090970414. 

February 2010 2-1 Draft NUREG-1437, Supplement 41 

1 2.0 AFFECTED ENVIRONMENT 

2 Cooper Nuclear Station, Unit 1 (CNS-1) is located in Nemaha County, Nebraska, 2.25 miles 

3 southeast of Brownville, Nebraska, approximately 60 miles southeast of Lincoln, Nebraska and 

4 65 miles south of Omaha, Nebraska. CNS-1 is bounded on the east by the Missouri River and 

5 by non-Nebraska Public Power District (NPPD) owned property on the north, south, and west. 

6 Figure 2.1-1 shows a map of a 50-mile radius around CNS-1. Figure 2.2-2 shows the area 

7 within a six-mile radius of CNS-1. The site is owned and operated by NPPD. The site structures 

8 for CNS-1 span approximately 55 acres of the site’s total area of approximately 1,359 acres, 

9 including 239 acres on the opposite bank (east) of the Missouri River in Atchison County, 

10 Missouri. Over 99 percent of the acreage in Nemaha County is used for agriculture and farming. 

11 A significant portion of NPPD property at CNS-1, 234 acres in Missouri and 715 acres in 

12 Nebraska, is currently leased for agricultural activities such as farming and raising livestock. 

13 2.1 FACILITY DESCRIPTION 

14 The principal structures at CNS-1 consist of the reactor building, turbine building (including 

15 service area appendages), control building, controlled corridor, radwaste building, augmented 

16 radwaste building, intake structure, off-gas filter building, elevated release point, diesel 

17 generator building, multi-purpose facility, railroad airlock, drywell and suppression chamber, 

18 miscellaneous circulating water system structures (e.g., circulating water conduits, seal well), 

19 optimum water chemistry gas generator building, and office building. Predominant features are 

20 the 290-foot tall reactor building, the 325-foot tall elevated release point, and the 328.8-foot tall 

21 meteorological tower. 

22 The reactor and nuclear steam supply systems for the site, along with the mechanical and 

23 electrical systems required for the safe operation of CNS-1, are primarily located in the 

24 containment structure. These vital components of the station are located in a protected area that 

25 is completely enclosed by a security fence, with access to the station controlled at a security 

26 gate. A plant security system monitors the protected area, as well as the buildings within the 

27 station. Normal access to the site is by a paved entrance road built across the site from Nemaha 

28 County Road 648A Avenue, located on the west side of the property. No residences are 

29 permitted within the CNS-1 exclusion area boundary. 

30 2.1.1 Reactor and Containment Systems 

31 CNS-1 is a single-unit boiling-water reactor (BWR) plant with a nuclear steam supply system 

32 supplied by General Electric Company and a turbine generator set supplied by Westinghouse 

33 Electric Corporation. CNS-1 achieved commercial operation in 1974 with an initial licensed core 

34 thermal power of 2,381 megawatt-thermal (MWt). In 2008, with U.S Nuclear Regulatory 

35 Commission (NRC) approval, the applicant performed a measurement uncertainty recapture 

36 uprate that increased the core thermal power by 1.62 percent to its current level of 2,419 MWt 

37 and 830 megawatt-electric (Mwe) (NPPD, 2008). Figure 2.1-3 shows the general layout of the 

38 buildings at CNS-1. 
Affected Environment 

Draft NUREG-1437, Supplement 41 2-2 February 2010 

1 

2 Figure 2.1-1. Location of Cooper Nuclear Station, Unit 1, 50-mile (80-kilometer) Region 

3 (Source: NPPD, 2008) 
Affected Environment 

February 2010 2-3 Draft NUREG-1437, Supplement 41 

1 

2 Figure 2.1-2. Location of Cooper Nuclear Station, Unit 1, 6-mile (10-kilometer) Region 

3 (Source: NPPD, 2008) 
Affected Environment 

Draft NUREG-1437, Supplement 41 2-4 February 2010 

1 

2 Figure 2.1-3. Cooper Nuclear Station, Unit 1, General Site Layout (Source: NPPD, 2008)

3 The reactor fuel is low-enriched high density ceramic uranium dioxide fuel pellets stacked within 

4 a Zircaloy-2 cladding tube, which is evacuated, back-filled with helium, and sealed by welding 

5 Zircaloy plugs in each end. NPPD currently operates CNS-1 with an individual rod average 

6 burnup of not more than 62,000 megawatt-days per metric ton uranium (MWd/MTU) (NPPD, 

7 2008). 

8 The CNS-1 containment system utilizes a multibarrier concept consisting of two systems, a 

9 primary containment, which is a pressure suppression system, and a secondary containment, 

10 which minimizes the release of radioactive materials. 
Affected Environment 

February 2010 2-5 Draft NUREG-1437, Supplement 41 

1 The primary containment houses the reactor pressure vessel, the reactor coolant recirculation 

2 system, and other branch connections of the reactor coolant system. Primary containment is a 

3 pressure suppression system consisting of a drywell, a suppression chamber which stores a 

4 large volume of water, a connecting vent system between the drywell and suppression pool, 

5 isolation valves, portions of the emergency core cooling system, and other service equipment. 

6 The drywell is a steel pressure vessel in the shape of an inverted light bulb, and the suppression 

7 chamber is a torus-shaped steel pressure vessel, often referred to as the torus, located below 

8 and encircling the drywell. 

9 Secondary containment encloses the primary containment system, refueling and reactor 

10 servicing areas, new and spent fuel storage facilities, and other reactor auxiliary systems. 

11 Secondary containment serves as the primary containment, when required, during reactor 

12 refueling and maintenance operations, when primary containment is inoperable and as an 

13 additional barrier when primary containment is operable (NPPD, 2008). 

14 2.1.2 Radioactive Waste Management 

15 The radioactive waste system for CNS-1 collects, treats, and disposes of radioactive and 

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

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

18 (principally metallic corrosion products) and fission products resulting from defective fuel 

19 cladding or uranium contamination within the reactor coolant system. Operating procedures for 

20 the radioactive waste system ensure that radioactive wastes are safely processed and 

21 discharged from the plant within the limits set forth in Title 10 of the Code of Federal 

22 Regulations (CFR) Part 20, “Standards for Protection against Radiation,” 10 CFR Part 50, 

23 “Domestic Licensing of Production and Utilization Facilities,” the plant’s technical specifications, 

24 and the CNS-1 offsite dose assessment manual (ODAM) (NPPD, 2008). 

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

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

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

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

29 from reactor and turbine equipment containing radioactive material. Radioactive solid wastes 

30 are solids from the reactor coolant system, solids that come into contact with reactor coolant 

31 system liquids or gases, or solids used in the reactor coolant system or steam and power 

32 conversion system operation or maintenance (NPPD, 2008). 

33 Reactor fuel that has exhausted a certain percentage of its fissile uranium content is referred to 

34 as spent fuel. Spent fuel assemblies are removed from the reactor core and replaced with fresh 

35 fuel assemblies during routine refueling outages. Spent fuel assemblies are stored in the spent 

36 fuel pool in the reactor building. In addition to the spent fuel pool, spent nuclear fuel is expected 

37 to be stored in dry casks during the license renewal term. 

38 The CNS-1 ODAM contains the methodology and parameters used to calculate offsite doses 

39 resulting from radioactive gaseous and liquid effluents, and the gaseous and liquid effluent 

40 monitoring alarm and trip setpoints used to verify that the radioactive material being discharged 

41 meets regulatory limits. The ODAM also contains the radioactive effluent controls and 

42 radiological environmental monitoring activities and descriptions of the information that is 

43 included in the annual radiological environmental operating report and annual radioactive 

44 effluent release report (NPPD, 2008). 
Affected Environment 

Draft NUREG-1437, Supplement 41 2-6 February 2010 

1 2.1.2.1 Radioactive Liquid Waste 

2 The CNS-1 liquid waste disposal system collects, holds, treats, processes, and monitors all 

3 liquid radioactive wastes for reuse or disposal. The function of the radioactive waste system is 

4 to reclaim the liquid phase of the wet solid wastes for reuse within the station and to prepare the 

5 solid waste for offsite shipment while minimizing radiation exposure to the workers. Prior to 

6 offsite shipment to a licensed burial ground, solid wastes may be stored on site in shielded 

7 areas. The solid waste processing systems are located in the radioactive waste building and 

8 augmented radioactive waste building. Liquid radioactive waste is collected in sumps and 

9 drainage tanks and transferred to the appropriate subsystem collection tanks for treatment, 

10 disposal, or recycle. The waste processing selectively removes the radioactive material from the 

11 liquid. The processing methods used include filtration and/or demineralization. The system can 

12 also handle effluent streams that typically do not contain radioactive material, but may on 

13 occasion, be radioactive. The applicant limits, to the extent possible, the amount of liquid 

14 radioactive wastes discharged to the Missouri River. For example, there were no liquid 

15 radioactive discharges from CNS-1 into the Missouri River in 2007. Liquid discharges are made 

16 only after the radioactive material has been analyzed and the projected dose to members of the 

17 public has been calculated to be within the values specified in the ODAM, 10 CFR Part 20; and 

18 Appendix I to 10 CFR Part 50 (NPPD, 2008). 

19 The NRC staff reviewed the CNS-1 radioactive effluent release reports for 2003 through 2007 

20 for liquid effluents (NPPD 2004, 2005, 2006, 2007, 2008b). Based on the liquid waste 

21 processing system’s performance from 2003 through 2007, the liquid discharges for 2007 are 

22 consistent with the radioactive liquid effluents discharged from 2003 through 2006. Variations on 

23 the amount of radioactive effluents released from year to year are expected, based on the 

24 overall performance of the plant and the number and scope of outages and maintenance 

25 activities. The radioactive liquid wastes reported by CNS-1 are reasonable and no unusual 

26 trends were noted. 

27 2.1.2.2 Radioactive Gaseous Waste 

28 The CNS-1 gaseous waste disposal system processes and disposes of radioactive gaseous 

29 effluent to the atmosphere. The off-gas system (non-augmented) includes subsystems that 

30 process and dispose of the gases from the main condenser air ejectors, the startup mechanical 

31 vacuum pumps, and the gland steam condensers. The processed gases are routed to the 

32 elevated release point for dilution and release to the atmosphere. Radiation monitors monitor 

33 the gaseous discharges (NPPD, 2008). 

34 CNS-1 discharges gaseous waste in accordance with the procedures and methodology 

35 described in the ODAM. The radioactive gaseous waste system is used to reduce radioactive 

36 materials in gaseous effluents before discharge to meet the dose limits in 10 CFR Part 20 and 

37 the dose design objectives in Appendix I to 10 CFR Part 50. 

38 The NRC staff reviewed the CNS-1 radioactive effluent release reports for 2003 through 2007 

39 for gaseous effluents (NPPD 2004, 2005, 2006, 2007, 2008b). Based on the gaseous waste 

40 processing system’s performance from 2003 through 2007, the gaseous discharges for 2007 

41 are consistent with the effluents discharged from 2003 through 2006. Variations on the amount 

42 of radioactive effluents released from year to year are expected, based on the overall 

43 performance of the plant and the number and scope of outages and maintenance activities. The 

44 radioactive gaseous wastes reported by CNS-1 are reasonable and no unusual trends were 

45 noted. 
Affected Environment 

February 2010 2-7 Draft NUREG-1437, Supplement 41 

1 2.1.2.3 Radioactive Solid Waste 

2 The CNS-1 radioactive solid waste disposal system collects, stores, and processes wet and dry 

3 solid waste for packaging and shipment offsite. The system consists of a wet process, which 

4 collects, processes, dewaters, and solidifies wet solid wastes, and a dry process, which collects 

5 and packages dry solid wastes. Wet solid wastes include spent resins, filter cartridges, and filter 

6 crud. Dry solid wastes include contaminated rags, clothing, paper, outage equipment, and other 

7 radioactively contaminated equipment. CNS-1 uses a combination of onsite processing and an 

8 offsite vendor to process radioactive wastes for disposal. Transportation of the radioactive solid 

9 waste is conducted in accordance with NRC and U.S. Department of Transportation (DOT) 

10 regulations as specified in 10 CFR Part 61, “Licensing Requirements for Land Disposal of 

11 Radioactive Wastes,” and 10 CFR Part 71, “Packaging and Transportation of Radioactive 

12 Material” (NPPD, 2008). 

13 The State of South Carolina’s licensed low-level radioactive waste (LLW) disposal facility, 

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

15 that are not part of the Atlantic Low-Level Waste Compact. Nebraska is not a member of the 

16 Atlantic Low-Level Waste Compact. This has had a minimal affect on CNS-1’s ability to dispose 

17 of its solid LLW. It uses the licensed LLW disposal site operated by Envirocare in Clive, Utah for 

18 its Class A waste. The applicant has onsite storage capacity to store its Class B and C 

19 radioactive waste during the license renewal term. 

20 In 2007, preparation work began for the construction of an independent spent fuel storage 

21 installation (ISFSI) located on the north end of the CNS-1 site in an area that was previously 

22 disturbed. The ISFSI will provide storage space for spent fuel storage casks. The ISFSI, in 

23 combination with the existing spent fuel pool, will store spent fuel assemblies generated during 

24 the license renewal term. Operation of the ISFSI will be in accordance with NRC regulations to 

25 ensure the spent fuel is stored safely and that worker and public radiation exposures are 

26 controlled in accordance with the dose limits specified in 10 CFR Part 20, as well as the 

27 Environmental Protection Agency’s (EPA) radiation standards in 40 CFR Part 190, 

28 “Environmental Radiation Protection Standards for Nuclear Power Operations” (NPPD, 2008). 

29 The NRC staff reviewed the CNS-1 LLW reports for 2003 through 2007 (NPPD 2004, 2005, 

30 2006, 2007, 2008b). The solid waste volumes and radioactivity amounts generated in 2007 are 

31 typical of previous annual waste shipments made by CNS-1. Variations in the amount of solid 

32 radioactive waste generated and shipped from year to year are expected, based on the overall 

33 performance of the plant and the number and scope of outages and maintenance activities. The 

34 volume and activity of solid radioactive wastes reported by CNS-1 are reasonable and no 

35 unusual trends were noted. 

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

37 operation of CNS-1 through the license renewal term. Routine plant operational and 

38 maintenance activities currently performed will continue during the license renewal term. Based 

39 on the past performance of the radioactive waste system, and the lack of any planned 

40 refurbishment activities, similar amounts of radioactive solid waste are expected to be 

41 generated during the license renewal term. 
Affected Environment 

Draft NUREG-1437, Supplement 41 2-8 February 2010 

1 2.1.3 Nonradiological Waste Management 

2 CNS-1 generates nonradioactive wastes as part of routine plant maintenance, cleaning 

3 activities, and plant operations. Resource Conservation and Recovery Act (RCRA) governs the 

4 disposal of solid and hazardous waste. RCRA regulations are contained in Title 40, “Protection 

5 of the Environment,” Parts 239 through 299 (40 CFR 239, et seq.), of the CFR. Parts 239 

6 through 259 of Title 40 contain regulations for solid (nonhazardous) waste, and Parts 260 

7 through 279 contains regulations for hazardous waste. RCRA Subtitle C establishes a system 

8 for controlling hazardous waste from “cradle to grave,” and RCRA Subtitle D encourages States 

9 to develop comprehensive plans to manage nonhazardous solid waste and mandates minimum 

10 technological standards for municipal solid waste landfills. Nebraska State RCRA regulations 

11 are administered by the Nebraska Department of Environmental Quality (NDEQ) and address 

12 the identification, generation, minimization, transportation, and final treatment, storage, or 

13 disposal of hazardous and nonhazardous waste. 

14 2.1.3.1 Nonradioactive Waste Steams 

15 CNS-1 generates solid waste, defined by RCRA, as part of routine plant maintenance, cleaning 

16 activities, and plant operations. Nebraska is a part of EPA Region 7 and its Solid Waste 

17 program. In 1985, the EPA authorized NDEQ to administer portions of the RCRA program in the 

18 State of Nebraska that are incorporated in Title 128 (Nebraska Hazardous Waste Regulations) 

19 of Nebraska Administrative Code (NAC). NAC Title 128 was updated in 2004 to keep current 

20 with Federal RCRA regulations. 

21 The EPA classifies certain nonradioactive wastes as hazardous based on characteristics 

22 including ignitability, corrosivity, reactivity, or toxicity (identification and listing of hazardous 

23 waste is available in 40 CFR Part 261). State-level regulators may add wastes to the EPA’s list 

24 of hazardous wastes. RCRA provides standards for the treatment, storage, and disposal of 

25 hazardous waste for hazardous waste generators (regulations are available in 40 CFR Part 

26 262). 

27 The EPA recognizes three main types of the hazardous waste generators (40 CFR 260.10) 

28 based on the quantity of the hazardous waste produced: Large Quantity Generators (LQGs), 

29 that generate 2,200 pounds (1,000 kg) per month or more of hazardous waste, more than 

30 2.2 pounds (1 kg) per month of acutely hazardous waste, or more than 220 pounds (100 kg) per 

31 month of acute spill residue or soil; Small Quantity Generators (SQGs) that generate more than 

32 220 pounds (100 kg), but less than 2,200 pounds (1,000 kg) of hazardous waste per month; 

33 and, Conditionally Exempt Small Quantity Generators (CESQGs) that generate 220 pounds 

34 (100 kg) or less per month of hazardous waste, or 2.2 pounds (1 kg) or less per month of 

35 acutely hazardous waste, or less than 220 pounds (100 kg) per month of acute spill residue or 

36 soil. State of Nebraska has incorporated the EPA’s regulations regarding hazardous wastes and 

37 recognizes CNS-1 as a conditionally exempt small quantity generator of hazardous wastes 

38 under Title 128, Chapter 8 of NDEQ Administrative Code. CNS-1 generates small amounts of 

39 hazardous wastes including spent and expired chemicals, laboratory chemical wastes, and 

40 occasional project-specific wastes. As reported in the NPPD environmental report (ER), CNS-1 

41 produced no hazardous waste in 2003, 1,112 pounds (504 kg) in 2004, 4,285 pounds (1,944 kg) 

42 in 2005, 5,317 pounds (2,412 kg) in 2006, and 308 pounds (140 kg) in 2007 (NPPD, 2008). The 

43 increase in quantity of the hazardous waste produced by CNS-1 in 2005–2006 was due to large 

44 volumes of paint used during outages, as was confirmed by the NRC staff during the site audit. 

45 Used oil, produced during operation of CNS-1, is sent offsite to the EPA-approved hazardous 

46 waste disposal facility (NPPD, 2009c). 
Affected Environment 

February 2010 2-9 Draft NUREG-1437, Supplement 41 

1 The EPA classifies several hazardous wastes as universal wastes; these include batteries, 

2 pesticides, mercury-containing items, and fluorescent lamps. NDEQ has incorporated the EPA’s 

3 regulations (40 CFR Part 273) regarding universal wastes in Chapter 25 of Title 128 of the NAC. 

4 NDEQ defines used batteries, pesticides, mercury-containing items, spent non-TCLP 

5 fluorescent and HID lamps, cathode ray tubes (CRTs) and electronics as universal waste and 

6 such wastes make up the majority of the hazardous wastes produced by CNS-1. The NPPD ER 

7 reports that in 2007 CNS-1 produced 20,860 pounds (9,462 kg) of electronic waste, 6,190 

8 pounds (2,808 kg) of lamps and 25,200 pounds (11,431 kg) of batteries (NPPD, 2008). 

9 CNS-1 does not routinely chlorinate circulating water systems; however the periodic use of 

10 chlorine/bromine in the circulating water system and cooling water system is allowed in CNS-1 

11 National Pollutant Discharge Elimination System (NPDES) permit No. NE0001244 (NPPD, 

12 2008). Radioactive liquid waste is addressed in Section 2.1.2. Section 2.1.7.3 provides more 

13 information on CNS-1 NPDES permit and permitted discharges. 

14 The Emergency Planning and Community Right-to-Know Act (EPCRA) requires applicable 

15 facilities to provide information on hazardous and toxic chemicals to local emergency planning 

16 authorities and the EPA (Title 42, Section 11001, of the United States Code (42 USC 11001)). 

17 On October 17, 2008, the EPA finalized several changes to the Emergency Planning (Section 

18 302), Emergency Release Notification (Section 304) and Hazardous Chemical Reporting 

19 (Sections 311 and 312) regulations that were proposed on June 8, 1998 (63 FR 31268). CNS-1 

20 is subject to Federal EPCRA reporting requirements, and thus submits an annual Section 312 

21 (Tier II) report on hazardous substances to local emergency agencies. 

22 Low-level mixed wastes (LLMW) are wastes that contain both LLW and RCRA hazardous waste 

23 (40 CFR 266.210). The EPA (or any authorized State agency) regulates the hazardous 

24 component of the mixed waste through RCRA, and the NRC regulates radioactive waste subject 

25 to the Atomic Energy Act (AEA). CNS-1, as a conditionally exempt small quantity generator 

26 under RCRA Subtitle C, periodically produces small amounts of LLMW, mainly from the use of 

27 liquid cleaners, and sends it offsite for disposal to an approved disposal facility. 

28 2.1.3.2 Pollution Prevention and Waste Minimization 

29 NPPD established company-wide recycle programs at its major and minor facilities, with a 

30 growing Green Team, that focuses on pollution prevention, waste minimization, and education 

31 of personnel. CNS-1 implements this program and participates in Green Team activities. NPPD 

32 compiles an annual recycling report that summarizes recycling efforts at various locations 

33 including CNS-1. As a result of the CNS-1 recycling efforts 51.2 tons (46 metric tonnes (MT) of 

34 the office paper, 6,800 pounds (3.1 MT) of batteries, 8,500 pounds (3.9 MT) of electronic waste 

35 and 2,675 pounds (1.2 MT) of fluorescent lamps were recycled in 2008 as stated in Nebraska 

36 Public Power District 2008 Recycling Report (NPPD, 2008). 

37 In support of nonradiological waste minimization efforts, the EPA’s Office of Prevention and 

38 Toxics has established a clearinghouse that provides information regarding waste management 

39 and technical and operational approaches to pollution prevention (EPA, 2009a). The EPA’s 

40 clearinghouse can be used as a source for additional opportunities for waste minimization and 

41 pollution prevention at CNS-1, as appropriate. 
Affected Environment 

Draft NUREG-1437, Supplement 41 2-10 February 2010 

1 The EPA also encourages the use of Environmental Management Systems (EMSs) for 

2 organizations to assess and manage the environmental impact associated with their activities, 

3 products, and services in an efficient and cost-effective manner. The EPA defines an EMS as “a 

4 set of processes and practices that enable an organization to reduce its environmental impacts 

5 and increase its operating efficiency.” EMSs help organizations fully integrate a wide range of 

6 environmental initiatives, establish environmental goals, and create a continuous monitoring 

7 process to help meet those goals. The EPA Office of Solid Waste especially advocates the use 

8 of EMSs at RCRA-regulated facilities to improve environmental performance, compliance, and 

9 pollution prevention (EPA, 2009). 

10 2.1.4 Plant Operation and Maintenance 

11 Maintenance activities conducted at CNS-1 include inspection, testing, and surveillance to 

12 maintain the current licensing basis of the facility and to ensure compliance with environmental 

13 and safety requirements. Various programs and activities currently exist at CNS-1 to maintain, 

14 inspect, test, and monitor the performance of facility equipment. These maintenance activities 

15 include inspection requirements for reactor vessel materials, boiler and pressure vessel in16 service inspection and testing, maintenance structures monitoring program, and maintenance of 

17 water chemistry. 

18 Additional programs include those implemented to meet technical specification surveillance 

19 requirements, those implemented in response to the NRC generic communications, and various 

20 periodic maintenance, testing, and inspection procedures. Certain program activities are 

21 performed during the operation of the unit, while others are performed during scheduled 

22 refueling outages. Nuclear power plants must periodically discontinue the production of 

23 electricity for refueling, periodic in-service inspection, and scheduled maintenance. CNS-1 

24 refuels on an 18-month interval. 

25 2.1.5 Power Transmission System 

26 The NPPD notes in their ER that four transmission lines, owned and operated by NPPD, are 

27 considered in scope for license renewal. Three of these four lines are numbered and connect 

28 CNS-1 to the regional grid via 345-kilovolt (kV) transmission lines, and total approximately 

29 148 miles (238 km). Two of these numbered lines, NPPD TL301 and NPPD TL3502, form a 

30 transmission line corridor extending 145 miles (233 km) west-northwest from CNS-1 in Nemaha 

31 County and ending within 4 miles (6 km) east of Grand Island in Merrick County. Line NPPD 

32 TL3501 originates at CNS-1 and extends approximately 64 miles (103 km) west-northwest to 

33 the Mark T. Moore substation, located 1.5 miles (2.4 km) north of Hallam, Nebraska. Line NPPD 

34 TL3502 extends approximately 83 miles (134 km) west-northwest from the Moore substation 

35 and ends east of Grand Island, crossing the Platte River within one mile of the Grand Island 

36 substation (Figure 2.1.5-1). This transmission line right-of-way (ROW) originating from the CNS37 1 switchyard spans Nemaha County, Johnson County, Gage County, Lancaster County, Saline 

38 County, Fillmore County, York County, Hamilton County, and Merrick County, Nebraska. Line 

39 NPPD TL3504 originates at CNS-1 and extends 0.6 miles (1 km) east from the plant and 

40 midway to the Missouri River, where it connects with a transmission line owned by Mid-America 

41 Energy that is not considered in scope. A fourth unnumbered transmission line in the scope of 

42 license renewal connects from the plant to the switchyard and is also considered in scope 

43 (NPPD, 2008). 
Affected Environment 

February 2010 2-11 Draft NUREG-1437, Supplement 41 

1 There are several additional transmission lines originating at the CNS-1 switchyard that are 

2 neither owned nor operated by CNS-1. Two transmission lines originating at the CNS-1 

3 switchyard are owned by Omaha Public Power District (OPPD), and a third is owned by Aquila. 

4 As these three transmission lines are not owned or under the control of NPPD, they are not 

5 within the scope of license renewal for CNS-1 (NPPD, 2008). 

6 The transmission lines do not cross any Federal, State, or local parks (NPPD, 2008). However, 

7 the western half of the transmission line corridor traverses counties that are part of the U.S. Fish 

8 and Wildlife Service’s (USFWS) Rainwater Basin Wetland Management District (RBWMD). The 

9 RBWMB contains 61 tracts of wetlands comprising over 21,000 acres scattered over 14 

10 counties in southeastern Nebraska, and are managed to provide resting stops for millions of 

11 migratory birds (USFWS, 2009h). 

12 Farming occurs virtually unimpeded under the majority of the transmission lines, and only the 

13 footprints of the poles are not used for crops (NPPD, 2008). On the CNS-1 property the 

14 agricultural land is managed by a single farmer under an agreement with NPPD. According to 

15 staff of NPPD, approximately 70 percent of the transmission line corridor beyond the CNS-1 site 

16 traverses cropland, and NPPD has easements with the individual property owners to perform 

17 maintenance activities along the corridor. Where the remaining 30 percent of the transmission 

18 line corridor crosses forested areas, including wetlands and streams, NPPD has vegetative 

19 maintenance procedures in place to prevent vegetation from interfering with the lines (NPPD, 

20 2006b). 

21 NPPD utilizes an integrated management approach to maintain vegetation along the 

22 transmission line ROW that includes both mechanical and chemical control methods. 

23 Mechanical control methods in the non-cultivated areas include clearing only woody plants with 

24 growth habits that may interfere with the transmission lines or the removal of tall trees that may 

25 fall onto the transmission line tower poles. Chemical treatment is used to control brush and re26 growth of stumps following mechanical cutting (NPPD, 2006b). Native grasses and low-lying 

27 woody plants are allowed to grow below the power lines within the forested ROWs (NPPD, 

28 2008). All tree trimming performed by NPPD follows ANSI guidelines for maintaining safe 

29 clearance and operation of the electrical systems. Chemical control methods adhere to the 

30 State of Nebraska, Department of Agriculture guidelines for application of restricted-use 

31 herbicides. All personnel involved with herbicide applications are trained and certified on the 

32 application of restricted-use herbicides by the State of Nebraska or a reciprocating State. For 

33 mechanical vegetation management in wetlands or along the shoreline of the Missouri River, 

34 NPPD contacts the U.S. Army Corps of Engineers (USACE) to determine if there is a need to 

35 obtain a Section 404 permit (NPPD, 2006b). NPPD staff has indicated that no chemical 

36 treatment of vegetation is performed in wetlands. Chapter 3 of the NPPD Corporate 

37 Environmental Manual (NPPD, 2007b) includes provisions for NPPD personnel and 

38 vendors/contractors to follow for any land disturbance activities, including work performed in 

39 wetlands or along riverbanks. 
Affected Environment 

Draft NUREG-1437, Supplement 41 2-12 February 2010 

1 ROW aerial inspections occur bi-monthly, and there is an annual foot patrol inspection; 

2 additional patrols are conducted following severe storms. Maintenance activities are performed 

3 in compliance with the Endangered Species Act (ESA), the Bald and Golden Eagle Protection 

4 Act, and the Migratory Bird Treaty Act. Birds that are nesting are protected except for nests of 

5 pigeons, house sparrows, and starlings (NPPD, 2006b). 

6 Figure 2.1.5-1. Cooper Nuclear Station, Unit 1 Transmission Line Corridor 

7 (Modified from NPPD, 2008 CNS-1 ER.) 

8 2.1.6 Cooling and Auxiliary Water Systems 

9 CNS-1 lies on the western shore of the Missouri River, withdraws river water for its once10 through cooling system, and discharges heated water back to the river. Unless otherwise cited, 

11 NRC staff drew information about CNS-1’s cooling and auxiliary water systems from NPPD 

12 (2006c) and the applicant’s ER. In the vicinity of the plant, the Missouri River has a regulated 

minimum flow of 31,000 cubic feet per second (cfs) (878 cubic meters per second (m3 13 /sec)) to 

14 the southeast. The circulating water intake structure is located on the western shore of the river 

15 behind a guide wall and submerged weir meant to reduce the amount of suspended sediment in 

16 the cooling water. The weir attaches to shoreline structures north of the intake and then runs 

17 parallel to the face of the intake at a distance of 14.25 feet (4.3 m). The wall continues past the 

18 intake and ends 40 feet (12 m) downstream of the downstream corner of the intake structure. In 

19 a line riverward of the weir wall and extending downstream of it, 23 sheet pile vanes (10 ft wide 

20 by 6 ft high, 3 m wide by 2 m high) oriented at a 22 degree angle to the weir redirect sand and 

21 gravel outward from the weir and the intake structure. After flowing generally south along the 

Grand 

Island 

In scope 

transmission line 

NPPD TL3502 

In scope transmission line 

NPPD TL3501 

ÅCNS 
Affected Environment 

February 2010 2-13 Draft NUREG-1437, Supplement 41 

1 weir and vanes, river water must reverse course and turn northwest to move between the weir 

2 and shore and reach the intake bays. Water velocity between the weir wall and the cooling 

3 water intake structure is about 4 ft/sec (1.2 m/sec). 

4 In winter, about 25 to 30 percent of main condenser discharge water recirculates through an ice 

5 control tunnel at the front of the intake structure and discharges in front of the trash rack to 

6 prevent icing. Water flows beneath a curtain wall at about 1.1 ft/sec (0.3 m/sec). Water enters 

7 the five intake bays, four of which provide circulating water and are 22 feet (6.7 m) wide and one 

8 of which provides service water and is 22.5 feet (6.8 m) wide. The incoming water then flows 

9 through trash racks, 3/8 inch (1.0 cm) vertical bars separated 3 inches (7.6 cm) on center, at up 

10 to 0.7 ft/sec (20 cm/sec). 

11 The circulating water intake bays each separate into two screen bays and the service water 

12 intake bay narrows before water encounters the traveling screens, which are oriented at right 

13 angles to the flow. Water filters twice through nine 1/8 by 1⁄2-in. (.3 cm by 1.3 cm) smooth-top 

14 mesh modified dual-flow traveling screens (eight for circulating water and one for service water). 

15 The upward pass is in the front and the downward pass is behind the screens, that rotate 

16 continuously at 8.2 ft/min (2.5 m/min). The intake water velocity at the screens is about 2 ft/sec 

17 (0.6 m/sec). 

18 After the 4.2-ft (1.28-m) wide traveling screen panels rotate over the upper cog and begin 

19 moving down, a high pressure (30–60 psig, 200–400 kPa) screen wash of 3000 gallons per 

minute (gpm) (0.19 m3 20 /sec) supplied by the service water pumps removes fish and debris, which 

21 return together to the river through an 18-in (0.46-m) diameter steel pipe that discharges 

22 downstream from the intake. Although the screens are fitted with fish baskets, the system has 

23 neither a low-pressure spray system to more gently remove fish from the screens nor a fish 

24 return trough to convey fish and other aquatic organisms back to the river separately from 

potentially damaging debris. Debris loads are about 10 cubic yards per month (8 m3 25 /month). 

26 CNS-1 plans to install “dual-flow conversion screen fish handling systems” during its current 

27 operational term. This system will have low pressure (5 to 10 psi, 35-70 kPa) fish washing 

28 sprays on both the ascending and descending screens and a fish return trough that is separate 

29 from the debris trough. A recovery basket will collect fish and other aquatic organisms washed 

30 from the screens, and the fish trough will return them to the river. Figure 2.1.6-1, Figure 2.1.6-2, 

31 and Figure 2.1.6-3 show the CNS-1 intake structures. 
Affected Environment 

Draft NUREG-1437, Supplement 41 2-14 February 2010 

1 

2 Figure 2.1.6-1. Cooper Nuclear Station, Unit 1, Intake Structure Plan 

3 (Source: NPPD, 2008)
Affected Environment 

February 2010 2-15 Draft NUREG-1437, Supplement 41 

1 

2 Figure 2.1.6-2. Cooper Nuclear Station, Unit 1, Intake Structure Section 

3 (Source: NPPD, 2008) 
Affected Environment 

Draft NUREG-1437, Supplement 41 2-16 February 2010 

1 

2 Figure 2.1.6-3. Cooper Nuclear Station, Unit 1, Typical Dual Flow Screen 

3 (Source: NPPD, 2008) 
Affected Environment 

February 2010 2-17 Draft NUREG-1437, Supplement 41 

1 After water passes through the traveling screens, the two screen bays of each intake bay rejoin 

2 behind the screens. The four circulating water pumps, one per bay, draw water from the bays 

and provide up to 159,000 gpm (10 m3 3 /sec) each. The four service water pumps in the fifth bay 

provide a combined flow of 32,000 gpm (2 m3 4 /sec). Water from the circulating water pumps 

5 travels to and circulates through the condenser, where it cools steam from the turbines. 

6 Because of the scouring from the suspended sediment, CNS-1 typically does not need to 

7 chlorinate the circulating water to control biological film fouling, although it has the capacity to 

8 chlorinate or brominate if needed. NPPD is studying the effectiveness of these options. 

9 Water temperature increases about 17.8°F (10°C) as it passes through the condenser tubes. 

10 From the condenser, circulating cooling water flows through concrete tunnels to a seal well 

11 structure and then to the discharge canal, where it travels about 1,000 feet (300 m) to discharge 

12 to the river at a slight angle. Water velocity at the discharge is about 1 ft/sec (0.3 m/sec) at 

13 average river flow and about 5.6 ft/sec (1.7 m/sec) during low flows. The travel time from the 

14 intake structure to the discharge is about 20 minutes at high river flow and 10 to 12 minutes at 

15 low flow. 

16 Cooling water flow varies with electrical load and ambient river water temperature. At full load 

17 during summer, the expected circulating water system flow is highest: about 636,000 gpm 

(40 m3 18 /sec). Circulating water flow is lower under other conditions. In comparison, the lowest 

19 river flow at CNS-1 is about 3,000 cfs. Under the worst conditions, the circulating water system 

20 flow would be about 47 percent of Missouri River flow. Stone riprap at the discharge structure 

21 prevents the discharge from eroding the river bottom. 

22 2.1.7 Facility Water Use and Quality 

23 CNS-1 has a once-through circulating water system withdrawing cooling water from and 

24 discharging to the Missouri River. Each of the four facility circulating water pumps can draw a 

25 maximum of 159,000 gpm. The four service water pumps provide a combined flow of 32,000 

26 gpm. In addition, CNS-1 uses two wells to supply potable ground water to the facility, two wells 

27 to supply water to pump seals and one well for fire protection training (NPPD, 2008). 

28 2.1.7.1 Ground Water Use and Quality 

29 The CNS-1 property overlies the Missouri River Stream Valley Aquifer (described in Section 

30 2.2.3) which consists of interbedded alluvial sand, silt, clay, and gravel ranging in thickness 

31 between 62 and 71 feet (18.9 and 21.6 m) (NDNR, 2008). Saturated thickness of the aquifer 

32 averages approximately 50 feet (15.2 m). In the area of CNS-1, the alluvial aquifer is in 

33 hydraulic contact with the Missouri River with seasonal discharge to the river during lower river 

34 stage and recharge from the river during high stage (NPPD, 2008c). Ground water usually flows 

35 from west to east towards the river, but will flow east to west when river levels are high in the 

36 spring. 

37 The two potable water supply wells completed in the alluvial aquifer are registered with the 

38 Nebraska Department of Natural Resources (NDNR) and have a current combined pumping 

39 capacity of 250 gpm (0.016 m3/s) (NDNR, 2008). Normal operations require pumping only one 

40 well at a time to supply 125 gpm (0.008 m3/s). The wells together operate as a Nebraska Public 

41 Water Supply System under permit number NE3150505 from the Nebraska Department of 

42 Health and Human Services (NHHSS, 2000). The water is chlorinated, distributed onsite, and 

43 operated with preventive maintenance and cross connection/backflow prevention programs. 

44 NPPD plans to replace the two drinking water wells with two similar new wells in the near future. 
Affected Environment 

Draft NUREG-1437, Supplement 41 2-18 February 2010 

1 A third alluvial aquifer well registered with the NDNR used for fire protection training has a 

capacity of 750 gpm (0.047 m3 2 /s). Two additional wells, River Wells A and B, have a capacity of 

3 150 gpm (0.01 m3/s) each and are used to supply water for pump seals. 

4 NPPD CNS-1 also has authorization number NE0208256 from the NDEQ to conduct 

5 underground injection of storm water run-off within the protected area using storm water 

6 drainage wells (dry wells) (NDEQ, 2000). These wells look like storm drains but contain gravel 

7 at the bottom that allows the collected storm water to seep into the fill material above the water 

8 table. This water eventually reaches the water table and disperses. 

9 Ground water monitoring at CNS-1 is conducted by sampling 14 monitoring wells, eleven of 

10 which were installed to measure the concentration of tritium in ground water. Three of the wells 

11 are piezometers installed as part of the ISFSI Project. NPPD has documented seven instances 

12 of liquid radiological releases since the licensing of CNS-1 in 1974, but none of the releases is a 

13 current source of ground water contamination (CRA, 2007). Preliminary sampling and analysis 

14 results from the ground water monitoring program for tritium will be submitted and summarized 

15 in the final SEIS. 

16 2.1.7.2 Surface Water Use and Quality 

17 CNS-1 employs a once-through cooling system using water from the Missouri River. Wing dams 

18 on the Missouri side of the river are designed to force flow into the central channel of the river. 

19 Flow in the river is channelized and carries a heavy sediment load. Sedimentation at the CNS-1 

20 intake is minimized by turning vanes and a sheet-pile wall set in the river that direct sediment 

21 away from the intake structure. 

22 Surface water quality data in the CNS-1 vicinity are provided by USACE low flow studies in 

23 support of the Missouri River Master Water Control Manual. Results show relatively small 

24 ranges of values of temperature, pH, and dissolved oxygen, but wider variations of suspended 

25 solids (USACE, 2007). None of the samples from downstream of CNS-1 showed effects from 

26 operating the CNS-1 once-through cooling system. However, the NDEQ, under the authority of 

27 the Clean Water Act, has designated the Missouri River in the reach from the Platte River to the 

28 Kansas border as impaired for primary contact recreation and fish consumption due to the 

29 presence of fecal coliform and polychlorinated biphenyls (PCBs). Beneficial uses of surface 

30 water identified in the CNS-1 area are for agricultural and industrial water supply (NDEQ, 2004). 

31 2.1.7.3 National Pollutant Discharge Elimination System 

32 The Nebraska Department of Health, Water Pollution Control Council, originally authorized 

33 CNS-1 to use water from and discharge to the Missouri River. Discharge is regulated by 

34 Nebraska NPDES permit NE-0001244 which identifies effluent limitations, monitoring 

35 requirements and other conditions to comply with NDEQ Title 117 and Title 119, Chapter 27 

36 (NPDES permits rules and regulations) and 40 CFR Part 423 (NPPD, 2008). The effluent 

37 limitations for each outfall are shown in Table 2.1.7-1. 
Affected Environment 

February 2010 2-19 Draft NUREG-1437, Supplement 41 

1 Table 2.1.7-1. Effluent Limitations (mg/L) – National Pollutant Discharge Elimination 

2 System Permit for Cooper Nuclear Station, Unit 1 

Total 

Suspended 

Solids

Oil and Grease Total 

Residual 

Chlorine

Temperature-F 

Outfall 

No. 

Avg. 

Month 

Max. 

Daily 

Avg. 

Month 

Max. 

Daily 

Avg. 

Month 

Max. 

Daily 

Max. 

current 

Max. 

proposed 

001 NLR NLR NLR NLR 0.01 0.02 109.4 115.7 

002a NLR NLR NLR NLR NLR NLR NLR NLR 

002b 30 100 NLR 10 NLR NLR NLR NLR 

002c 30 100 NLR 10 NLR NLR NLR NLR 

003 NLR NLR NLR NLR NLR NLR NLR NLR 

004 30 100 NLR 10 NLR NLR NLR NLR 

005 30 100 15 20 NLR NLR NLR NLR 

006 NLR NLR NLR NLR NLR NLR NLR NLR 

008 30 100 NLR 10 NLR NLR NLR NLR 

009 30 100 NLR 10 NLR NLR NLR NLR 

NLR = No Limit Required 

3 Outfall 001, the main discharge canal outfall for the circulating water system, is located 

4 approximately 1000 feet downstream of the CNS-1 intake structure and empties to the Missouri 

5 River. The once-through service water and equipment non-contact cooling water discharges 

6 through Outfall 006, which empties into the discharge canal. Outfall 004 discharges overflow 

7 from the reverse osmosis treatment system and boiler blowdown and also empty into the 

8 circulating water discharge canal. 

9 Outfalls 002a, 002b, and 002c discharge water from roof drain sumps outside the power block, 

10 from clear well discharge, and HVAC blowdown, respectively. Along with the intake screen 

11 backwash discharged through Outfall 003, Outfalls 002a, b, and c discharge to the Missouri 

12 River. Outfall 005 discharges batch volumes of sanitary waste from the sewage lagoon system. 

13 The discharge is sprayed on nearby farm land and is not directly connected to area surface 

14 water bodies. Outfall 008 discharges demineralized well water from the primary plant system’s 

15 waste sample tank and have had only one discharge in the last five years. Outfall 009 

16 discharges demineralized well water from the sample tank floor drains in the radioactive control 

17 area. This outfall has not had a discharge in the last five years. 

18 The only NPDES non-compliance reported in the last five years was total suspended solids 

19 (TSS) at Outfall 004 on August 31, 2008. The TSS averaged 37.4 milligrams per liter (mg/l) 

20 which exceeds the monthly daily permit limit of 30.0 mg/l . The cause of this small excess was 

21 found to be the presence of fish in the reverse osmosis treatment settling pond. The fish, 

22 introduced to the pond by flooding in 2008, stirred up bottom sediment and caused the sample 

23 to contain higher than average TSS. The treatment system did not cause the excess. 
Affected Environment 

Draft NUREG-1437, Supplement 41 2-20 February 2010 

1 In addition to the NDEQ industrial wastewater NPDES permit, CNS-1 has an industrial storm 

2 water discharge permit NER000059 for storm water discharge outside the power block area. 

3 Inside the power block area, storm water discharge is directed to storm water drainage wells 

4 permitted as Class V underground injection wells by the NDEQ under permit NE0208256. The 

5 storm water enters the storm drains and disperses in the vadose zone (i.e., the portion of the 

6 earth between the top of the ground surface and the water table) above the local water table 

7 before it likely discharges to the Missouri River. 

8 2.1.7.4 Dredging 

9 CNS-1 has a USACE dredging permit NE 01-10322 to conduct maintenance dredging of the 

10 CNS-1 intake structure. A typical dredging event removes approximately 350 cubic yards 

(267.6 m3 11 ) of sediment outside the main channel and discharges the dredged material 

12 downstream in the Missouri River (USACE, 2002). 

13 2.2 SURROUNDING ENVIRONMENT 

14 The vicinity of CNS-1 is sparsely populated with zero population within a one-half mile radius of 

15 the plant. Brownville, Nebraska, the nearest developed community, had a 2005 population of 

16 approximately 137. The largest town within 6 miles, Nemaha, Nebraska, located 2.5 miles 

17 southwest, had a 2005 population of approximately 177. The largest town with industry within 10 

18 miles is Auburn, Nebraska, located to the west, with a 2005 population of approximately 3,076. 

19 Nebraska City, located approximately 24 miles northwest of the site, is the closest major town 

20 with a 2005 population of 7,035. Maryville, Missouri, located approximately 40 miles east of the 

21 plant, is the largest community within 50 miles with a 2005 population of approximately 10,567 

22 (NPPD, 2008). 

23 CNS-1 is located on the Missouri River at RM 532.5. In the vicinity of CNS-1, on average the 

24 Missouri River is approximately 800 feet wide and 28 feet deep. Under the present flow 

25 regulation, a minimum Nebraska City flow of 31,000 cfs is maintained for navigational purposes 

26 beginning in March and extending through November. During the winter months, a minimum 

27 flow of 3,000 cfs is required for sanitary purposes. The flow is highly channelized with swift flows 

28 and heavy sediment transport. 

29 The site is located on a constructional plain bordering the west bank of the Missouri River 

30 situated on the first bottomland of the broad, nearly level, flood plain. The USACE has stabilized 

31 the channel by use of pile dikes and bank protection. Earthen levees running parallel with the 

32 Missouri River, and flood protection levees were constructed in the area to prevent meandering 

33 of the river within the alluvial flood plain. The eastern bank of the Missouri River is chiefly a 

34 densely forested land similar to the un-farmable bluffs that run parallel to the Missouri River. To 

35 the west there are bluffs that peak at 1,100 feet, but average 1,000 feet along the stretch of river 

36 from Brownville to Nemaha. Beyond the bluffs, the land is a gently rolling flood plain. 

37 There are several Native American lands within a 50-mile radius of CNS-1 including the Sac 

38 and Fox Reservation, Iowa Reservation, and Kickapoo Reservation. There are also several 

39 local and county parks, golf courses, forest lands, wildlife areas, and other public recreation 

40 lands within a 50-mile radius of CNS-1 (NPPD, 2008). 

41 2.2.1 Land Use 

42 CNS-1 is located on approximately 1,359 acres (550 hectares (ha)) of land owned and operated 

43 by NPPD, including 239 acres (97 ha) on the opposite bank (east) of the Missouri River in 
Affected Environment 

February 2010 2-21 Draft NUREG-1437, Supplement 41 

1 Atchison County, Missouri, see Figure 2.2.1. Of the 1,359 acres (550 ha), 949 acres (384 ha) 

2 are currently leased for agricultural activities such as farming and livestock: 234 acres (95 ha) in 

3 Missouri and 715 acres (289 ha) in Nebraska. The 234 acres (95 ha) on the Missouri side of the 

4 river intermittently flood and are mostly wooded wetlands, with 40 of these acres (16 ha) cleared 

5 for agricultural activities. The developed portion of the plant site consisting of the power plant 

6 structure and associated buildings, maintenance facilities, parking lots, and roads occupies 

7 approximately 55 acres (22 ha) of the site (NPPD, 2008). 

8 

9 Figure 2.2.1-1. Cooper Nuclear Station Facility Location 

10 The immediate area around the station is completely enclosed by a security fence, with access 

11 to the station controlled at a security gate. The exclusion area, as defined by 10 CFR 100.3, 

12 surrounds the plant site as shown in Figure 2.2.1-2. The plant site can be accessed by road on 
Affected Environment 

Draft NUREG-1437, Supplement 41 2-22 February 2010 

1 the west side or from the Missouri River on the east. Road access to the plant site is from 

2 Nemaha County 648A Avenue. A railroad spur connected to the site during construction was 

3 abandoned by the Burlington Northern Railroad. The Steamboat Trace Recreational Trail runs 

4 north and south through NPPD property west of the station along the abandoned railroad right5 of-way (ROW). The nearest residences lie 0.9 miles beyond the site boundary to the northwest 

6 (NPPD, 2008). 

7 

8 Figure 2.2.1-2. Cooper Nuclear Station, Unit 1, Site Boundary Map 

9 (Source: NPPD, 2008a) 
Affected Environment 

February 2010 2-23 Draft NUREG-1437, Supplement 41 

1 2.2.2 Climate and Meteorology 

2 Nebraska is located in the middle portion of the Great Plains. The Great Plains occupy a large 

3 region extending from southern Canadian provinces and parts of States such as Montana, North 

4 Dakota, and Minnesota and southward to Texas, New Mexico, and Louisiana (David J. Wishart, 

5 2004). Nemaha County, where CNS-1 is located, is a part of the Dissected Till Plains that 

6 occupy much of Iowa, eastern Nebraska, northwestern Missouri, and small areas of 

7 northwestern Illinois, southern Minnesota, and northeastern Kansas. Moderately dissected, 

8 glaciated, flat-to-rolling terrain that slopes gently toward the Missouri and Mississippi River 

9 valleys characterizes this area. 

10 Nebraska has a highly variable continental climate, with a large range of both diurnal and 

11 annual temperatures and considerable diversity. There are significant precipitation and 

12 temperature variations from east to west of Nebraska. The climate of eastern Nebraska is 

13 classified as Dfa by Köppen Climate Classification System: a humid continental climate with hot 

14 summers and year round precipitation. 

15 The State of Nebraska belongs to the High Plains National Oceanic and Atmospheric 

16 Administration (NOAA) Regional Climate Center, which is a Federal-State cooperative effort. 

17 The two closest NOAA National Weather stations, which provide the most current 

18 meteorological data for the area, are in Lincoln and Omaha, NE, and are located 61 miles 

19 (98 km) northwest and 62 miles (100 km) north from CNS-1 respectively. 

20 Strong northwestern winds during winter bring cold Arctic air masses from Canada. Occasional 

21 low-pressure systems moving from southwestern States cause high winter winds and severe 

22 blizzards. The average annual wind speed for the National Weather Service (NWS) Station 

23 located in Lincoln, NE, is 10.1 mph (8.8 knots) and 10.5 mph (9.1 knots) for the Omaha NWS 

24 Station (NCDC 2009). In the summer, winds are predominantly from the south. Annual normals 

25 for the 1971–2000 30-year period, provided by the University of Lincoln, indicate that the annual 

26 mean temperature was 51.1°F (10.6°C), with a minimum annual temperature of 39.3°F (4°C), 

27 and a maximum annual temperature of 62.8°F (17.1°C) (UNL, 2009). 

28 The occurrence of severe weather events in Nebraska is high. During 1950–2009, Nemaha 

29 County reported 274 storm events, mostly consisting of tornadoes and high winds with 

30 thunderstorms and hail. According to the National Climatic Data Center (NCDC), 17 tornadoes 

31 were reported in Nemaha County from January, 1950 to February, 2009: 5 @ F0, 7 @ F1, 4 @ 

32 F2, and 1 @ F3 strengths (NCDC, 2009a). Occurrence of floods in Nemaha County is less than 

33 1 per year. Usually they do not cause any significant damage; however, the Auburn flood of 

34 1996 caused $680,000 in property damage and $2.1 million in crop damage. 

35 Nebraska has wide ranges of precipitation from year to year with a steady decrease of rainfall 

36 from east to west. East and southeast areas of Nebraska receive significantly more precipitation 

37 than other areas of the State, where drought is not uncommon. According to the 1971–2000 

38 annual normals for Lincoln, Nebraska, annual precipitation was 28.37 inches (72 cm) (UNL, 

39 2009). 

40 Sections 101(b)(1), 110, 169(a)(2), and 301(a) of the Clean Air Act as amended (42 U.S.C. 

41 7410, 7491(a)(2), 7601(a) established Mandatory Class I Federal Areas where visibility is an 

42 important value. There are no Mandatory Class I Federal areas in the State of Nebraska. The 

43 closest Mandatory Class I Federal area is Hercules-Glades Wilderness Area, which is located 
Affected Environment 

Draft NUREG-1437, Supplement 41 2-24 February 2010 

1 295 miles southeast of CNS-1 in the State of Missouri. Due to the significant distance from the 

2 site, no adverse impacts on Class I areas are anticipated from CNS-1 operation. 

3 2.2.2.1 Air Quality Impacts. 

4 CNS-1 is located in Nemaha County, Nebraska, which belongs to EPA Region 7. There are no 

5 counties designated by the EPA as nonattainment or maintenance for any of the criteria 

6 pollutants in the 50-mile (81 km) vicinity of CNS-1. Douglas County, Nebraska, located 

7 approximately 72 miles (116 km) from CNS-1, is the closest maintenance county for lead. 

8 The Nebraska Division of Air Quality of the NDEQ has primary responsibility for regulating air 

9 emission sources within the State of Nebraska. The NDEQ, with assistance from Lincoln10 Lancaster County Health Department and Douglas County Health Department, conducts 

11 ambient air monitoring in Nebraska, operating 28 sites throughout the State with 34 monitors. 

12 The EPA and National Atmospheric Deposition Program also monitor air quality in Nebraska, 

13 which participates in the EPA’s AIRNow Network that allows for continuous monitoring of the 

14 criteria pollutants and informs the public of current environmental conditions. NDEQ compiles an 

15 annual air quality report (NDEQ, 2008). In compliance with 40 CFR §58.10, NDEQ submitted a 

16 Network Plan for EPA review and approval that reflects changes to the ambient air monitoring 

17 program in Nebraska (NDEQ, 2009). 

18 CNS-1 has a number of stationary emission sources, such as three standby emergency power 

19 supply diesel generators, auxiliaries required for safe starting and continuous operation, and 

20 several petroleum fuel storage tanks, which do not require the facility to secure Title V permit. 

21 CNS-1 is granted a low emitter status by the NDEQ Air Quality Section due to the actual 

22 quantities of emissions that are required to meet criteria and not to exceed thresholds for the 

23 emissions of pollutants defined in Chapter 5, Title 129 of Nebraska Administrative Code: for the 

24 emissions of particulate matter PM10, carbon monoxide (CO), volatile organic compounds 

25 (VOC), oxides of nitrogen (NOx), SO2 or SO3 or any combination of the two (SOx), single 

26 Hazardous Air Pollutant (HAP) or Hazardous Air Pollutant (HAPs) and lead. As reported and 

27 submitted to NDEQ, actual total emissions from all sources at CNS-1 from 2004 to 2008 were 

28 11.52 tons (10.45 MT) per year, 10.73 tons (9.73 MT) per year, 13.21 tons (10.73 MT) per year, 

29 11.43 tons (10.37 MT) per year, and 9.85 tons (8.94 MT) per year respectively. Highest 

30 emissions from 2004 to 2008 were reported in 2006: 0.16 tons (0.15 MT) per year of PM10, 

31 2.41 tons (2.19 MT) per year of CO, 0.22 tons (0.20 MT) per year of VOC, 9.0 tons (8.16 MT) 

32 per year of NOx, 1.41 tons (1.28 MT) per year of Sox, and 0.01 tons (0.009 MT) per year of 

33 single HAP (NPPD, 2009c). The generators are tested periodically to ensure their continued 

34 ability to perform their intended function; and there are procedures in place to ensure 

35 continuous monitoring, sampling, and filtering of the oil. Used oil is collected for offsite disposal. 

36 Used oil disposal is discussed further in the waste management section. 

37 CNS-1 operates a meteorological system that consists of two monitoring sites at the ground 

38 elevation of approximately 889 feet (271 m) above mean sea level (AMSL). The first monitoring 

39 site accommodates a 328-foot (100-m) primary meteorological tower and a 32.8-foot (10-m) 

40 back up tower. The former is located approximately 3,230 feet (985 m) and the latter is located 

41 approximately 1,597 feet (487 m) from the northwest corner of the reactor building respectively. 

42 The second monitoring site, a 328-foot (100-m) meteorological tower, with equipment and 

43 monitoring system that is nearly identical to the original 328-foot (100-m) tower, was recently 

44 built approximately 2,000 feet (610 m) northwest of the first site. There are two independent 

45 identical dual sensors, system A and system B, mounted onto the 328-foot (100-m) primary 

46 meteorological tower measuring temperature, wind speed, and direction at 32.8 feet (10 m), 197 
Affected Environment 

February 2010 2-25 Draft NUREG-1437, Supplement 41 

1 feet (60 m) and 328 feet (100 m). Vertical temperature differential is measured with temperature 

2 sensors between all three levels. A relative humidity sensor is positioned at the 32.8 feet (10 m) 

3 level. Precipitation is measured at ground level (NPPD, 2008). 

4 The meteorological data (15-minute and hourly average) is run through meteorological data 

5 validation software that checks and flags data discrepancies and inputs it to the CNS-1 plant 

6 computer. In the case of a complete system failure, the National Weather Service Office, 

7 located in Valley, Nebraska provides backup meteorological data by telephone or National 

8 Warning System (NPPD, 2008). 

9 2.2.3 Ground Water Resources 

10 As described by the United States Geological Survey (USGS, 1997), the Western Interior Plains 

11 Bedrock Aquifer System is present beneath the CNS-1 site but contains no fresh water. The 

12 only freshwater aquifer system beneath the site consists of unconsolidated alluvial deposits of 

13 the Missouri River Stream Valley Aquifer and glacial deposits of the Glacial Drift Aquifer. These 

14 deposits are reworked and difficult to distinguish within the main river valley. All of the onsite 

15 wells are completed in these deposits and the aquifer is under unconfined (water-table) 

16 conditions (NPPD, 2008). 

17 As part of a hydrogeologic investigation undertaken by CNS-1 for the study of radioisotopes in 

18 ground water, CRA reviewed water use in the area surrounding the station and searched the 

19 NDNR water-well database for all wells in Nemaha County. Three irrigation wells, completed in 

20 the shallow unconsolidated aquifer, are located between two and three miles southwest of CNS21 1. Four farm wells within one mile of the station, all only 15 feet deep, produce a limited amount 

22 of ground water. None of these wells are impacted by ground water pumping at CNS-1 because 

23 the station wells are screened in an unconfined aquifer and have limited radii of influence. A 

24 search of wells by NPPD in Atchison County, Missouri, across the river from CNS-1 identified no 

25 wells within two miles of the station. In addition, the Missouri River serves as a ground water 

26 recharge/discharge boundary. 

27 Because of the limited radius of influence of CNS-1 wells completed in the unconfined aquifer, 

28 no public ground water supplies are close enough to CNS-1 to be impacted by ground water 

29 use at the station. There are no well-head protection areas or EPA-designated sole source 

30 aquifers in the vicinity of CNS-1 (CRA, 2007). 

31 2.2.4 Surface Water Resources 

32 CNS-1 is within the Nemaha River Basin whose water resources are managed by the Nemaha 

33 Natural Resources District (NNRD). The basin is defined as those areas south of the Platte 

34 River that drain directly into the Missouri River. Total area of the basin is 2,800 square miles 

(7,252 km2 35 ) (NPPD, 2008). 

36 Flow of the Missouri River at CNS-1 is partially controlled by the Gavins Point Dam located 

37 approximately 200 miles (321 km) upstream near Yankton, South Dakota. The USACE 

38 constructed and operates six of the seven main-stem dams on the Missouri River; the U.S. 

39 Bureau of Reclamation operates the seventh dam located east of Helena, Montana. The 

40 confluence of the Platte and Missouri rivers is located 63 miles (101 km) north of CNS-1. The 

41 Platte River discharges a significant amount of sediment into the Missouri, much of which is 

42 carried downriver to CNS-1 and beyond (NPPD, 2008). 
Affected Environment 

Draft NUREG-1437, Supplement 41 2-26 February 2010 

1 At the CNS-1, the Missouri River is approximately 800 feet (244 m) wide and 28 feet (8.5 m) 

2 deep in the main channel. As currently regulated by the USACE, the minimum flow in the river 

3 for navigation purposes in March through November at Nebraska City, NE, 30 miles (48.3 km) 

north of CNS-1, is 31,000 cfs ( m3 4 /s). In December through February, the minimum flow 

permitted is 3,000 cfs (85 m3 5 /s), primarily for sanitary purposes. The lowest flow recorded at 

Nebraska City was 4,320 cfs (122 m3 6 /s) in 1957. If a severe drought occurs, USACE would 

7 shorten the navigation season to keep upstream reservoirs high enough to maintain minimum 

8 sanitary flows. Water release schedules and priorities for the dams are contained in the USACE 

9 Master Manual (USACE, 2004). 

10 Water level elevations in the river at CNS-1 range from 874.5 to 899.0 feet (266.5 to 274 m) 

11 AMSL with an average level of 880.0 feet (268 m). The mean annual discharge of the river at 

Nebraska City is 42,160 cfs (1,194 m3 12 /s) as measured and calculated for the years since 1948 

13 when the upstream impoundments started to control flows. Because the river has been 

14 channelized and has a relatively uniform cross-section, flow velocity is up to 3 miles per hour 

15 (3.8 kmh), which is significantly higher than historic flows prior to completion of the major 

16 impoundments (NAS, 2002). 

17 Significant changes in the Missouri River due to management practices include loss of natural 

18 flood and low flow processes, straightening of meanders, bank stabilization, and reduction of 

19 temperature variation. These changes, although ecologically significant, result in a more stable 

20 water supply for CNS-1. 

21 2.2.5 Description of Aquatic Resources 

22 2.2.5.1 Ecosystem Services Provided by Missouri River Aquatic Ecosystems 

23 The Missouri River has provided and continues to provide many ecological services to people 

24 living within its basin. The phrase ecosystem services “refers to a wide range of conditions and 

25 processes through which natural ecosystems, and the species that are part of them, help 

26 sustain and fulfill human life” (Daily et al., 1997). These services are intrinsic to the river itself 

27 and go beyond the obvious constructed economic services of providing a route for 

28 transportation or a source of water for irrigation and public consumption. 

29 Daily et al. (1997) provide examples of general ecosystem services, and NRC staff identified the 

30 following ecosystem services specifically provided by the Missouri River. The Missouri River 

31 supports birds and other wildlife through fish, insect, and other food webs and also provides 

32 recreation and commercial fishing. The river supports populations of mussels that once were a 

33 major source of food, tools, and jewelry for Native Americans and later a source of buttons and 

34 starting nuclei for cultured pearls. It provides drinking water that supports many forms of 

35 domestic animals and wildlife and helps maintain biodiversity from which we derive key 

36 ingredients of our agricultural, pharmaceutical, and industrial enterprises. The river supports the 

37 aquatic phase of insect predators that help control agricultural and other pests. 

38 Within the Missouri River ecosystem, bacteria, algae, fungi, and invertebrates absorb waste 

39 nutrients and break down, detoxify, and decompose various wastes and, in doing so, purify 

40 water. Living and nonliving components of the aquatic ecosystem participate in the oxygen, 

41 carbon, and nitrogen cycles and help mediate concentrations of oxygen and carbon dioxide in 

42 the air. Bacteria, fungi, and invertebrates that break down wastes and organic matter, help 

43 make the soil fertile where suspended solids that the river deposits following floods. In doing 

44 this, the river helps cycle and move nutrients. The river also helps disperse seeds of some 

45 natural vegetation. The Missouri River helps maintain the balance of recharge to the ground 
Affected Environment 

February 2010 2-27 Draft NUREG-1437, Supplement 41 

1 water and cycling of water back to air as part of moderating the water cycle. The river also 

2 provides aesthetic beauty, intellectual stimulation, and opportunities for education. 

3 2.2.5.2 Conceptual Model of Midwestern Rivers 

4 Karr et al. (1985) summarized the history and sources of degradation of Midwestern rivers. The 

5 conclusions, which they illustrate with examples from the Maumee and Illinois rivers are 

6 applicable to understanding the aquatic resources of the Missouri River near CNS-1 today. Karr 

7 et al. (1985) found that the human activity with the greatest impact on Midwestern fish 

8 communities was agriculture, which lowers the water table and supplies excess nutrients; 

9 navigational locks and channels in large rivers; impoundments, levees, and milldams; discharge 

10 of wastes that consume oxygen and toxic contaminants; overconsumption of water; and 

11 introduction of exotic species. The authors presented a conceptual model to illustrate the links 

12 between these activities and those for recovery and restoration and Midwestern river fish 

13 communities. 

14 In their conceptual model (Figure 2.2.5-1), five primary variables affect the integrity of aquatic 

15 biota. (1) The energy source may be primarily allochthonous (not formed in situ, but originating 

16 in another place) organic matter or primary production. As well as the amount of energy, the 

17 size distribution of organic particles affects aquatic communities. (2) Water quality includes such 

18 factors as temperature, turbidity, dissolved oxygen concentration, soluble organic and inorganic 

19 materials, metals, and toxic substances. (3) Habitat structure includes such things as bottom 

20 type (e.g., hard substrata, sand); water depth; current velocity; availability of spawning, nursery, 

21 and hiding places; and habitat diversity. (4) Flow regime indicates water volume, seasonality 

22 and temporal distribution of flow and water volume, and frequency of flooding. (5) Trophic 

23 interactions among biotic components include such factors as competition, predation, disease, 

24 and parasitism. Natural changes and human activities act through these five primary variables 

25 effecting the integrity of aquatic biota to cause changes in aquatic communities. The following 

26 summary of natural and human history in the Missouri watershed, represented in Figure 2.2.5-1, 

27 shows continual changes in the factors that influence the structure and function of aquatic 

28 communities in this Missouri River . 
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Draft NUREG-1437, Supplement 41 2-28 February 2010 

1 

2 Figure 2.2.5-1. Conceptual model showing primary external and internal variables with 

3 their interactions that govern the integrity of the aquatic biota of Midwestern streams

4 (After Karr et al., 1985)

5 2.2.5.3 Description of the Missouri River Basin 

6 The nature of Missouri River aquatic resource communities strongly reflects the formation and 

7 history of the Prairie region it drains. The Missouri River basin is large, and its present ecology 

8 was formed fairly recently on a geological and evolutionary time scale. Because of its size, the 

9 basin encompasses many diverse habitats on regional and local levels. Because it is fairly 

10 recent, many species that live in the basin are not endemic but have evolved elsewhere and 

11 moved into the basin. The present ecology of aquatic communities reflects a history of change 

12 both prehistoric and historic and of habitat diversity within seasons and across various 

13 geographic scales. 

14 The modern Missouri River basin is the second largest in the United States and drains about a 

15 sixth of the conterminous United States as well as part of Canada, including all or parts of 

16 10 U.S. States, 2 Canadian provinces, and 25 Native American lands or tribal reservations. 

17 Many of the Missouri River’s tributaries drain east to the main stem, which flows roughly 

18 southeast. Starting from the west, the river basin drains three physiographic divisions: the 

19 Rocky Mountain System, which contributes a little over 10 percent of total flow; the Interior 

20 Plains; and the Interior Highlands. Most of the river flows through the highly erodible soils of the 

21 Great Plains and Central Lowlands' physiographic provinces of the Interior Plains division, 

22 which produces high turbidity and sediment transport (Galat et al., 2005b). 

23 Change and perturbation heavily influence the ecology of the Missouri River, including the 

24 aquatic ecology. Glaciers covered much of the basin during the last ice age and helped 

25 determine the course of the modern Missouri River and its tributaries as well as land forms and 

26 soils. The modern prairie drained by the Missouri River is relatively young and formed in the last 

27 several million years so that much of the flora and fauna have colonized from surrounding 

28 ecosystems and few species evolved in and are endemic to the prairie (Benedict et al., 1996). 

29 Between the last ice age, which ended about 10,000 years ago, and the beginning of recorded 

EXTERNAL 

LAND-WATER 

INTERFACE 

INTERNAL 

Weather / 

Climate 

Riparian 

Environment 

Land Use 

Channel 

Morphometry 

Flow 

Regime 

Water 

Quality 

Physical 

Habitat 

Biotic 

Interactions 

Fish 

Community 

Structure 

Energy 

Source 

Redrawn after Karr et al. 1985 
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February 2010 2-29 Draft NUREG-1437, Supplement 41 

1 history of the prairie, invasion and colonization of the basin by plants and animals, and later 

2 humans, and extinction of nearly all large mammal species brought further change. Early human 

3 settlement probably had limited effects on the ecology of the basin until the twentieth century, 

4 when the Federal government intervened to encourage further settlement and development 

5 (National Research Council, 2002). 

6 Increased settlement occurred through the 1800s, and irrigated agriculture resulted in the early 

7 construction of first small and then larger dams in the late 1800s. From the mid-1820s through 

8 the 1870s, the Federal government worked to remove large tree snags from the Missouri River 

9 to improve navigation. The USACE began stabilizing the river banks in the late 1880s. 

10 Construction of hydropower dams began in the late 1800s. Several irrigation projects began in 

11 1904, and by the 1930s, most of the tributaries of the Missouri River had one or more dams. In 

12 the late 1920’s, the USACE began a program that combined bank stabilization with dike 

13 construction and strategic dredging designed to narrow the river and eliminate meandering. 

14 Where the USACE eliminated wide bends in the river and narrowed the channel, the river’s 

15 velocity increased, and in some places the river became self-scouring. The subsequent Federal 

16 Pick-Sloan Plan in 1944 led to the construction of six main-stem dams and dedicated upstream 

17 storage to three primary uses: hydropower generation, navigation enhancement, and flood 

18 control (National Research Council, 2002). 

19 Today the Missouri River is highly regulated, with about 1,200 single-purpose and 

20 100 multipurpose reservoirs, including six reservoirs on the main stem (Galat et al. 2005a, 

21 2005b). The aquatic community has been highly influenced by damming and channelization. 

22 The reservoirs have changed lentic (i.e., pertaining to still or standing water) habitat into lotic 

23 (i.e. pertaining to flowing or running water) habitat and impair migration of fish and other aquatic 

24 organisms. Construction of structures such as dikes, levees, stabilization structures, and dams 

25 have added hard substrata, or replaced soft substrata with hard substrata in aquatic habitats. 

26 The reservoirs, channels, and structures affect physical habitat, water temperature and quality, 

27 flow regimes, suspended sediment loads, and light penetration, and many other attributes of the 

28 aquatic ecosystem (Galat et al. 2005a, 2005b). The prairie is subject to frequent perturbations 

29 on time scales that range from shorter than a year to those spanning decades or millennia, such 

30 as fire, draught, flooding, grazing, storms, and local events such as digging activities of animals 

31 (Benedict et al. 1996). All of these influences affect aquatic habitats and communities. 

32 The climate in the basin is semi-arid, and both direct precipitation and snow melt contribute to 

33 the flow, which results in a seasonal succession of low and high flows. Before dam construction 

34 and regulation, river flows peaked twice a year: A smaller peak in March through April as snow 

35 and ice melted in the middle and upper basins and the prairie, and a second, larger peak in 

36 June as the result of melting snows in the Rocky Mountains and precipitation over the prairie. 

37 Overbank flooding was common during peak flows. Flows then declined in July and remained 

38 low until spring (Galat et al., 2005a). 

39 Before dam construction and regulation of the river, the variation in flow drove changes in the 

40 river channel’s location, form, and volume of sediment transported. The river carried large 

41 amounts of sediment and was known as the “Big Muddy.” During high flows, erosion could be 

42 severe. As flooding subsided, the river deposited substantial amounts of sediments on flood 

43 plains. In a dynamic equilibrium, the river redistributed sediments between its channel and 

44 floodplain. The channel was braided to highly sinuous and “characterized by log jams, snags, 

45 whirlpools, chutes, bars, cut-off channels, and secondary channels around bars” (National 

46 Research Council 2002). Sand bars shifted frequently. “A typical cross-section of the 

47 pre-regulation Missouri River contained a deep channel, multiple side channels, oxbow lakes, 
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Draft NUREG-1437, Supplement 41 2-30 February 2010 

1 islands, sand bars and dunes, and backwater habitats interspersed by areas of higher land.” 

2 The seasonal pattern of flow and temperature cued many natural processes, such as fish 

3 spawning, insect emergence, and seed germination. The diverse habitat with frequent 

4 disturbance supported high biodiversity and biological productivity (National Research Council, 

5 2002). 

6 In the post-regulation Missouri River, main stem dams dampen the high variation in flows below 

7 them, and the extremely high and low flows no longer occur. Dredging and channelization have 

8 eliminated much of the temporal and spatial variation. In channelized areas, a typical cross 

9 section of the post-regulation Missouri River is trapezoidal rather than varied, and in places, 

10 complex. Suspended sediment loads now drop from suspension in the relatively still water of 

11 reservoirs behind dams, where clearer water supports greater primary productivity and aquatic 

12 species that hunt by vision. Channel degradation occurs below the dams while sedimentation 

13 accumulates in reservoirs, and these processes slowly change aquatic habitats. Seasonal cues 

14 to biological processes are muted. Fish no longer use floodplains seasonally for spawning and 

15 as nursery areas for their young. The water, sediment, and nutrients that once spread across 

16 the flood plains are now contained within the channel and reservoirs. In the change from pre-to 

17 post-regulation, some aquatic species thrived, and some, such as pallid sturgeon 

18 (Scaphirhynchus albus) and sauger (Sander canadense), experienced sharp reductions. 

19 Overall, the less diverse habitat and decreased disturbance of the post-regulation Missouri 

20 River support lower biodiversity and lower biological productivity (National Research Council, 

21 2002). 

22 The biological classifications of its terrestrial ecosystems, land uses, and the distribution of fish 

23 in the entire basin and in the main stem illustrate the spatial diversity of the Missouri River. The 

24 Missouri River flows through and drains six terrestrial ecoregions: North Central Rockies 

25 Forests, Montana Valley and Foothill Grasslands, Northwestern Mixed Grasslands, Northern 

26 Mixed Grasslands, Central Tall Grasslands, and the Central Forest/Grassland Transition Zone 

27 (Galat et al. 2005b). Within 3 miles (5 km) of the river, however, most of the land use is in 

28 cropland (33 percent), grassland (26 percent), and developed land (17 percent) (Galat et al. 

29 2005b). Abell et al. (2000, 2008) define three aquatic ecoregions of the Missouri River primarily 

30 on the basis of fish distribution: the Upper Missouri, Middle Missouri, and the Central Prairie. 

31 Based on geomorphology and hydrology, Galat et al. (2005a and 2005b) recognize three zones 

32 of the Missouri River main stem: The upper zone, from the origin of the Missouri River to Fort 

33 Peck Lake, Montana, which is the first major impoundment, is unchannelized and largely flows 

34 freely; the middle zone, from the upper end of Fort Peck Lake to the Gavins Point Dam, which 

35 forms Lewis and Clark Lake, is not channelized but has impoundments, and can be subdivided 

36 into a reservoir zone made up of individual impoundments separated by an inter-reservoir, 

37 riverine zone that connects them; and the lower zone, from Gavins Point Dam to the confluence 

38 with the Mississippi River, is channelized and has bank stabilization and floodplain levees. 

39 CNS-1 lies within the lower, channelized zone. 

40 2.2.5.4 Physical Features of the Missouri River near the Cooper Nuclear Station 

41 CNS-1 is located on the west bank of the Missouri River at RM 532.5 (1,960 river miles). The 

42 bottom contour of the river at CNS-1 is roughly trapezoidal. The Missouri River channel in front 

43 of CNS-1 is at an elevation of about 860 to 865 feet (262 to 265 m) AMSL compared to the 

44 natural grade level of the flood plain around CNS-1 of 890 feet (271 m) AMSL. On average, the 

45 river is about 800 feet (245 m) wide and 28 feet (8.5 m) deep in the vicinity of CNS-1. Riprap 

46 covers some areas of shoreline near the CNS-1, and soft sediments are typically composed of 
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February 2010 2-31 Draft NUREG-1437, Supplement 41 

1 medium to course sand. Pile dikes and shoreline protection stabilize the channel. Gavins Point 

2 Dam, located about 200 river miles (322 river kilometers (RKm)) upstream in Yankton, South 

3 Dakota, largely controls the flow of the Missouri River at CNS-1. The flow changes seasonally, 

but the annual mean river flow from 1930 through 2001 was 38,251 cfs (1,083 m3 4 /sec) at the 

5 USGS gauging station located about 30 river miles (48 RKm) upstream at Nebraska City, 

6 Nebraska. NPPD owns the 345 kV transmission line designated as TL3504 that passes over the 

7 Missouri River at CNS-1; at the center of the Missouri River, transmission line ownership 

8 changes (NPPD, 2008). 

9 2.2.5.5 Potentially Affected Aquatic Resources 

10 Several publications and reviews provide comprehensive descriptions of the Missouri River 

11 aquatic ecosystems, including National Research Council (2002), Galat et al. (2005a, 2005b), 

12 and USACE (2004). From the headwater streams to the main stem Missouri River, aquatic 

13 communities show the affects of man’s activities. Rabeni (1996) summarized the state of the 

14 fish and aquatic resources of the prairie ecosystem as follows: 

15 The ecological integrity of most prairie streams has been compromised, because 

16 every important relation has been affected: flow conditions by dewatering, altered 

17 land-use, and disruption of headwaters; energy source balance by the increase 

18 of instream primary production with nutrients and less shading; water quality by 

19 modern synthetic compounds and organic wastes; physical habitat by 

20 channelization and riparian degradation; and the biotic balance by the 

21 introduction of fish predators and competitors and elimination of important food 

22 sources. 

23 Comparing this description to Karr et al.’s (1985) conceptual model of Midwestern rivers 

24 (Figure 2.2.5-1), one can see that human activities have adversely affected all aspects of the 

25 environment that influence the integrity of aquatic communities. 

26 Much of the information summarized below is from a compendium of studies (Hesse et al., 

27 1982b) conducted in the late 1960s and early 1970s to provide ecological information for 

28 assessing the impacts of Fort Calhoun and Cooper Nuclear Stations, both on the Missouri 

29 River. Fort Calhoun Station is a nuclear generating unit located at river mile marker (RM) 646.0 

30 (1,040 RKm), about 113.5 river miles (183 RKm) north of CNS-1, which is located at RM 532.5 

31 (857 RKm); the aquatic communities at the two stations are similar. 

32 2.2.5.6 Primary Producers: Phytoplankton, Periphyton, and Aquatic Macrophytes 

33 Before the completion of the dams on the main stem, phytoplankton abundance was low due to 

34 the high turbidity and current velocity and the lack of still water habitats. Although dams now 

35 replace lotic habitat with lentic habitat where sedimentation increases water clarity, the limiting 

36 factor for algal growth in much of the river is still light, not nutrients, due to turbidity (Galat et al., 

37 2005b). 

38 Galat et al. (2005a, in Rivers of North America) summarized the ecology of planktonic algae and 

39 cyanobacteria in the Missouri River basin. Most of the information dated from the 1980s or 

40 before. Reetz (1982) reported results of phytoplankton studies conducted in the Missouri River 

41 in the vicinity of CNS-1 and Fort Calhoun (Nuclear) Station, about 113.5 RM (183 RKm) north of 

42 CNS-1, from 1974 through 1977. The composition of the phytoplankton community through the 

43 year was largely determined by discharges from Lewis and Clark Lake (RM 811, RKm 1,305), 

44 which is 278.5 river miles (448 RKm) upstream, with modifications due to “production in 

45 backwater areas of the unchannelized river, production in pools behind the trail dikes in the 
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Draft NUREG-1437, Supplement 41 2-32 February 2010 

1 channelized portion, input of phytoplankton from tributaries, and the scouring of periphytic 

2 forms” (Reetz, 1982, p. 73). While the species may have changed over the last several decades 

3 since Reetz’s 1982 studies, the process he describes likely remains unchanged. Although Reetz 

4 (1982) could discern no clear trend in phytoplankton abundance at CNS-1 for the 1974–1977 

5 study period, carbon fixation rates were generally lower in winter and highest in mid-summer. 

6 Carbon fixation is the photosynthetic process by which plants convert carbon dioxide (and 

7 water) to sugar (and oxygen). 

8 Reetz (1982) compared phytoplankton functions at the intake and discharge of both CNS-1 and 

9 Fort Calhoun Station. Initial (7-hour) differences in carbon fixation rates at CNS-1 ranged from 

10 an average of about 17 percent inhibition during summer to no change during winter. The 

11 inhibition in the summer months appeared to depend on absolute discharge temperature and 

12 the highest inhibition rates (above 26 percent) occurred when absolute discharge temperatures 

13 exceeded 101 °Fahrenheit (38.5 °C). Recovery from initial inhibition at CNS-1 occurred within 

14 48 hours. While the river would carry phytoplankton far downstream in 48 hours so that a 

15 substantial part of the river would be affected, Reetz (1982) concluded that the low rate of water 

16 use by CNS-1 compared to river flow combined with the rapid mixing of the thermal plume 

17 would make the effects relatively unnoticeable. 

18 Farrall and Tesar (1982) reported results of periphytic algae studies conducted in the Missouri 

19 River in the vicinity of CNS-1 from 1972 through 1977, and Fort Calhoun Station from 1974 and 

20 1975. Periphytic algae are those algae attached to solid surfaces under water such as rocks, 

21 logs, pilings and other structures. Because they remain in one place, periphytic algae colonizing 

22 natural and artificial substrata can be used as indicators of environmental effects. Algae fix 

23 carbon through photosynthesis and are a base of food webs. In some rivers, such as the 

24 Missouri River, organic matter from land and upstream sources is often another base of local 

25 aquatic food webs. Farrell and Tesar (1982) did not detect changes in the diversity, density, and 

26 biovolume of periphytic algae related to water temperature in the vicinity of CNS-1, although 

27 species composition did reflect water temperature. Although these results may generally be 

28 indicative of periphyton responses and processes at CNS-1 today, species composition and 

29 magnitude of response, which depends on the species involved, may have changed over the 

30 decades since Ferral and Tesar’s (1982) studies. 

31 High turbidity, unstable substrates, and variable currents almost exclude aquatic macrophytes 

32 from the Missouri River (Galat et al. 2005, in Rivers of North America), and NRC staff found no 

33 studies of these macrophytes in the vicinity of CNS-1. 

34 2.2.5.7 Invertebrates: Zooplankton and Benthos 

35 Repsys and Rogers (1982) reported results of invertebrate zooplankton studies conducted in 

36 the Missouri River in the vicinity of CNS-1 and Fort Calhoun Station from 1972 through 1977. 

37 Zooplanktons are animals suspended in the water column and typically contain permanent 

38 residents of the water column; temporary members swept up by currents, etc.; and organisms 

39 that spend only part of their life cycle in the water column, such as insect and fish eggs and 

40 larvae. Zooplankters eat algae and bacteria, protozoans, other zooplankton, detritus, fish eggs 

41 and larvae, or a combination of these, and, in turn, are eaten by other invertebrates, fish, and 

42 amphibians. In general, zooplanktons are more adapted to the lentic environment of lakes and 

43 reservoirs than the lotic environment of streams and rivers. In flowing water environments, 

44 currents and suspended sand can buffet zooplankters and cause mechanical damage, while 

45 smaller suspended silt and clay particles can adhere to their bodies and interfere with 

46 respiration and feeding. 
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February 2010 2-33 Draft NUREG-1437, Supplement 41 

1 Repsys and Rogers (1982) concluded that the zooplankton community near CNS-1 appears to 

2 be largely determined by upstream reservoirs, where the lotic environment encourages their 

3 production. The most common groups they collected include copepods and cladocerans (both 

4 crustaceans) and rotifers. While the general pattern of abundance in the study indicated 

5 relatively high crustacean peaks in late fall to spring and reduced populations during summer 

6 and early autumn, the pattern was poorly defined. The authors concluded that the seasonality of 

7 zooplankton densities in the limnetic Lake Francis Case, which is more like a natural lake and 

8 has high zooplankton production, influenced through releases the pattern of zooplankton 

9 downstream in the smaller and less productive Lewis and Clark Lake, which in turn influenced 

10 through releases the pattern of zooplankton downstream at CNS-1. 

11 Decreasing zooplankton densities in the river indicated to them that zooplankton populations 

12 originating in the highly productive Lake Francis Case experienced considerable mortality on the 

13 downriver journey to CNS-1. Repsys and Rogers (1982) also investigated the effects of CNS-1 

14 on zooplankton populations in 1974 through 1978. High absolute discharge temperatures 

15 ≥ 95 °F (35 °C) critically affected zooplankton survival, as did duration of exposure. Repsys and 

16 Rogers (1982) concluded that entrainment losses were small when compared to the large 

17 downstream decreases in zooplankton. Without further studies, NRC staff concludes that these 

18 general patterns and processes most likely still occur, although species composition and 

19 magnitude of response, which depends on the species involved, may have changed over the 

20 decades since Repsys and Rogers’ (1982) studies. 

21 Carter et al. (1982) reported results of benthic infaunal and epifaunal (called aufwuchs on the 

22 artificial substrate samples employed by Carter et al.) invertebrate studies conducted in the 

23 Missouri River in the vicinity of CNS-1 and Fort Calhoun Station from 1973 through 1977. 

24 Benthic infauna refers to the organisms that live in underwater sediments, and benthic epifauna 

25 refers to organisms that live on underwater surfaces. Benthic invertebrates form a complex 

26 community. Various members may eat algae filtered from the water column, suspended detritus 

27 and organisms, sediments, periphytic algae and bacteria, other benthic organisms, and fish 

28 eggs and larvae. Carter et al. (1982) report that the channel area of the Missouri River in the 

29 vicinity of CNS-1 is largely unsuitable for macroinvertebrates because of continuous shifting and 

30 scouring of bottom sediments. In the lee of wing dikes, sedimentation occurs during periods of 

31 low flow and supports infaunal communities that may be lost due to scouring during periods of 

32 high flow. The seasonal diversity of the benthic community in this area is inversely related to the 

33 variability of the flow as measured on a daily basis (Carter et al., 1982): benthic diversity is 

34 higher when flows are stable. The most common members of the benthic community are 

35 oligochaete worms, primarily tubificids, which live in tubes and may avoid direct contact with the 

36 currents, and secondarily naids, which live in the surface layers of sediments and may be 

37 subject to low level scouring. Another numerically important group was insect larvae of the 

38 family Chironomidae, or non-biting midges (flies). All of these groups are indicative of 

39 organically enriched sediments and tolerate low dissolved oxygen levels and so have been 

40 designated as indicators of poor water quality (Barbour et al., 1999). 

41 Epifaunal invertebrates in this section of the river are typically found on dikes and riprap. Carter 

42 et al. (1982) report that the most common members on dykes and artificial substrate samplers 

43 were chironomid, trichopterid (caddisfly), and ephmeropterid (mayfly) larvae. The caddisfly 

44 larvae found here are typically net spinners and filter feeders whose survival depends on 

45 currents. The chironomid larvae included grazers, predators, and tube-dwellers. The insect 

46 larvae are seasonal members of the macroinvertebrate community that become terrestrial after 

47 emergence. Carter et al. (1982) were not able to detect consistent changes in the epifaunal 

48 invertebrate community due to the operation of CNS-1. 
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Draft NUREG-1437, Supplement 41 2-34 February 2010 

1 2.2.5.8 Larval Fish 

2 Hergenrader et al. (1982) report the results of both field and entrainment studies on larval fish in 

3 the vicinity of CNS-1 in 1974 through 1976. Several life stages of fish may occur in the plankton, 

4 where they are called ichthyoplankton, and may be subject to entrainment at power plants: 

5 eggs; larvae, which include both yolk-sac and post yolk-sac larvae and have little or no fin 

6 development; post larvae, which have fully developed fins but bodies that have not yet reached 

7 the adult form; and juveniles, which have attained the adult form but are still immature. Eggs 

8 and juveniles in the collections near CNS-1 were not commonly caught, and made up two 

9 percent and one percent, respectively, of all ichthyoplankton. Larval fish were common in the 

10 drift near CNS-1 from May through July, and the numerically dominant fish larvae were 

11 freshwater drum, catastomids (e.g., suckers), cyprinids (e.g., minnows), and carp. Larval fish 

12 were rare or absent in other months. Although freshwater drum comprised only about five 

13 percent of adult fish in the vicinity of CNS-1, since they are pelagic spawners, spawning in the 

14 open water column, they contributed 70 to 90 percent of the larvae. Other species commonly 

15 found as larvae in the drift, common carp (Cyprinus carpio), catastomids, gizzard shad 

16 (Dorosoma cepedianum), and goldeneye (Hiodon alosoides), are also either random or pelagic 

17 spawners. The larvae of most of the game fish in the area—white bass (Morone chrysops), 

18 sunfish (Lepomis spp.), crappie (Pomoxis spp.), sauger (Stizostedion canadense), walleye 

19 (Sander vitreus), and channel catfish (Ictalurus punctatus)—were relatively under-represented 

20 because most of these fish either build nests or spawn randomly, most have adhesive and 

21 demersal (sinking) eggs, and some of these species provide parental care of the eggs and 

22 larvae. 

23 Depending on the species, the sources of the larvae near CNS-1 included the upstream Louis 

24 and Clark Lake, tributaries, cut-off chutes, and backwaters. Densities of ichthyoplankton also 

25 depended on time of year, river flow, horizontal position in the river (cutting bank, mid-channel, 

26 or filling bank), depth and patterns of vertical migration, and growth and mortality rates 

27 (Hergenrader et al., 1982). 

28 Hergenrader et al. (1982) also report on entrainment mortality. NRC staff conclude that little can 

29 be learned from their direct observations of entrainment mortality because the control mortality 

30 measured at the intake was very high, which makes estimation of plant-induced mortality 

31 impossible, and because they only observed immediate mortality (typically 20 to 40 minutes 

32 after collection), which does not provide an estimate of longer-term or chronic mortality. Injured 

33 larvae may not die immediately, and today the standard holding time for fish larvae in short-term 

34 chronic toxicity tests with a survival endpoint is typically seven days (EPA, 2002) in order to 

35 account for mortality that is not immediate. In order to determine if entrainment (and 

36 impingement) were having an effect on the fish populations in the area, Hergenrader et al. 

37 (1982) looked for changes in adult fish populations resulting from impacts to ichthyoplankton but 

38 detected none. They concluded that either no significant changes occurred or “[t]oo few 

39 resources (financial, technical, equipment, labor) were applied over too small a time frame in too 

40 restricted an area to detect the changes which have occurred.” 
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February 2010 2-35 Draft NUREG-1437, Supplement 41 

1 2.2.5.9 Fish 

2 Galat et al. (2005a, 2005b) report about 183 fish species from the Missouri River, of which 

3 about 136 were found in the main channel. No fish species are unique to the main stem (i.e., 

4 endemic species), and just two are endemic to the Missouri River basin. About three quarters of 

5 Missouri River fish species are native, that is, they live and survive in the river under natural 

6 conditions and have not been introduced by human activity. The majority of the species (68 

7 percent) belong to just five families: Cyprinidae (e.g., carp, chub, dace, shiners, minnows); 

8 Catostomidae (e.g., suckers, chubsuckers, redhorse, buffalo); Salmonidae (e.g., trout, salmon, 

9 whitefish); Centrarchidae (e.g., sunfish; crappies; freshwater basses, but not striped bass and 

10 white bass); and Ictaluridae (e.g., catfish, bullhead, madtom). About half of the species are “Big11 River species,” meaning that they occur primarily in the main channel. Lists of species from the 

12 Missouri River can be found in Galat et al. (2005a) and USACE (2003, as reproduced in the 

13 ER). 

14 Galat et al. (2005a) present summary data from which the NRC staff made several 

15 observations. The study lists 53 species as prevalent or common in the Central Lowlands 

16 physiographic province that includes CNS-1. The species were assigned to mutually exclusive 

17 guilds: most (27 spp.) are macrohabitat generalists and the rest distribute evenly between fluvial 

18 specialists and fluvial dependents (12 species each). The generalists may inhabit either 

19 reservoirs or river segments that connect them, while the other two groups are either 

20 specialized for or dependent on flowing river habitat. The high proportion of generalists reflects 

21 the variability and history of continued change in the Missouri River system. In terms of habitat, 

22 46 of the prevalent fish species in the Central Lowlands have been found in the channel and 

23 channel borders, 9 in floodplains, and 8 in reservoirs, including the species that can be found in 

24 more than one of these habitats. The high proportion found in the channel and channel border 

25 reflects the history of the river as a flowing water body before regulation and formation of 

26 reservoirs. With the main channel and channel borders, 35 species are associated with the main 

27 channel, 9 with channel borders, and 8 are “waifs,” that is, removed from their original habitats. 

28 CNS-1 is located below the Gavins Point Dam, the last of the six major dams, in a riverine 

29 environment that extends unimpeded to the mouth of the Missouri River at St. Louis. The upper 

30 section of this reach is unchannelized north of Sioux City, Iowa with such diverse habitat 

31 characteristics as chutes, backwater marshes, sandbars, islands, snags, deep pools, and 

32 variable current velocities. The environment is changing due to the downstream effects of 

33 Gavins Point Dam and the sedimentation that occurs behind it as well as some armoring of the 

34 riverbed and bank stabilization, which cause channel degradation and siltation of shallow areas, 

35 with associated loss of marshes, backwaters and chute habitats (USACE, 2004, p.100). 

36 Downstream of Sioux City, construction of dikes, revetments and channelization result in a less 

37 diverse environment. Yet, the most common fish species are similar in the unchannelized and 

38 channelized portions of the river. These include emerald shiner (Notropis antheroides), river 

39 carpsucker (Carpiodes carpio), channel catfish (Ictalurus punctatus), gizzard shad (Dorosoma 

40 cepedianum), red shiner (Notropis lutrensis), shorthead redhorse (Moxostoma macrolepidotum), 

41 common carp (Cyprinus carpio), and goldeye (Hiodon alosoides). Big river fish in the lower river 

42 and its major tributaries include pallid (Scaphirhynchus albus), shovelnose sturgeon 

43 (Scaphirhynchus albus), and paddlefish (Polyodon spathula) (USACE, 2004). 

44 The aquatic community, particularly the fish community, may not be stable and may still be 

45 changing in response to historical changes in land use, river regulation, and other human 

46 activities. For example, USACE (2004) reports that the benthic fish community appears to be 

47 changing based on 1996 and 1997 studies. The diversity of species in the unchannelized 
Affected Environment 

Draft NUREG-1437, Supplement 41 2-36 February 2010 

1 section appears to be increasing, possibly due to the diverse habitats. Typically more species 

2 are found at shallow depth (less than 2 meters) and slower water velocities (less than 

3 0.6 m/sec), and fish in the unchannelized section are most abundant in the backwater areas. In 

4 the channelized segment below Sioux City, most fish near revetments and dikes. Although 

5 surveys have found the most fish in this segment in side channels, but few such habitats 

6 remain. USACE (2004) reported that ecologists know very little of the mechanisms that control 

7 fish production in the channelized segment of the river. 

8 Other investigators have reached similar conclusions. Rabeni (1996) found that “[d]rastic 

9 changes in the streams and rivers of the prairie region and their fish fauna have occurred in the 

10 last 150 years.” More recently, NRC (2003) reported that: 

11 The aquatic resources in the vicinity of Fort Calhoun Station are associated with 

12 the Missouri River. The species composition of the fish community in this reach 

13 of the river has changed significantly (due to channelization) from the 1973 to 

14 1977 fish studies associated with the initial licensing of Fort Calhoun Station and 

15 its operations. 

16 2.2.6 Terrestrial Resources 

17 The CNS-1 site is located within the Missouri alluvial plains level IV ecoregion in Nebraska and 

18 Missouri, and lies near the western limit of a relatively flat, 6-mile-wide (10 km) alluvial 

19 floodplain. Natural relief on the CNS-1 site is limited to about 10 feet (3 m). Much of this 

20 floodplain has been ditched and drained for farming, with numerous levees constructed for flood 

21 protection. Immediately west of the CNS-1 site and running north-south are bluffs rising 

22 approximately 170 feet (52 m) above the CNS-1 property and the Missouri River (NPPD, 2008) 

23 that transition into the Nebraska/Kansas loess hills level IV ecoregion (USGS, 2001). 

24 According to the ER, the CNS-1 facilities are located within 55 acres (22 ha) of a 1,121-acre 

25 (454 ha) site in Nemaha County, Nebraska, adjacent to the western bank of the Missouri River 

26 at RM 532.5. There is an additional 239 acres (97 ha) of undeveloped CNS-1 property across 

27 the Missouri River and adjacent to its east bank in Atchison County, Missouri. The CNS-1 

28 property in Nebraska is bordered on the west by Nemaha County Road 648A Avenue, the 

29 Missouri River on the east, and by agricultural lands on the north and southsides. The CNS-1 

30 property in Missouri is adjacent to the eastern bank of the Missouri River and is bordered by 

31 cropland on its north, south, and east sides (Figure 2.2.1-1) (NPPD, 2008). 

32 On the Nebraska side of the CNS-1 site, approximately 900 acres (364 ha) are currently used 

33 for agricultural activities. There are also more than 120 additional acres (49 ha) of vegetated, 

34 non-agricultural land located primarily contiguous with the riverbank but extending inland in 

35 some areas into the farm fields on the site. Most of these vegetated areas are classified as 

36 palustrine forested, scrub-shrub, and emergent wetlands (USFWS, 2009a) and include two 

37 segments of intermittent streams and, according to NPPD staff, a 55-acre (22 ha) wetland 

38 mitigation site. One wetland area is located in the middle of a farm field in the south-central part 

39 of the property (Figure 2.2.6-1). The USFWS has identified over 700 wetlands within a 6.0-mile 

40 (10 km) radius of CNS-1 (USFWS, 2007b). The remaining acreage on the Nebraska side 

41 includes the riverbank, streams and canals, and transmission line corridors. Several segments 

42 of intermittent streams are subject to plowing, which may impact wetland resources (NPPD 

43 2008a). NPPD staff noted that these intermittent streams drain south from the CNS-1 site into 

44 the adjacent USACE Langdon Bend Wetlands Restoration Project and into the Little Nemaha 

45 River, and finally into the Missouri River (NDNR, 2009). The Langdon Bend project is one 
Affected Environment 

February 2010 2-37 Draft NUREG-1437, Supplement 41 

1 component of the larger Missouri River Mitigation Project (USACE, 2004b). Additional surface 

2 water at the CNS-1 site drains from the wetlands and fields directly into the Missouri River by 

3 way of manmade drainage ditches and into the Little Nemaha River by way of the intermittent 

4 tributary system. However, NPPD staff indicated that the farm fields and wetland areas still 

5 flood, primarily from overland drainage, and occasionally because of overbank flow from the 

6 Missouri River. 

7 NPPD staff indicated that a system of levees on the Nebraska side of the CNS-1 site is 

8 designed to protect the CNS-1 reactor and support buildings from a 200-year flood event. 

9 Additional levees have been constructed along both sides of the Missouri River floodplain 

10 through the entire CNS-1 site. Levee construction on the Missouri River was initiated in 1945 as 

11 part of a Federal project implemented in 1912 to deepen and widen the Missouri River for 

12 navigation purposes. Earthen levees were constructed along the eastern border of the CNS-1 

13 property located in Missouri. 

14 On the Nebraska side of the river, the alluvial bottomland and rolling floodplains are dominated 

15 by cottonwood (Populus deltoides), green ash (Fraxinus pennsylvanica), boxelder (Acer 

16 negundo), elm (Ulmus spp.), lowland tallgrass prairie, big bluestem (Andropogen gerardii), 

17 prairie cordgrass (Spartina pectinata), switchgrass (Panicum virgatum) and several sedges 

18 (USGS, 2001). 

19 In Missouri on the CNS-1 property, approximately 200 acres (81 ha) of the 239 acres (97 ha) 

20 are classified as palustrine forested wetlands and flood periodically. NRC staff noted during the 

21 site audit evidence of flood water from the Missouri River reaching over four feet high on some 

22 trees on the Missouri side of the CNS-1 property. The two transmission line corridors running 

23 east-west through the Missouri property (not in scope) are primarily emergent wetlands where 

24 the transmission lines do not cross cropland. Less than 40 acres (16 ha) of the 239 acres (97 

25 ha) have been cleared and are used for agricultural activities (NPPD, 2008). 

26 The forested riparian areas on the Missouri side of the CNS-1 property are dominated by 

27 cottonwood, American sycamore (Platenus occidentalis), silver maple (Acer sacharrinum), black 

28 willow (Salix nigra), boxelder, buttonbush (cephalanthus occidentalis), and false indigo 

29 (Amorpha fruticosa) (NRCS, 2007). The two transmission line corridors located on the Missouri 

30 side are dominated primarily by emergent wetlands vegetation, similar to the grasses described 

31 on the Nebraska side, as well as some scrub-shrub wetlands vegetation. 

32 Several exotic invasive plant species are located along the riverbank of the CNS-1 site, and 

33 include purple loosetrife (Lythrum salicaria) and reed canary grass (Phalaris arundinacea) 

34 (NRCS, 2007). The common reed (Phragmites austrailis) is another exotic invasive species 

35 found along the riverbank in the vicinity of the CNS-1 site that was recently added to the list of 

36 noxious weeds by the Nebraska Department of Agriculture (NDA, 2008). 

37 While much of the CNS-1 site and vicinity is agricultural land, there are a number of wooded 

38 areas and hedgerows that provide habitat for several species of mammals common to this 

39 region, including coyote (Canis latrans), white-tailed deer (Odocoileus virginianus), raccoon 

40 (Procyon lotor), eastern cottontail rabbit (Sylvilagus floridanus), muskrat (Ondatra zibethicus), 

41 mink (Mustela vison), bobcat (Lynx rufus), mice (Bailey, 2007). 

42 The CNS-1 site provides habitat to a variety of game birds and resident and neo-tropical 

43 migratory songbirds primarily along the transmission line corridor and within the wooded 

44 wetland and scrub-shrub habitat on both sides of the river, some of which were observed by 
Affected Environment 

Draft NUREG-1437, Supplement 41 2-38 February 2010 

1 NRC staff during the site audit. Species of game birds that are commonly found in the vicinity of 

2 CNS-1 include the northern bobwhite quail (Colinus virginianus), the ring-necked pheasant 

3 (Phasianus colchicus), the wild turkey (Meleagris gallopavo), and the greater prairie chicken 

4 (Tympanuchus cupido). Other birds commonly found on CNS-1 property and the transmission 

5 line corridor include cliff swallows (Petrochelidon pyrrhonota), the American kestrel (Falco 

6 sparverius), the turkey vulture (Cathartes aura), the killdeer (Charadrius vociferus), the horned 

7 lark (Eremophila alpestris), and the American bald eagle (Halieatus leucocephalus) (Bailey, 

8 2007; UNSM, 2007a). There is an active bald eagle nest on the Missouri side of the CNS-1 

9 property with a breeding pair of eagles that have produced a number of chicks over the past 

10 several years (NPPD, 2008). Although no longer protected under the ESA, the bald eagle is still 

11 protected from any take without a permit under the Bald and Golden Eagle Protection Act (50 

12 CFR Part 22) (NPPD, 2008). 

13 

14 Figure 2.2.6-1. Nontidal Wetlands Located on the Cooper Nuclear Station, Unit 1, Site 

15 (Source: USFWS, 2009a; National Wetlands Inventory; Nemaha Quad; NPPD, 2008a). (Note 

16 that the wetlands polygon is approximate, and includes the 55-acre (22-ha) NPPD wetlands 

17 mitigation site.) 

18 The CNS-1 is located along an overlapping section of the Mississippi and Central Flyways, with 

19 20 waterfowl species following the Missouri River during fall and spring migrations. These 

20 waterfowl may utilize the wetlands located on the CNS-1 site (NPPD, 1971) and its vicinity. The 

21 ER contains information on observed bird mortality at CNS-1 from 2003–2006, including a great 
Affected Environment 

February 2010 2-39 Draft NUREG-1437, Supplement 41 

1 horned owl (Bubo virginianus), three additional birds, and the death in 2006 from West Nile 

2 Virus of a juvenile bald eagle found near CNS-1 (NPPD, 2008). 

3 Several amphibians and reptiles are found or are potentially found in the vicinity of CNS-1 and 

4 the transmission line corridor. Reptiles include the painted turtle (Chrysemys picta), the common 

5 snapping turtle (Chelydra serpentine), the eastern rat snake (Elaphe obsoleta), two species of 

6 garter snakes (Thamnophis spp.), and the prairie kingsnake (Lampropeltis calligaster). 

7 Amphibians include the Cope’s gray treefrog (Hyla chrysoscelis), the northern cricket frog (Acris 

8 crepitans), the northern leopard frog (Rana pipiens), and the bullfrog (Rana catesbeiana) 

9 (UNSM, 2007b). 

10 2.2.7 Protected Species 

11 National Marine Fisheries Service (NMFS) and USFWS are responsible for listing aquatic and 

12 terrestrial species as threatened and endangered at the Federal level, as delegated by the ESA. 

13 The State may list additional species that are regionally threatened or endangered. For the 

14 purposes of this Supplemental EIS, we have included all Federally and State-listed species that 

15 occur or potentially occur in Nemaha County, Nebraska (the location of CNS-1) and Johnson, 

16 Gage, Lancaster, Saline, Fillmore, York, Hamilton, and Merrick Counties, Nebraska, as well as 

17 Atchison County, Missouri (Illinois Wildflowers, 2009; Kansas Wildflowers and Grasses, 2009; 

18 MOBOT, 2009; MDC, 2009b; MDC, 2009c; Missouri Plants, 2007; NatureServe, 2009d; 

19 NatureServe, 2009e; NGPC, 2008; NGPC, 2009c; NPPD, 2008a; NRCS, 2009; USFWS, 2008a; 

20 USFWS, 2009b; USGS, 2006; USGS, 2008; UWYO, 2002), where transmission line corridors 

21 associated with CSN-1 lie (Table 2.2.7-1). On January 15, 2008, the NPPD contacted the 

22 USFWS regional offices in Nebraska and Missouri, the NGPC, and the MDC regarding any 

23 concerns these Federal and State natural resources agencies may have as a result of the 

24 license renewal action as CNS-1. The NGPC has not commented upon potential impacts to 

25 Federally or State-listed threatened or endangered species, but has provided an updated list of 

26 Nebraska species of concern (NGPC, 2009c). 

27 Table 2.2.7-1. Listed Aquatic and Terrestrial Species 

28 The species listed are Federally-listed, Nebraska-listed and/or Missouri-listed as threatened, 

29 endangered, or State species of concern (SC). State SC may be further classified as S-1, S-2, 

30 S, or SX as described at the bottom of this table. The listed species may occur on the CNS-1 

31 site or in its vicinity, within the Missouri River, or within the transmission line corridors. 

32 

Scientific Name Common 

Name 

Federal 

Statusa State Statusb,c

Habitat 

Fish 

Acipenser fulvescens Lake sturgeon - T (NE) Large turbid rivers 

Cycleptus elongates Blue sucker - T (NE) Rivers 

Fundulus zebrinus Plains killifish - SC (MO) Streams and lakes 

Hybognathus argyritis Western 

silvery 

minnow 

- SC (MO) Creeks and backwaters 

Hybognathus placitus Plains minnow - SC (MO) Perennial plains streams 
Affected Environment 

Draft NUREG-1437, Supplement 41 2-40 February 2010 

Scientific Name Common 

Name 

Federal 

Statusa State Statusb,c

Habitat 

Macrhybopsis meeki Sicklefin chub - T (NE) Free-flowing rivers with high 

turbidity 

Macrhybopsis gelida Sturgeon chub - E (NE) Free-flowing rivers with high 

turbidity 

Platygobio gracilis Flathead chub - E (MO) Main stem Missouri River and 

small streams 

Scaphirhyncus albus Pallid 

sturgeon 

E E Main stem Missouri and 

Mississippi rivers 

Reptiles and Amphibians 

Agkistrodon contortrix Copperhead - S2 (NE) In or near deciduous forest in 

hilly situations; vicinity of rock 

outcrops; floodplains; mesic 

situations near water in the arid 

west. 

Ambystoma texanum Smallmouth 

salamander 

- S1 (NE) Adults migrate from upland, 

mesic forests to breed in 

fishless, seasonal, and 

semipermanent wetlands. 

Carphophis vermis Western 

wormsnake 

- S2 (NE) Woodlands; forest edge; moist, 

rocky, hillsides; riparian 

corridors in prairies; burrowing 

in or using soil, fallen logs, 

debris. 

Crotalus horridus Timber 

rattlesnake 

- S1 (NE) Riparian; forested and scrubshrub wetlands; high, dry 

ridges; hilltop rock outcrops in 

thick woods. 

Elaphe vulpina vulpine Western fox 

snake 

- E (MO) Farmlands, prairies, stream 

valleys, woods, and dune 

habitats. 

Eumeces obsoletus Great plains 

skink 

- S2 (MO) Open plains; rolling grasslands 

with few trees and scattered 

rocks. Takes refuge under 

rocks, logs; other cover. 

Lampropeltis calligaster Yellow-bellied 

kingsnake 

- S2 (NE) Prairies, (including sand 

prairies), open grassland, forest 

edge; fields; ditches; 

woodlands; stream valleys and 

bluffs. 

Lampropeltis getula Common 

kingsnake 

- S1 (NE) Open coniferous forest; prairie; 

desert; woodland; swamps; 

coastal marshes; river bottoms; 

farmland; chaparral. 

Liochlorophis vernalis Smooth green 

snake 

- S1 (NE) 

SX (MO) 

Meadows, grassy marshes, 

moist grassy fields at forest 

edges, stream borders; 

mountain shrublands, bogs, 

abandoned farmland; vacant 

lots. Extirpated in MO. 
Affected Environment 

February 2010 2-41 Draft NUREG-1437, Supplement 41 

Scientific Name Common 

Name 

Federal 

Statusa State Statusb,c

Habitat 

Ophisaurus attenuatus Slender glass 

lizard 

- S1 (NE) Open grassland; prairie; open 

and woodland edge; scrubby 

areas; fallow fields; near 

streams and ponds; often in 

habitats with sandy soil. 

Rana pipiens Northern 

leopard frog 

- S2 (MO) Springs, slow streams, 

marshes, bogs, ponds, canals, 

flood plains, reservoirs, and 

lakes; permanent water with 

rooted aquatic vegetation; wet 

meadows and fields. 

Overwinters usually 

underwater. 

Regina grahamii Graham's 

crayfish snake

- S2 (NE) Sluggish and still waters and 

their vegetated margins; 

marshes, swamps; roadside 

ditches. 

Sistrurus catenatus Massasauga 

rattlesnake 

- T (NE) 

E (MO) 

Wetlands, 

grassland/herbaceous, old field, 

savanna, shrubland/chaparral, 

woodlands. 

Thamnophis proximus Western 

ribbonsnake 

- S2 (NE) Semiaquatic. Wide range 

shrubby habitats near lakes, 

ponds, sloughs, ditches, 

swamps, and marshes. 

Birds 

Ammodramus henslowii Henslow's 

sparrow 

- S2 (NE) Grassland; open fields and 

meadows; shrubby vegetation; 

damp or low-lying areas. 

Bonasa umbellus Ruffed grouse - SX (NE) Presumed extirpated. Dense 

forest with some deciduous 

trees; both wet and relatively 

dry situations. 

Charadrius melodus Piping plover T T (NE) Sandy upper beaches with 

sparse vegetation, sparsely 

vegetated shores and islands of 

shallow lakes, ponds, rivers, 

and impoundments. 

Falco peregrinus Peregrine 

falcon 

- S1 (NE) 

S1 (MO) 

Various open situations with 

suitable nesting cliffs; tall 

buildings with ledges. Nonbreeding – occurs in farmlands, 

marshes, lakeshores, river 

mouths, tidal flats, urban areas.

Grus American Whooping 

crane 

E E (NE) Wetlands, wet meadows, 

sandbars and shallow water in 

rivers. 

Lanius ludovicianus Loggerhead 

shrike 

- S2 (MO) Open country with scattered 

trees and shrubs, savanna, 

desert scrub, open woodland; 

often perches on poles, wires 

or fence posts. 
Affected Environment 

Draft NUREG-1437, Supplement 41 2-42 February 2010 

Scientific Name Common 

Name 

Federal 

Statusa State Statusb,c

Habitat 

Laterallus jamaicensis Black rail - S1 (NE) 

S1 (MO) 

Breeding and non-breeding: 

shallow portions of salt, 

brackish, and freshwater 

marshes; pond borders; wet 

meadows; and grassy swamps. 

Numenius borealis Eskimo curlew E SX (NE) Possibly extinct. Non-breeding: 

grasslands; pastures; plowed 

fields; and less frequently, 

marshes and mudflats. Nests in 

open Arctic tundra. 

Rallus elegans King rail - S1 (NE) 

S1 (MO) 

Freshwater marshes, uplandwetland marsh edges, flooded 

farmlands, shrub swamps. 

Sterna antillarum athalassos Interior least 

tern 

E E (NE) 

S1 (MO) 

Bare sand bars and sandy 

shorelines of large rivers, lakes 

and sand pits. 

Strix varia Barred owl - S2 (NE) Dense woodland and forest, 

swamps, wooded river valleys. 

Thryothorus ludovicianus Carolina wren - S2 (NE) Open deciduous woodland; 

thickets; undergrowth; parks; 

forest edge; pine barrens; 

shrubbery of residential areas. 

Tryngites subruficollis Buff-breasted 

sandpiper 

- S1 (NE) Migratory through NE. Short 

grass plains and dry uplands. 

Man-altered habitats – fields; 

golf courses; runways. 

Mammals 

Glaucomys volans Southern 

flying squirrel 

- T (NE) Red oak-basswood-ironwood 

forest. 

Lontra canadensis River otter - T (NE) Streams, lakes, ponds, 

swamps, marshes, estuaries (in 

some areas), exposed outer 

coast. 

Microtus pinetorum Woodland 

vole 

- S1 (NE) Wide variety of habitats; prefers 

upland wooded areas with thick 

layer of loose soil and humus in 

shallow burrows. 

Mustela nigripes Black-footed 

ferret 

E E (NE) Limited to open habitat and 

burrows used by prairie dogs: 

grasslands and shrub steppe. 

Perognathus flavescens Plains pocket 

mouse 

- S2 (MO) Tallgrass prairie, sandy-loose 

soil prairies. 

Spermophilus franklinii Franklin’s 

ground 

squirrel 

- S2 (MO) Tallgrass and mid-grass 

prairies; riparian areas; forestfield edges, fields, hedgerows, 

unmowed strips of railroad 

rights-of-way and roadsides. 

Spilogale putorius interrupta Plains spotted 

skunk 

- S1 (NE) 

E (MO) 

Forested areas; habitats with 

significant cover; open and 

brushy areas; rocky canyons 

and outcrops in woodlands and 

prairies 
Affected Environment 

February 2010 2-43 Draft NUREG-1437, Supplement 41 

Scientific Name Common 

Name 

Federal 

Statusa State Statusb,c

Habitat 

Myotis sodalis Indiana bat E E (MO) Hibernates in caves; foraging 

habitats include riparian areas, 

upland forests, ponds, and 

fields. 

Insects 

Atrytone arogos iowa Iowa skipper - S1 (NE) Short grass prairie in Colorado 

to mesic or dry tall grass 

prairie. 

Cicindela nevadica linolnaina Salt Creek 

tiger beetle 

E E (NE) Eastern Nebraska saline 

wetlands and their associated 

streams. 

Cicindela togata White-cloaked 

tiger beetle 

- S1 (NE) Very open saline areas far from 

vegetation. Salt flats, salt 

marshes, saline lakeshores. 

Melanoplus packardii Packard’s 

grasshopper 

- S2 (MO) Bare, somewhat grassy 

beaches; sandy woods, always 

on dry sand and not on 

vegetation. 

Nicrophorus americanus American 

burying beetle

- S1 (NE) 

SH (MO) 

Broad vegetational tolerances. 

Mature forest; grassland; old 

field shrubland. 

Plants 

Agalinis purpurea Large-purple 

false foxglove

- S1 (NE) Moist sand prairies; sandy 

savannas, paths and openings 

in sandy woodlands; boggy 

areas; occasional disturbance. 

Anagallis minima Chaffweed - S1 (NE) Bare damp ground, by 

roadsides. 

Anemone cylindrical Thimbleweed - S2 (MO) Dry open woods, slopes, 

prairies, along railroad grades. 

Arisaema dracontium Green dragon - S2 (NE) Moist deciduous woodlands; 

shady seeps; and wooded 

areas adjacent to springs and 

vernal pools. 

Arnoglossum atriplicifolium Pale Indianplantain 

- S2 (NE) Full to partial sun; prairies, 

woods; in sandy, loamy soil. 

Asclepias amplexicaulis Clasping 

milkweed 

- S1 (NE) Prairies; glades; rocky open 

woods; roadsides; railroads. 

Asclepias purpurascens Purple 

milkweed 

- S1 (NE) Rocky open woods, glades; 

prairies; stream banks; wet 

meadows; valleys; thickets; 

roadsides. 

Astragalus lotiflorus Low milk 

vetch 

- S2 (MO) Dry native prairie in areas 

where the shortgrasses like 

blue grama grow. 

Bidens polylepis Awnless 

beggar-ticks 

- S2 (NE) Wet prairies and meadows; 

swampy woods; roadsides; 

disturbed grounds. 

Blephilia hirsuta Hairy 

Woodmint 

- S1 (NE) Rich, moist, shady woods, 

slopes and valleys. 
Affected Environment 

Draft NUREG-1437, Supplement 41 2-44 February 2010 

Scientific Name Common 

Name 

Federal 

Statusa State Statusb,c

Habitat 

Bouteloua gracilis Blue grama - S1 (MO) Dryish soils on upland short 

grass prairies and along 

railroad tracks. 

Bouteloua hirsute var. hirsuta Hairy grama - S2 (MO) Shortgrass prairies. 

Brachyelytrum erectum Bearded 

shorthusk 

- S2 (NE) Mesic upland forests; 

bottomland forests; occasional 

dry upland forest. 

Buchloe dactyloides Buffalo grass - SH (MO) Possibly extirpated 

Carex bushii Bush's sedge - S1S2 (NE) Moist prairies, fields, and 

meadows in full sun (ODNR 

1998). 

Carex crus-corvi Ravenfoot 

sedge 

- S1 (NE) Wet meadows and swamps 

(MSU 2007). 

Carex frankii Frank's sedge - S1S2 (NE) Edges of wet woods; 

seasonally wet meadows (USU 

2006). 

Carex sprengelii Longbeak 

sedge 

- S1 (MO) Moist soil on bottomlands and 

streambanks; cliffs and rocky 

slopes. 

Castilleja sessiliflora Downy 

painted cup 

- S2 (MO) Dry prairies and rocky hillsides.

Coeloglossum viride Long-bract 

Green orchis 

- S1 (NE) Sub-arid soil in damp open 

woods; mesic to wet 

woodlands, thickets and shrub 

boarders; disturbed areas. 

Corallorhiza wisteriana Spring 

coralroot 

- S1 (NE) Terrestrial in moist hardwood 

forests and hammocks. 

Mycorrhizal with fungi. 

Cornus racemosa Gray dogwood - S1 (NE) Thickets and moist soil in 

riparian zones, roadsides, on 

sandy slopes and limestone 

ridges. 

Corydalis aurea Golden 

Corydalis 

- S1 (NE) Rocky or sandy soils along 

lakes or ponds or in open 

woods. 

Cypripedium calceolus Yellow lady'sslipper 

- S1 (NE) Rich, humus and decaying leaf 

litter in wooded areas, often on 

rocky wooded hillsides. 

Cypripedium candidum Small white 

lady’s slipper 

- T (NE) 

S1 (MO) 

Mesic/wet blacksoil prairie; 

glacial till hill prairie, sedge 

meadow, glade. Calcareous 

soils. Extirpated/possibly 

extirpated in MO. 

Dalea enneandra Nine-anther 

dalea 

- S2 (MO) Grassland and prairie. 

Dasistoma macrophylla Mullein 

foxglove 

- S1 (NE) Rich woodlands, often along 

streams. 

Desmodium cuspidatum Toothed ticktrefoil 

- S2? (NE) Dry or rocky woods; thickets; 

bluffs; base of slopes; ridges; 

ravines; valleys. 
Affected Environment 

February 2010 2-45 Draft NUREG-1437, Supplement 41 

Scientific Name Common 

Name 

Federal 

Statusa State Statusb,c

Habitat 

Dracocephalum parviflorum American 

dragonhead 

- S1 (NE) Woodland; shrublands; 

openings. 

Eleocharis atropurpurea Purple 

spikerush 

- S1 (NE) 

S1 (MO) 

Banks; hammocks; irrigation 

ditches; lake and pond margins.

Eleocharis wolfii Wolf's 

spikerush 

- S2 (NE) Marshes, wet to wet-mesic 

prairies, wetland margins; wet 

ditches, sandy roadsides, mud 

flats. 

Erysimum inconspicuum Small-flower 

prairie 

wallflower 

- S2 (NE) Dry native prairie; found where 

grazing is light or moderate. 

Erythronium mesochoreum Midland 

fawnlily 

- S2 (NE) Prairies and open woods; 

occasionally found in cut-over 

woods. 

Galearis spectabilis Showy orchis - S1 (NE) Floodplains. 

Gastrophryne olivacea Great Plains 

narrowmouth 

toad 

 S2 (NE) Variable. Creeks; pools; 

temporary pools; grasslands; 

rocky wooded hills; rotten logs; 

burrows under rocks. 

Gentiana alba Yellow gentian - S1 (NE) Mesic black soil prairies; upland 

forests; rocky bluffs. 

Helianthemum bicknellii Plains 

frostweed 

- S1S2 (NE) Sandy soil of open woodlands 

and prairie areas. 

Heliotropium curassavicum var. 

curassavicum 

Seaside 

Heliotrope 

- S1 (NE) 

S1 (MO) 

Dry or moist saline and alkaline 

areas; seasonal flooding. 

Isoetes melanopoda Blackfoot 

quillwort 

- S1 (NE) Submerged or in wet soil of 

swales and temporary ponds. 

Lactuca tatarica var. pulchella Blue lettuce - S1 (MO) Plains, foothills, montane; 

meadows, roadside ditches. 

Lespedeza violacea Violet bushclover 

- S1 (NE) Edges of open upland woods, 

roadsides; thickets; rocky 

prairies; dry, rocky soils. 

Leucospora multifida Narrowleaf 

paleseed 

- S1 (NE) Shores and stream banks, 

often where sandy. 

Liatris squarrosa var. hirsuta Glades 

gayfeather 

- S1? (NE) Diverse; including dry, sandy, 

upland prairies. 

Melica nitens Three-flower 

melicgrass 

- S1 (NE) Open woods; moist canyon 

slopes; canyon bottoms; 

roadsides; rocky 

grasslands; streambanks. 

Monotropa uniflora Indian-pipe - S1 (NE) Non-green herb parasitic on 

roots of pines. 

Neeragrostis reptans Hairy creeping 

lovegrass 

- S1 (NE) 

SH (MO) 

Wet sandy or muddy stream 

banks and alluvial bar. 

Nothocalais cuspidate Prairie 

dandelion 

- S2 (MO) Dry upland areas of prairies, hill 

prairies, and rocky slopes. 

Nymphaea odorata American 

water-lily 

- S2 (NE) Lakes; lake margins; ponds; 

quiet bays in lakes and rivers; 

slow-moving streams; ponds. 
Affected Environment 

Draft NUREG-1437, Supplement 41 2-46 February 2010 

Scientific Name Common 

Name 

Federal 

Statusa State Statusb,c

Habitat 

Orobanche uniflora One-flowered 

broomrape 

- S1 (NE) Parasitic. Wooded slopes; 

lowland; rocky base of bluffs. 

Oxytropis lambertii var. lambertii Locoweed - S2 (MO) Extirpated/possibly extirpated. 

Packera glabella Grassleaf 

ragwort 

 S1 (NE) Moist-to-wet habitat. (UT 2009)

Panax quinquefolium American 

ginseng 

- T (NE) Rich, cool, moist but not 

extremely wet woods, under a 

closed canopy; slopes; ravines.

Paronychia canadensis Forked 

nailwort 

- S1 (NE) Dry sandy or rocky places. 

Pediomelum argophyllum Silvery 

psoralea 

- S2 (MO) Moist prairies, rocky hillsides, 

lowlands, stream valleys, and 

open woodlands. 

Pellaea atropurpurea Purple-stem 

cliffbrake 

- S2 (NE) Crevices of rock outcrops, 

bluffs and boulders; sinkholes; 

dry soils adjacent to dolomite 

glades. 

Penstemon grandiflorus Large beardtongue 

- S1 (MO) Prairie bluffs in open grassy 

places. 

Penstemon tubiflorus White-wand 

beardtongue 

- S1 (NE) Rich loam or sand loam soil 

from open prairies to deciduous 

forests; disturbed areas; rocky 

glades; along railroads. 

Platanthera praeclara Western 

prairie fringed 

orchid 

T T (NE) 

E (MO) 

Tallgrass prairie; moist, 

calcareous or subsaline prairies 

and sedge meadows (many 

flooded for a period of 1-2 

weeks during the year). 

Podophyllum peltatum Mayapple - S2 (NE) Rich cove forests; mesic 

hardwood forests; low 

topographic positions. 

Quercus alba White oak - S1 (NE) Deciduous forests; mesic; 

bottomland soil. 

Ruellia strepens Limestone 

wild petunia 

- S2 (NE) Moist woods, around ponds 

and lakes, along streams. 

Salicornia rubra Western 

glasswort 

- S1 (NE) Saline or alkaline soil of flats, 

shores, seepage areas and 

ditches. 

Schoenoplectus saximontanus Rocky 

Mountain 

bulrush 

- S1 (NE) 

S1 (MO) 

Damp soils to emergent, 

freshwater ponds; ditches, 

often drying; disturbed and 

sandy areas. 

Senna marilandica Maryland 

senna 

- S1S2 (NE) Prairie ravines, open woods, 

thickets, disturbed areas, and 

bases of slopes and bluffs; dry, 

gravelly soils. 

Sparganium chlorocarpum Greenfruit burreed 

- S2 (NE) Shallow water or mud of 

marshes, streams, ditches and 

ponds, where the water is fairly 

fresh. 
Affected Environment 

February 2010 2-47 Draft NUREG-1437, Supplement 41 

Scientific Name Common 

Name 

Federal 

Statusa State Statusb,c

Habitat 

Spiranthes vernalis Twisted 

ladies'-tresses

- S2? (NE) Moist open areas, meadows, 

swales, bogs. 

Symphoricarpos occidentalis Wolfberry - S1 (MO) Open prairies, and moist, low 

ground around streams or 

lakes. 

Trifolium reflexum Buffalo clover - S1 (NE) Rocky open woods; glades; old 

fields; prairies. 

Triodanis perfoliata var. biflora Claspingleaf 

Venus'-

looking-glass 

- S1 (NE) Dry sandy or gravelly prairies, 

pastures, waste ground, and 

occasionally woodlands. 

Verbena simplex Narrowleaf 

vervain 

- S1 (NE) Dry, open waste areas, rocky 

prairie hillsides, and roadsides.

Veronicastrum virginicum Culver's-root - S1 (NE) Varied habitats. Moist tallgrass 

prairie and prairie remnants, 

moist woods, woodland 

borders, thickets, fields and 

meadows, stream banks and 

terraces. 

Viola palmata Palmateleaved violet 

- S2 (NE) Dry upland woodlands, rocky 

wooded slopes, and thinly 

wooded bluffs. 

Vitis cinerea Pigeon grape - S1 (NE) Low woods, floodplains, along 

streams, marshes, 

bottomlands. 

Yucca glauca Small 

soapweed 

yucca 

- S2 (MO) Loess hill prairies. 

a 1 E = Endangered; T = Threatened 

b 2 NE = Nebraska; MO = Missouri 

c 3 S = State listing; S1 = critically imperiled; S2 = imperiled; SX - presumed extirpated; SH - possibly extirpated. Note 

4 that S3 species (“vulnerable”) are not included in this list in order to maintain a less-expansive list. 

5 Sources: NGPC, 2008; NGPC, 2009c; MDC, 2009b; MDC, 2009c; USFWS, 2008a; USFWS, 2009b; University of 

6 Wisconsin (UW), 2009. 
Affected Environment 

Draft NUREG-1437, Supplement 41 2-48 February 2010 

1 2.2.7.1 Aquatic Species 

2 Table 2.2.7-1 presents aquatic species that are listed as protected by the USFWS, the State of 

3 Nebraska, and the State of Missouri that have the potential to occur in counties near CNS-1 or 

4 along the transmission corridors. One fish species is listed by USFWS for Nemaha County, 

5 Nebraska: the pallid sturgeon (Scaphirhynchus albus) (USFWS, 2007). Regarding State-listed 

6 species, Hesse et al. (1982) report the identification of several fish species then listed as 

7 threatened or endangered by Iowa, Missouri, or Nebraska, based on studies from 1971 through 

8 1977 from the channelized Missouri River in the reach from Fort Calhoun Station to CNS-1. 

9 These included skipjack herring (Alosa chrysochloris, listed in Iowa), sturgeon chub 

10 (Macrhybopsis gelida, listed in Iowa and Missouri), blue sucker (Cycleptus elongates, listed in 

11 Missouri), plains killifish (Fundulus kansae, listed in Missouri), and burbot (Lota lota), listed in 

12 Missouri). Of these, they collected a single sturgeon chub (in 1977), three plains killifish (in 

13 1971), ten burbot, and consistent low numbers of blue suckers near CNS-1. MDC (2009) no 

14 longer lists sturgeon chub, plains killifish or burbot, and Iowa no longer lists the sturgeon chub 

15 (Iowa Administrative Code, Chapter 77). Fish species that the States of Missouri and Nebraska 

16 currently list and that Hesse et al. (1982) collected near CNS-1 or in the reach between CNS-1 

17 and FCS in the 1971 though 1977 studies include sturgeon chub, blue sucker, and plains 

18 killifish. NRC staff did not find more recent data on fish species living in the Missouri River near 

19 CNS-1, but lack of captures does not necessarily indicate absence of uncommon species in any 

20 case. 

21 Life History of Pallid Sturgeon 

22 Sturgeons are members of an order of fish (Acipenseriformes) that probably evolved in the 

23 Devonian age. Living members of this order in North America include the paddlefish and eight 

24 sturgeon species. The paddlefish (Polyodon spathula) and three sturgeon species, the lake 

25 sturgeon (Acipenser fulvescens), pallid sturgeon (Scaphirhynchus albus), and the shovelnose 

26 sturgeon (S. platorynchus), live in the Missouri and Mississippi rivers. In the past, commercial 

27 fishermen harvested all three of the sturgeon species in the Missouri and Mississippi rivers. 

28 Today pallid sturgeon are a Federally-listed endangered species, and lake sturgeon are listed 

29 as endangered by Nebraska. The life history information below is from Dryer and Sandvol 

30 (1993) and USFWS (2007) if not otherwise cited. 

31 Pallid sturgeons have a flattened snout, a long tail, and rows of bony armor plates. The upper 

32 side is convex and the lower side is straight. They have an inferior (bottom-facing) mouth and 

33 eat invertebrates, such as the immature stages of insects, and fish. The body shape is well 

34 adapted swimming close to the bottom of relatively fast flowing, large rivers. The diet, inferior 

35 mouth, and barbels in front of the mouth are well adapted to feeding on or near the bottom in 

36 highly turbid environments. 

37 The USFWS listed pallid sturgeon as endangered in 1990. The historic abundance of pallid 

38 sturgeon is somewhat vague since biologists did not recognize it as a separate species from 

39 shovelnose sturgeon until 1905, but its historical range probably extended from the middle and 

40 lower Mississippi River in the south up through the Missouri River and lower reaches of the 

41 Platte, Kansas, and Yellowstone rivers in the north and west. The pallid sturgeon is one of the 

42 largest fish species in those rivers. Available information suggests that the pallid sturgeon was 

43 not a common species since the time of European settlement. Today pallid sturgeon are among 

44 the rarest fish of the Missouri and Mississippi River basins, and the present range includes the 

45 States of Montana, North and South Dakota, Nebraska, Iowa, Kansas, Missouri, Illinois, 

46 Kentucky, Arkansas, Mississippi, and Louisiana. The populations are largely older fish that will 

47 die off in the near future. 
Affected Environment 

February 2010 2-49 Draft NUREG-1437, Supplement 41 

1 Fisheries biologists know little about pallid sturgeon reproduction or even preferred spawning 

2 habitats and conditions. Hurleya et al. (2004) tracked sonically-tagged pallid sturgeon in the 

3 Mississippi River and found that they exhibited positive selection for the main-channel border, 

4 downstream island tips, between-wing-dam, and wing-dam-tip habitats; they showed negative 

5 selection for main-channel, downstream of wing dams, and upstream of wing dam habitats. The 

6 sturgeon exhibited little habitat selection for temperature or dam discharge. The authors 

7 concluded that habitat enhancement and restoration of habitat diversity might be necessary for 

8 recovery of pallid sturgeon. 

9 Reports of pallid sturgeon reproduction are rare. The USGS (2007), NGPC, and the USACE 

10 confirmed spawning of two female pallid sturgeon in the upstream reaches of the lower Missouri 

11 River in May 2007. The capture of young pallid sturgeon that would verify natural reproduction 

12 are also rare: none were captured between 1978 and a Mississippi River trawl survey in 1998 

13 through 2000 using equipment designed to capture larval fish in deep, turbulent water (Hrabik et 

14 al., 2007). Hrabik et al. (2007) concluded that those latest captures verified reproduction, 

15 possibly from the lower Missouri River to the upper and lower Mississippi River, although they 

16 also found no evidence of recruitment of pallid sturgeon because they captured no juveniles 

17 after 374 trawl hauls that captured over 21,735 fish in that 1998 through 2000 survey. Wildhaber 

18 et al. (2007) suggest that one or more of the following factors may be responsible for the lack of 

19 finding larval pallid sturgeon and of recruitment: lack of successful spawning, low recruitment, 

20 high mortality, ineffective sampling methods, inadequate sampling of drift and settling locations, 

21 or rapid dispersal and washout of sturgeon larvae in the Missouri and Mississippi rivers. Pallid 

22 sturgeon larvae are indistinguishable from those of the congeneric shovelnose sturgeon, which 

23 may also help to explain the paucity of reported collections in the past. Also, the construction of 

24 dams and other structures with resulting habitat change and the elimination of shallow areas in 

25 the river with little or no flow have probably deprived sturgeon of critical nursery areas needed 

26 for the survival of immature sturgeon (MDC, 2009). 

27 Larval pallid and shovelnose sturgeon become strongly photopositive and migrate upwards 

28 toward the light starting the first day after hatching. As a result, they remain far above the 

29 bottom, even at the water surface, and migrate far downriver (Kynard et al., 2002). Cultured 

30 yearling pallid sturgeon in laboratory studies also migrate downstream during summer and fall, 

31 which suggests a two-stage (larval, then yearling) downriver migration in the first year of life. 

32 Adult sturgeons are also highly migratory and often migrate hundreds of miles in a year. 

33 The young of both shovelnose and pallid sturgeon eat invertebrates, but as pallid sturgeon 

34 grow, they become more piscivorous. Gerrity and Guy (2006) found that the diet of juvenile 

35 pallid sturgeon of age 6 and 7 was mostly fish, compared to the diet of shovelnose sturgeon, 

36 which is mainly aquatic insects. Sturgeon chub (Macrhybopsis gelida) and sicklefin chub (M. 

37 meeki) together comprised 79 percent of the number of identifiable fish in juvenile pallid 

38 sturgeon stomachs. Populations of these two cyprinid minnows have declined throughout much 

39 of the Missouri River due to the construction of dams and man’s other alterations of river 

40 habitat. While the population of the piscivorous pallid sturgeon has declined in the Missouri and 

41 Mississippi rivers, the population of its similar, insectivorous congener, shovelnose sturgeon, 

42 has not declined. Gerrity and Guy (2006) concluded that the prevalence of sicklefin chub and 

43 sturgeon chub as a food resource of juvenile pallid sturgeon may help explain the decline of 

44 pallid sturgeon populations and that recovery and management of native cyprinids is a 

45 potentially important step in the recovery of pallid sturgeon. 

46 Male pallid sturgeons are believed to mature at 7 to 9 years after which they spawn at intervals 

47 of 2 to 3 years. Females may reach sexual maturity at 7 to 15 years and spawn at intervals up 
Affected Environment 

Draft NUREG-1437, Supplement 41 2-50 February 2010 

1 to 10 years. Individuals may reach ages of 60 years or more and reach lengths of 6 feet (2 m). 

2 Like many other fish species, the largest individuals are found farthest north in the species’ 

3 range and maximum size decreases with distance south. For example, the maximum weight of 

4 pallid sturgeon in the upper Missouri River in Montana and North Dakota is 86 pounds (39 kg), 

5 in the Missouri River in South Dakota and Nebraska 46 pounds (21 kg), and in the Mississippi 

6 River 26 pounds (12 kg). They become much larger than shovelnose sturgeon, which rarely 

7 weigh more than 8 pounds (3.6 kg). 

8 While they were successful in the historical Missouri and Mississippi rivers, with the high flow 

9 and turbidity and diverse habitats of floodplains, backwaters, chutes, sloughs, islands, sand and 

10 gravel bars, and both braided and main channels, they are not so well adapted to the Missouri 

11 and Mississippi rivers today with the construction of dams that isolated subpopulations, 

12 channelization, controlled flow, and elimination of habitat diversity. USFWS (2007) concludes 

13 that man’s activities have adversely affected all of the 3,350 miles (5,390 km) of river habitat 

14 within their range, and habitat alteration and loss may be the biggest threat to their existence. 

15 Other threats may include hybridization with shovelnose sturgeon, commercial fishing, and 

16 exposure to environmental contaminants such as polychlorinated biphenyls, cadmium, mercury, 

17 selenium, chlordane DDT, DDE, and dieldrin, all of which have been found in pallid sturgeon 

18 tissue in the past. 

19 During the early 1990s, the MDC developed “action plans” for lake and pallid sturgeon with a 

20 goal of reestablishing self-sustaining populations so they can be delisted as endangered 

21 species and ultimately provide limited sport fisheries. These plans stress the restoration of both 

22 species through habitat improvement, artificial propagation, protection, research, management, 

23 and education (MDC, 2009). As part of this effort, the MDC's Blind Pony Fish Hatchery has 

24 raised and stocked over 13,000 fingerling pallid sturgeon and 200,000 fingerling lake sturgeon 

25 into the Missouri and Mississippi rivers (MDC, 2009). In addition to these efforts, the USGS 

26 (Wildhaber et al., 2007) has developed a conceptual life history to organize the understanding 

27 about the complex life history of Scaphirhynchus sturgeons and improve understanding of the 

28 effects of management actions on the ecological requirements of pallid and shovelnose

29 sturgeons. The USFWS’s Pallid Sturgeon Recovery Plan (Dryer and Sandvol, 1993) designated 

30 six recovery priority management areas (RPMAs) for implementation of recovery tasks, and 

31 CNS-1 is located within RPMA 4. 

32 In 2000, the USACE, which provides the primary operation management of the Missouri River, 

33 asked the USFWS for formal consultation under the ESA on the Operations of the Missouri 

34 River Main Stem System, and related Operations of the Kansas River Tributary Reservoirs, and 

35 the Operations and Maintenance of the Missouri River Bank Stabilization and Navigation Project 

36 (USFWS, 2000). The USACE had prepared biological assessments for these projects and 

37 determined that their operations may affect listed species, including the endangered pallid 

38 sturgeon. The USFWS found that the proposed actions were likely to jeopardize the continued 

39 existence of pallid sturgeon, as well as the endangered least tern and threatened piping plover, 

40 though not the then-threatened bald eagle. Working together, the USACE and the USFWS 

41 developed Reasonable and Prudent Alternatives under the ESA to help insure the continued 

42 existence of the three species by returning some natural form and function to sections of the 

43 Missouri and Kansas rivers. Under the Alternatives, the following five actions are designed for 

44 pallid sturgeon: (1) enhance flow by including a spring release from Fort Peck dam and a spring 

45 rise and summer drawdown from Gavins Point dam to provide spawning clues and enhance 

46 aquatic habitat; (2) restore, create, enhance, acquire, or conserve habitat; (3) unbalance the 

47 upper reservoirs, (4) use an adaptive management process combined with monitoring; and (5) 
Affected Environment 

February 2010 2-51 Draft NUREG-1437, Supplement 41 

1 increase pallid sturgeon propagation and augmentation efforts while the habitat and hydrology 

2 improvements are being implemented. 

3 USFWS (2003a, 2003b) issued a Supplemental Biological Opinion that applied only to 

4 operations in 2003 due to a continuing drought. It represented a collaborative effort between the 

5 USFWS and the USACE and considered habitat conditions and new information not considered 

6 in the November 2000 biological opinion. The USACE changed flow regime in the Missouri 

7 River and the USFWS stocked year-old pallid sturgeon, both as interim measures in 2003. 

8 USFWS (2003a, 200b) reported that the long-term survival of pallid sturgeon will depend on a 

9 more natural hydrograph consisting of an increase in spring flows and declining summer flows. 

10 2.2.7.2 Terrestrial Species 

11 Federally Protected Species

12 Eight animal and plant species Federally-listed as threatened or endangered (Table 2.2.7-1) are 

13 known to occur or to potentially occur on terrestrial habitat within the vicinity of CNS-1 or along 

14 the associated in-scope transmission line corridor. The ranges of four of these species, the 

15 Indiana bat (Myotis sodalis), the western prairie fringed orchid (Platanthera praeclara), the 

16 piping plover (Charadrius melodius), and the interior least tern (Sterna antillarum athalassos) 

17 may include the CNS-1 site. The Indiana bat and interior least tern are listed as endangered, 

18 and the western prairie fringed orchid and piping plover are listed as threatened 

19 (USFWS, 2008a; USFWS, 2009b). 

20 Seven Federally-listed species are potentially present along the transmission line corridor, 

21 including the western prairie fringed orchid. The endangered species are the Salt Creek tiger 

22 beetle (Cincindela nevadica lincolniana), the black-footed ferret (Mustela nigripes), the interior 

23 least tern, the Eskimo curlew (Numenius borealis), and the only known wild population of 

24 whooping crane (Grus americana). The Eskimo curlew is extirpated from Nebraska and is 

25 globally extinct or near-extinct. The piping plover is listed as a threatened species and may be 

26 found along the western limit of the transmission line corridor by the Platte River, along with the 

27 interior least tern and whooping crane (NatureServe, 2009e; USFWS 2008a, 2009b, 2009c). 

28 While threatened piping plovers have not been observed along the CNS-1 shoreline, they have 

29 been found along the Missouri River in close proximity to CNS-1 and along the Platte River near 

30 the western limit of CNS-1 transmission line NPPD TL3502 (USFWS 2002, 2009c; NatureServe, 

31 2009a). The piping plover is a small shorebird with a white underbelly and pale brownish upper 

32 parts, with an average length of 6–7 inches (16–18 cm) and a wingspan of about 15 inches (38 

33 cm). The plover has a small black ring around the base of its neck and a black band over its 

34 eyes on its forehead (NatureServe, 2009a, USFWS, 1997). Piping plover habitat includes river 

35 channels, their associated sandbars and islands, and their sparsely vegetated shorelines and 

36 peninsulas (USFWS, 2002). Even though the shoreline along the Missouri River at CNS-1 does 

37 not contain the characteristics required by piping plovers for nesting, but they have been 

38 reported in the vicinity of CNS-1. Critical habitat has been designated for the northern Great 

39 Plains breeding population of the piping plover along portions of the Platte River in Hamilton 

40 County and Merrick County, which is the location of the transmission line crossing of the Platte 

41 River near Grand Island, Nebraska. Critical habitat has also been designated along the Missouri 

42 River near the Nebraska-South Dakota border, but not in the vicinity of the CNS-1 site (NPPD, 

43 2008a; USFWS, 2002). The destruction or degradation of their habitat and poor breeding 

44 success caused by predation are the major reasons for the decline of piping plover populations. 

45 Dam construction and channelization of the Missouri River have caused the loss of sandbar 

46 nesting habitat for the piping plover (USFWS 1997, 2002). 
Affected Environment 

Draft NUREG-1437, Supplement 41 2-52 February 2010 

1 Interior least terns are found along portions of the Missouri River in North Dakota, and also nest 

2 along portions of the Platte River and its tributaries in Hamilton County and Merrick County, 

3 Nebraska, near the western limit of transmission line NPPD TL3502 (NatureServe, 2009b; 

4 NGPC, 2009a). The interior least tern is a swallow-like bird 8–9 inches (22–24 cm) long with a 

5 wingspan of about 20 inches (31 cm). It has a pale gray and white body with a glossy black 

6 crown, and a long black-tipped yellow-orange bill. The interior least tern nests in habitat similar 

7 to that used by piping plovers. Threats to the interior least tern are also similar to those of the 

8 piping plover, with sand and gravel pits now providing some of the only available nesting habitat 

9 for least terns (NGPC, 2009a; USFWS, 2008b). 

10 The current range of the Indiana bat includes Atchison County, Missouri, on the east side of the 

11 Missouri River from CNS-1, but does not include Nebraska (USFWS, 2008a; MDC 2009b, 

12 2009c). The Indiana bat is a medium-sized bat about two inches (5 cm) long and weighing 

13 about one-quarter ounce (7 gm) (NYS DEC, 2009) with a wingspan of about eight inches 

14 (20 cm) and brownish-gray fur (MDC, 2009a). The Indiana bat hibernates in caves during the 

15 winter and migrates to streams and rivers in wooded areas in the summer where they roost 

16 under loose tree bark (NYS DEC, 2009; MDC, 2009a). Critical habitat for the Indiana bat has 

17 been designated in Missouri but not in Atchison County (USFWS, 2008a). A number of factors 

18 have contributed to population declines for the Indiana bat; a primary cause for their decline has 

19 been from humans disturbing bats hibernating in caves during the winter. Stream 

20 channelization, deforestation, and agricultural development threaten the habitat of Indiana bats 

21 in their summer range (MDC, 2009a). 

22 The western prairie fringed orchid occurs both in Nebraska and Missouri. It is found in Otoe 

23 County, located immediately north of Nemaha County, which is the location of CNS-1. It is also 

24 found in Atchison County, Missouri, the location of the Missouri portion of the CNS-1 property 

25 (USFWS 2008a, 2009b). The western prairie fringed orchid produces flower stalks up to about 4 

26 feet (133 cm) tall, with up to 40 one inch (2.5 cm) white flowers, attached to the stalk 

27 (USFWS, 2003; MN DNR, 1991). It grows in moderately wet to wet prairies and meadows and is 

28 occasionally found in old fields and roadside ditches. Habitat loss through conversion to 

29 cropland is the greatest threat to populations of the western prairie fringed orchid 

30 (USFWS, 2003). 

31 The only known existing wild population of whooping cranes migrates along the Platte River at 

32 the western limit of the CNS-1 transmission line corridor near Grand Island. The whooping 

33 crane is a large white crane standing as tall as 5 feet (1.5 m) with a wingspan of 8 feet (2.5 m) 

34 and weighing over 17 pounds (8 kg), making it the largest bird in North America and one of the 

35 three largest cranes in the world (NGPC, 2009b). Adult whooping cranes have a red crown and 

36 black forehead with black primary feathers visible during flight (USFWS, 2009k). Whooping 

37 cranes live and breed in wetlands, and feed primarily on crabs, small fish and other 

38 invertebrates (NGPC, 2009b; NatureServe, 2008a). Whooping cranes declined to the brink of 

39 extinction in the first half of the 20th century mainly caused by a loss of habitat to agriculture, 

40 human disturbance of nesting areas for eggs, and uncontrolled hunting for meat and plumage. 

41 By 1941, only 14 whooping cranes existed (NatureServe, 2008a; NGPC, 2009b). Current 

42 threats to their population include habitat degradation, low productivity associated with drought 

43 and/or winter malnutrition, collisions with power lines along their migration routes, and severe 

44 weather phenomena during nesting season (NatureServe, 2008a; USFWS, 2009c). 

45 There are currently three populations of whooping cranes totaling less than 400 adult and 

46 juvenile birds, including one wild population and two experimental, nonessential populations. 

47 The wild population of whooping cranes overwinters in the Aransas National Wildlife Refuge in 
Affected Environment 

February 2010 2-53 Draft NUREG-1437, Supplement 41 

1 Texas, and migrates north in the spring to one small breeding area in Canada (USFWS, 2009g). 

2 The wild population uses the Platte River and its tributaries and surrounding wetlands along its 

3 migratory corridor in the spring and fall. CNS-1 transmission line NPPD TL3502 crosses the 

4 Platte River along the whooping crane migratory corridor one mile from the endpoint of the 

5 transmission line near Grand Island, Nebraska. Critical habitat has been designated for 

6 whooping cranes on the Platte River, located approximately 25 miles (40 km) southwest of 

7 Grand Island (USFWS, 1978). One of the two experimental populations breeds in Idaho and 

8 overwinters in Utah. The second experimental population breeds in Wisconsin and overwinters 

9 in Florida and several other southeastern States (NatureServe, 2008a). 

10 Captive breeding programs over the past several decades have increased whooping crane 

11 populations sufficiently to allow creation of the two experimental populations. As of April 2008, 

12 however, there were still less than 400 adult and juvenile whooping cranes in existence between 

13 these three flocks. Both the wild population and the experimental populations still suffer 

14 significant mortality attributable to severe weather, lack of food, and collisions with power lines. 

15 The wild Aransas population lost 57 adult and juvenile whooping cranes between spring 2008 

16 and winter 2009, for a loss of 21 percent of its population in 12 months. The spring 2009 flock of 

17 whooping cranes at Aransas totaled 247 birds (Stehn, 2009). 

18 The NPPD has coordinated efforts with the USFWS to address the potential risk of bird 

19 collisions with transmission line NPPD TL3502, which crosses the Platte River near the end of 

20 the CNS-1 transmission line corridor, located approximately 4 miles (6 km) east of Grand Island, 

21 Nebraska. The Federally-endangered whooping crane (Grus Americana), the interior least tern 

22 (Sterna antillarum athalassos), and the Federally threatened piping plover (Charadrius 

23 melodius) utilize the Platte River and associated wetlands around Grand Island for different 

24 portions of their lifecycle, such as for migration, resting, feeding, and nesting, and risk collisions 

25 with the NPPD transmission line. The USFWS has indicated that collisions with transmission 

26 lines are the main cause of whooping crane mortality during their migrations (USFWS, 2009c). 

27 On May 8, 2009, the NPPD informed the USFWS that NPPD had agreed to mark that portion of 

28 the NPPD transmission line that crosses the Platte River with bird flight diverters to increase the 

29 visibility of the transmission line and reduce the risk of birds colliding with the line (NPPD, 2009). 

30 The USFWS replied to NPPD on June 8, 2009, informing them that NPPD had satisfactorily 

31 addressed the concerns of the USFWS regarding bird collisions (USFWS, 2009l). 

32 The extremely rare Salt Creek tiger beetle is found only in the northern third of Lancaster 

33 County, Nebraska (Cornell University, 2008; USFWS, 2005; NatureServe, 2008b). The 

34 transmission line corridor for CNS-1 traverses the southern portion of Lancaster County (NPPD, 

35 2008). The Salt Creek tiger beetle is about one-half inch (1.0 cm) long and is metallic brown to 

36 dark olive green above with a metallic dark green underside (USFWS 2005, 2009h). The tiger 

37 beetle is an active predator, grasping other small invertebrates for prey with its mandibles. The 

38 Salt Creek tiger beetle, limited to three populations totaling less than 150 adults, is found only in 

39 saline wetlands and along muddy banks of associated streams and tributaries of Little Salt 

40 Creek in Lincoln, Nebraska. Threats to the remaining populations of the Salt Creek tiger beetle 

41 include habitat loss and degradation caused by development, increased water runoff and 

42 sediment runoff from urban areas, eroding banks associated with development, bank 

43 stabilization projects, pollution, pesticides, and habitat loss and degradation from grazing and 

44 cultivation (Cornell University, 2008; USFWS, 2005). On December 12, 2007, the USFWS 

45 proposed the designation of critical habitat for the Salt Creek tiger beetle (USFWS, 2009i). 

46 The black-footed ferret is considered to be one of the most endangered mammals in the United 

47 States, and has the potential to survive in Hamilton County and Merrick County, Nebraska, near 
Affected Environment 

Draft NUREG-1437, Supplement 41 2-54 February 2010 

1 the western limit of transmission line NPPD TL3502 (USFWS, 2009b; NPPD, 2008a). It is a 

2 member of the weasel family (Mustelidae), and is the only ferret native to North America. The 

3 black-footed ferret’s distinctive coloration includes a black face mask, black feet, and a black4 tipped tail, with a light yellow-buff color on its back and body. It is approximately 6 inches 

5 (15 cm) tall, 18–24 inches (50–60 cm) long including a 6-inch (15 cm) tail, and weighs 

6 1.5–2.5 pounds (0.7–1.1 kg) (Defenders of Wildlife, 2009; NatureServe, 2009c; USFWS 2000, 

7 2009j). 

8 Black-footed ferrets once ranged throughout the Great Plains region of the United States and 

9 part of southern Canada. They live primarily on the open prairie and spend most of their time 

10 underground in prairie dog burrows, relying on prairie dogs as their prey. Through the first half 

11 of the twentieth century, the conversion of open prairie to farmland, the shooting and poisoning 

12 of prairie dogs to eliminate them from livestock grazing areas, and sylvatic plague wiped out 

13 large numbers of prairie dogs and correspondingly decimated the black-footed ferret population. 

14 The black-footed ferret was feared extinct by the mid 1970s, until a small population of 130 was 

15 identified in Wyoming in 1981 (Black-footed Ferret Recovery Implementation Team, 2009; 

16 Defenders of Wildlife, 2009; USFWS, 2000). A captive breeding program over the last 25 years 

17 has increased their population from a low of 18 wild black-footed ferrets to their present number 

18 of 750 living in the wild, including an experimental nonessential population, and 250 living in 

19 captive breeding facilities (USFWS 2000, 2009j). Current threats to the black-footed ferret still 

20 include their reliance on prairie dogs as their food source, the corresponding prairie dog 

21 management practices implemented by agricultural interests competing for land, and the 

22 reduction and fragmentation of prairie dog populations to less than five percent of their historic 

23 range (Defenders of Wildlife, 2009; NatureServe, 2009c). 

24 State Protected Species

25 A total of 115 terrestrial species (41 terrestrial animal species and 74 terrestrial plant species) 

26 are protected by Nebraska and Missouri, and are listed as endangered, threatened, or species 

27 of special concern (S1; S2; SX; SH) (Table 2.2.7-1). Ninety-three of the protected species occur 

28 in Nebraska, and 37 of the protected species are in Atchison County, Missouri. These 115 

29 species have the potential to inhabit the counties within the vicinity of CNS-1 and/or the 

30 transmission line corridor, including Nemaha County, Johnson County, Gage County, Lancaster 

31 County, Saline County, Fillmore County, York County, Hamilton County, and Merrick County, 

32 Nebraska, and Atchison County, Missouri. These 41 animal species include 14 bird species, 12 

33 reptile species, 2 amphibian species, 8 mammal species, and 5 insect species (NGPC 2008, 

34 2009c; MDC 2009b, 2009c; USFWS 2008a, 2009b). The NPPD has indicated that no currently 

35 Federally or State-listed terrestrial plant or animal species have been observed on CNS-1 

36 property (NPPD, 2008). 

37 Forty-nine of the protected species inhabit Nemaha County, Nebraska, the location of CNS-1, 

38 including 15 species of mammals, birds, reptiles, and amphibians, and 34 species of plants 

39 (Table 2.2.7-1). Nebraska lists two mammals, the southern flying squirrel (Glaucomus volans) 

40 as threatened and the woodland vole (Microtus pinetorum) as a species of concern. Both 

41 species occur in Nemaha County. Six bird species protected by Nebraska that occur in Nemaha 

42 County include the ruffed grouse (Bonasa umbellus), the whip-poor-will (Caprimulgus 

43 vociferous), the peregrine falcon (Falco peregrinus), the barred owl (Strix varia), the blue-gray 

44 gnatcatcher (Polioptila caerula), and the Carolina wren (Thryothorus ludovicianus) 

45 (NatureServe, 2009e; NGPC, 2009c). The peregrine falcon was once a Federally-listed species, 

46 but was delisted in 1999. The bald eagle (Haliaeetus leucocephalus), an S3 designation, has 

47 been observed on both sides of the Missouri River on CNS-1 property. The bald eagle was 
Affected Environment 

February 2010 2-55 Draft NUREG-1437, Supplement 41 

1 likewise a listed species, but was delisted in 2007. Both the peregrine falcon and the bald eagle 

2 are protected under the Migratory Bird Treaty Act, and the bald eagle is also protected under 

3 the Bald and Golden Eagle Protection Act. There is an active bald eagle nest adjacent to a field 

4 on the Missouri side of the CNS-1 property. Six Nebraska State protected reptiles and one 

5 amphibian known to inhabit Nemaha County include the western wormsnake (Carphophis 

6 vermis), the yellow-bellied kingsnake (Lampropeltis calligaster), the common kingsnake 

7 (Lampropeltis getula), the smooth green snake (Liochlorophis vernalis), Graham’s crayfish 

8 snake (Regina grahamii), the Massasauga rattlesnake (Sistrurus catenatus), and the 

9 smallmouth salamander (Ambystoma texanum) (NatureServe, 2009e, NGPC, 2009c). 

10 Nebraska lists 27 animal species and 39 plant species that are protected and occur or 

11 potentially occur in the counties traversed by the transmission line. Species listed as 

12 endangered by Nebraska that occur or potentially occur in the counties traversed by the 

13 transmission line corridor include the whooping crane, interior least tern, Salt Creek tiger beetle, 

14 American burying beetle (Nicrophorus americanus), Eskimo curlew, and black-footed ferret. 

15 Species listed as threatened by Nebraska that occur or potentially occur in the counties 

16 traversed by the transmission line corridor include the Massasagua rattlesnake, the piping 

17 plover, and the river otter (Lontra canadensus) (NatureServe, 2009e; NGPC, 2009c). 

18 The 37 protected species in Atchison, County, Missouri (the eastern portion of the CNS-1 site), 

19 include 16 species of mammals, birds, reptiles, amphibians, and insects, and 21 species of 

20 plants. Two mammals that potentially occur on the CNS-1 site in Missouri include the State 

21 endangered Indiana bat (Myotis sodalis) and the plains spotted skunk (Spilogale putorius 

22 interrupta). Other State protected mammals include the plains pocket mouse (Perognathus 

23 flavescens) and Franklin’s ground squirrel (Spermophilus franklinii). Five bird species protected 

24 by Missouri also are in Atchison County, and include the peregrine falcon, the loggerhead shrike 

25 (Lanius ludovicianus), the black rail (Laterallus jamaicensis), the king rail (Rallus elegans), and 

26 the interior least tern. Four reptiles protected by Missouri and known to inhabit Atchison County 

27 are the western fox snake (Elaphe vulpine), the smooth green snake, the Massasauga 

28 rattlesnake, listed as State endangered, and the Great Plains skink (Eumeces obsoletus). One 

29 amphibian protected by Missouri and known to inhabit Atchison County is the northern leopard 

30 frog (Rana pipiens). Two insect species are protected by Missouri and found in Atchison, 

31 County, and include Packard’s grasshopper (Melanoplus packardii), and the American burying 

32 beetle. The western prairie-fringed orchid is State listed as endangered (MDC 2009b, 2009c; 

33 NatureServe 2009d). 

34 2.2.8 Socioeconomic Factors 

35 This section describes current socioeconomic factors that have the potential to be directly or 

36 indirectly affected by changes in operations at the CNS-1. The CNS-1 and the people and 

37 communities surrounding it can be described as a dynamic socioeconomic system. The nuclear 

38 power plant requires people, goods, and services from local communities to operate the plant; 

39 and the communities, in turn, provide the people, goods, and services to run the plant. CNS-1 

40 employees residing in the community receive income from the plant in the form of wages, 

41 salaries, and benefits, and spend this income on goods and services within the community, 

42 thereby creating additional opportunities for employment and income. People and businesses in 

43 the community also receive income for the goods and services sold to CNS-1. Payments for 

44 these goods and services create additional employment and income opportunities in the 

45 community. The measure of a communities’ ability to support the operational demands of 

46 CNS-1 depends on the ability of the community to respond to changing socioeconomic 

47 conditions. 
Affected Environment 

Draft NUREG-1437, Supplement 41 2-56 February 2010 

1 The socioeconomics region of influence (ROI) is defined by the areas where CNS-1 employees 

2 and their families reside, spend their income, and use their benefits, thereby affecting the 

3 economic conditions of the region. The CNS-1 ROI consists of a four-county area (Nemaha, 

4 Otoe, and Richardson counties in Nebraska and Atchison County in Missouri) where 

5 approximately 90 percent of CNS-1 employees reside. The following sections describe the 

6 housing, public services, offsite land use, visual aesthetics and noise, population demography, 

7 and the economy in the ROI surrounding CNS-1. 

8 NPPD employs a permanent workforce of approximately 750 employees (NPPD, 2008). 

9 Approximately 90 percent live in Nemaha, Otoe, and Richardson counties, Nebraska, and 

10 Atchison County, Missouri (Table 2.2.8-1). Most of the remaining 10 percent of the workforce 

11 are divided among 23 counties in Iowa, Kansas, Missouri, and Nebraska with numbers ranging 

12 from 1 to 13 employees per county. Given the residential locations of CNS-1 employees, the 

13 most significant impacts of plant operations are likely to occur in Nemaha, Otoe, Richardson, 

14 and Atchison counties. The focus of the socioeconomic impact analysis in this supplemental 

15 environmental impact statement (SEIS) is therefore on the impacts of the CNS-1 on these four 

16 counties. 

17 Table 2.2.8-1. Cooper Nuclear Station, Unit 1 Employee Residence by County 

County Number of Employees Percentage of Total 

Nemaha, NE 359 48 

Otoe, NE 108 14 

Atchison, MO 106 14 

Richardson, NE 100 13 

Fremont, IA 13 2 

Holt, MO 12 2 

Cass, NE 11 2 

Other 41 5 

Total 750 100 

Source: NPPD, 2008a 

18 Refueling outages at the CNS-1 normally occur at 18-month intervals. During refueling outages, 

19 site employment increases by as many as 700 to 900 workers for approximately 30 days 

20 (NPPD, 2008). Most of these workers are assumed to be located in the same geographic areas 

21 as CNS-1 employees. 

22 2.2.8.1 Housing 

23 Table 2.2.8.1-1 lists the total number of occupied and vacant housing units, vacancy rates, and 

24 median value in the four-county ROI. According to the 2000 Census, there were approximately 

25 17,700 housing units in the socioeconomic region, of which approximately 15,800 were 

26 occupied. The median value of owner-occupied housing units in the three Nebraska counties 

27 ranged from $38,900 in Richardson County to $78,000 in Otoe County. The vacancy rate was 

28 the lowest in Otoe County (7.7 percent) and highest in Richardson County (12.4 percent). 

29 Atchison County, Missouri, has the smallest number of total and vacant housing units among 

30 the four counties (USCB, 2009). 
Affected Environment 

February 2010 2-57 Draft NUREG-1437, Supplement 41 

1 By 2007, the estimated number of housing units grew in all three counties by approximately 

2 3 percent of their total inventories. In Nemaha County the number of housing units grew to an 

3 estimated total of 3,540 units in 2007, an increase of more than 100 units. In Otoe County the 

4 number of housing units grew by more than 390 units to an estimated total of 6,955 units or 

5 approximately 6 percent. The estimated total number of housing units also increased slightly in 

6 Atchison County, Missouri (USCB, 2009). 

7 Table 2.2.8.1-1. Housing in Nemaha, Otoe, and Richardson Counties in Nebraska and 

8 Atchison County in Missouri 

Nemaha Otoe Richardson Atchison ROI 

2000 

Total 3,439 6,567 4,560 3,103 17,669 

Occupied housing units 3,047 6,060 3,993 2,722 15,822 

Vacant units 392 507 567 381 1,847 

Vacancy rate (percent) 11.4 7.7 12.4 12.3 10.5 

Median value (dollars) 58,200 78,000 38,900 49,800 56,225 

2007* 

Total 3,540 6,955 4,563 3,129 18,187 

* Estimated occupied housing units, vacancy, and median value data is not available for all counties. 

Source: USCB, 2009a. 

9 2.2.8.2 Public Services 

10 This section presents information regarding public services including water supply, education, 

11 and transportation. 

12 Water Supply

13 Because 90 percent of workers at CNS-1 reside in Nemaha, Otoe, and Richardson counties, 

14 Nebraska and Atchison County, Missouri, the discussion of public water supply systems is 

15 limited to these counties. In Table 2.2.8.2-1, information about municipal water suppliers in 

16 these counties, their permitted capacities and/or maximum design yields, reported annual peak 

17 usage, and population served are presented. The primary source of potable water in the vicinity 

18 of the CNS-1 is ground water. Most of Nemaha, Atchison, and Richardson counties are not 

19 served by community water supplies. Private ground water wells supply much of the water to 

20 residents in the area. 

21 There are four wellhead protection areas within 10 miles of CNS-1: Village of Nemaha, Nemaha 

22 County Rural Water District (RWD) No. 1, City of Auburn, and Village of Stella. CNS-1 does not 

23 use public water systems for cooling or process water systems. NPPD relies on ground water 

24 wells and surface water from the Missouri River for all of its water needs at the CNS-1. Two 

25 wells supply potable water to the facility (NPPD, 2008). 

26 Community water supply systems in Nemaha County include the City of Auburn, the City of 

27 Nemaha, Nemaha County RWD No. 1, Nemaha County RWD No. 2, and the City of Peru. The 

28 Village of Brownville no longer uses its own supply wells, but is connected to Nemaha County 

29 RWD No. 1 (NPPD, 2008). The Auburn Board of Public Works operates the Auburn Municipal 

30 Water System. Eleven wells can provide up to 1,728,000 gallons of water per day. The system 

31 provides an average of 700,000 gallons of water per day and can meet a peak demand of 
Affected Environment 

Draft NUREG-1437, Supplement 41 2-58 February 2010 

1 1,181,700 gallons per day. The system has a storage capacity of 1,650,000 gallons (NDED and 

2 NPPD, 2008a). The Nemaha municipal water system serves the Village of Nemaha and 

3 provides an average of 17,500 gallons of water per day and can meet a peek demand of 30,000 

4 gallons per day. The system has a rated capacity of 216,000 gallons per day (NPPD, 2008). 

5 Nemaha County RWD No. 1 has a rated capacity of 100,000 gallons per day with a peak 

6 demand of 90,000 gallons per day. The Nemaha County RWD No. 1 public water system serves 

7 rural Nemaha County including the Village of Brownville. Nemaha County RWD No. 2 has an 

8 average service demand of 206,300 gallons per day. The storage capacity is reported to be 

9 230,000 gallons (NPPD, 2008). 

10 The Peru Municipal Water System serves the municipality of Peru in Nemaha County. The Peru 

11 system has a rated capacity of 576,000 gallons per day with an average of 83,000 gallons and a 

12 peak demand of 113,500 gallons per day (NPPD, 2008). 

13 Nebraska City Utilities provides water to the residents of Nebraska City in Otoe County. This 

14 water system has a rated capacity of 6,300,000 gallons per day with an average of 2,500,000 

15 gallons and a peak demand of 3,500,000 gallons per day (Great Plains Energy, 2009). 

16 Falls City provides water to approximately 4,800 residents in Richardson County. The water 

17 system has a rated capacity of 2,160,000 gallons per day with an average of 690,000 gallons 

18 and a peak demand of 1,528,000 gallons per day (Great Plains Energy, 2009). 

19 Richardson County RWD No. 1 and the Village of Shubert have community water systems 

20 within ten miles of CNS-1. Richardson County RWD No. 1 system has a capacity of 230,000 

21 gallons per day with an average demand of 100,000 gallons per day. The Village of Shubert 

22 operates a municipal water system with a capacity of 204,000 gallons per day, with an average 

23 daily demand of 22,800 gallons (NPPD, 2008). 

24 Almost all potable water use within Atchison County is from ground water supplied from wells, 

25 with the exception of Westboro, Missouri which purchases water from a surface water source. 

26 The Rock Port Municipal Water System on average supplies approximately 300,000 gallons per 

27 day with a system capacity of approximately 720,000 gallons per day (MDNR, 2008). 
Affected Environment 

February 2010 2-59 Draft NUREG-1437, Supplement 41 

1 Table 2.2.8.2–1. Public Water Supply Systems (thousand gallons per day) 

Water Supplier a Water Source a Average Daily 

Demand 

System 

Capacity

Population 

Served a

Nemaha County, Nebraska 

City of Auburn GW 1,182 1,728 3,217 

Village of Nemaha GW 30 216 188 

City of Peru GW 114 576 923 

Nemaha County RWD No. 1 GW 90 100 800 

Nemaha County RWD No. 2 GW 206 230 1,315 

Otoe County, Nebraska 

City of Nebraska GW 2,500 6,300 7,192 

Richardson County, Nebraska 

City of Falls City GW 690 2,160 4,761 

Richardson County RWD No. 1 GW 100 230 805 

Village of Shubert GW 23 204 240 

Atchison County, Missouri 

Fairfax GW 185 308 645 

Public Water System District No. 1 of 

Atchison County 

GW 171 1,310 831 

City of Rock Port GW 300 720 726 

Tarkio Board of Public Works GW 225 756 1,957 

Westboro SW 20 75 160 

2 GW = ground water; SW = surface water; RWD = rural water district 

a 3 EPA, 2009b 

4 Source: EPA, 2009b;Nebraska Department of Economic Development (NDED and NPPD, 2008a; NPPD, 2008a; 

5 Great Plains Energy, 2009; MDNR, 2008. 

6 Education

7 The CNS-1 is located in the Auburn Public School District, Nemaha County, which has an 

8 enrollment of approximately 882 students in the 2008–2009 school year (Nebraska Department 

9 of Education (NDE, 2009). Nemaha County has 2 public school districts with over 1,100 enrolled 

10 students (NDE, 2009). Otoe and Richardson counties have 4 school districts each (NDE, 2008). 

11 Total enrollment in Otoe and Richardson County schools in the 2008–2009 school year was 

12 approximately 2,900 and 1,600 students, respectively (NDE, 2009). 

13 Transportation

14 Several highways serve as transportation corridors within Nemaha and Atchison counties. The 

15 primary highways in Nemaha County include U.S. Highways 75 and 136 and Nebraska State 

16 Highways 62, 67, and 105. Access to the site is by Nemaha County Road 648A Avenue located 

17 on the west side of CNS-1 property. County Road 648A Avenue intersects US Highway 136 

18 which runs east to west, north of CNS-1 at Brownville, Nebraska. State Highway 67 traverses 

19 Nemaha County north to south to the west of CNS-1. U.S. Highway 75 bisects Nemaha County 

20 running north to south. Plant workers living east and west of CNS-1 travel on U.S. Highway 136 
Affected Environment 

Draft NUREG-1437, Supplement 41 2-60 February 2010 

1 to Nemaha County Road 648A Avenue to the site access road, and workers living north and 

2 south travel on U.S. Highway 75 and Nebraska State Highway 67 to U.S. Highway 136. 

3 The primary highways in Atchison County, Missouri on the east side of the Missouri River 

4 include Interstate 29 (I-29), U.S. Highways 136, 59, and 275, Missouri State Highways 46 and 

5 111, and County Roads B, M, and T. I-29 runs north to south through Atchison County roughly 

6 parallel to the river between Council Bluffs, Iowa northeast of CNS-1 and St. Joseph, Missouri, 

7 southeast of CNS-1. CNS-1 employees who reside in Missouri can access the site by using 

8 either U.S. Highways 136 or 159, which cross the Missouri River at Brownville and Rulo, 

9 Nebraska (in Richardson County), respectively. U.S. Highway 136 bisects Atchison County east 

10 to west in Missouri, similar to Nemaha County on the west side of the river. Atchison County is 

11 also bisected by U.S. Highway 59 which runs north to south through the central portion of the 

12 county. 

13 Primary highways in Richardson County include U.S. Highways 73, 75, and 159 and State 

14 Highways 8, 62, 67, and 105. U.S. Highway 75 runs north and south through both Nemaha and 

15 Richardson counties. U.S. Highway 159 crosses the river downstream of CNS-1 at Rulo, 

16 Nebraska, from Holt County, Missouri. 

17 The primary highways in Otoe County include U.S. Highways 50 and 75 and Nebraska State 

18 Highways 2, 43, 66A, 67, and 128. Otoe County is bisected north to south by U.S. Highway 50 

19 and Nebraska State Highway 2. Access to Otoe County directly from CNS-1 is primarily from 

20 Nebraska State Highway 67 and U.S. Highway 75. 

21 Table 2.2.8.2–2 lists commuting routes to CNS-1 and average annual daily traffic (AADT) 

22 volume values. The AADT values represent traffic volumes for a 24-hour period factored by both 

23 day of week and month of year. 
Affected Environment 

February 2010 2-61 Draft NUREG-1437, Supplement 41 

1 Table 2.2.8.2-2. Major Commuting Routes in the Vicinity of Cooper Nuclear Station, Unit 1 

2 in 2006 Average Annual Daily Traffic Count 

Roadway and Location Average Annual Daily Traffic (AADT) a

U.S. Highway 136 (between State Highway 67 and 

Brownville, NE) 2,905 

U.S. Highway 136 (between Brownville, NE and Missouri 

River) 2,615 

U.S. Highway 136 (between Interstate 29 and the Missouri 

River in Missouri) 2,487 

U.S. Highway 136 at Rock Port, MO 3,194 

U.S. Highway 136 (between Auburn, NE and State Highway 

67) 3,205 

State Highway 67 (between Nemaha, NE and Brownville, NE 960 

State Highway 67 at Nemaha, NE 770 

State Highway 67 south of CNS-1 625 

State Highway 67 at Peru, NE 1,025 

U.S. Highway 75 (between State Highway 67 and U.S. 

Highway 136, Auburn, NE) 5,220 

U.S. Highway 75 (near Julian, NE) 4,640 

U.S. Highway 75 (south of Nebraska City, NE) 5,585 

Interstate 29 north of U.S. Highway 136 in Missouri 10,325 

Interstate 29 south of U.S. Highway 136 in Missouri 11,832 

Source: NDOR, 2007; MOBOT, 2007. 

a

 All AADTs represent traffic volume during the average 24-hour day during 2006. 

U.S.=United States 

3 2.2.8.3 Offsite Land Use 

4 Offsite land use conditions in Nemaha County, Otoe County, Richardson County, and Atchinson 

5 County, are described in this section. In addition to property taxes, Nemaha and other counties 

6 in the vicinity of CNS-1 receive revenue from sales taxes and fees paid by NPPD and its 

7 employees residing in the region. Changes in the number of workers at CNS-1 and tax 

8 payments to local jurisdictions could affect land use conditions in these counties. 

9 CNS-1 is located in eastern Nemaha County. Otoe, Richardson, and Atchison counties are 

10 located along the Missouri River, north, south, and east of Nemaha County, respectively. The 

11 four-county area near CNS-1 is rural and largely unincorporated. Less than half of the 

12 population in the four-county area lives in incorporated towns and villages. Most of the land in 

13 the four-county area is in agricultural use or is forest or open land. Only a small percentage of 

14 the land has been developed for residential, commercial, or industrial purposes. Forested areas 

15 are generally limited to narrow strips of land along streams and rivers and steep, hilly areas 

16 unsuitable for agriculture. 
Affected Environment 

Draft NUREG-1437, Supplement 41 2-62 February 2010 

1 Nemaha, Richardson, and Atchison counties have seen a steady decline in population over the 

2 past 50 years as residents leave farms to seek employment in larger cities and towns. Most 

3 towns and villages located within a 50-mile radius of CNS-1 are small and primarily support 

4 agricultural communities. The closest communities to CNS-1 are the Village of Brownville, 

5 located approximately two miles northwest of CNS-1 and the town of Nemaha to the south. 

6 Industrial developments in the four-county area are located in the larger communities of Auburn 

7 and Nebraska City, Nebraska, and Marysville, Missouri. 

8 Nemaha County occupies approximately 409 square miles (262,000 ac) (USCB, 2009c). 

9 Approximately 213,000 acres or 81 percent of the land in Nemaha County was used for 

10 agriculturally related activities in 2007. There were 449 farms, with most of the agricultural land 

11 devoted to cropland (80 percent) and pasture (12 percent) (USDA, 2009). Nemaha County does 

12 not have county-wide zoning regulations although the city of Auburn has local zoning 

13 regulations (NPPD, 2008). 

14 Otoe County occupies roughly 616 square miles (394,000 ac) (USCB, 2009c). The largest 

15 category of land use, approximately 322,000 acres or 82 percent, is devoted to agriculture in 

16 Otoe County, with 804 farms in 2007. Approximately 80 percent of the agricultural land is in 

17 cropland and approximately 11 percent pasture (USDA, 2009). Otoe County has county-wide 

18 zoning regulations to manage future growth and development in the county. 

19 Richardson County occupies roughly 553 square miles (354,000 ac) (USCB, 2009c). The 

20 largest category of land use, approximately 279,000 acres or 79 percent, is devoted to 

21 agriculture in Richardson County, with 707 farms in 2007. Approximately 75 percent of the 

22 agricultural land is cropland and approximately 14 percent, pasture (USDA, 2009). Richardson 

23 County does not have county-wide zoning regulations although the City of Falls city has local 

24 zoning regulations (NPPD, 2008). 

25 Atchison County, Missouri occupies approximately 545 square miles (349,000 ac) 

26 (USCB, 2009c). Approximately 87 percent of Atchison County land is used for agricultural 

27 purposes. In 2007, the county had 501 farms on approximately 304,000 acres. Major 

28 agricultural uses consist of croplands (87 percent) and 6 percent pasture (USDA, 2009). 

29 Atchison County currently does not have county-wide zoning regulations to manage future 

30 growth and development (NPPD, 2008). 

31 No significant change in land use is anticipated for the future in these four counties. Land use 

32 trends reflect a slow, but steady overall decline in population in the region. Limited potential 

33 commercial and urban development occurs in the small urban areas where public services and 

34 utilities are available. No significant changes in future agricultural acreage, farm size, and land 

35 uses are anticipated for the four-county region near CNS-1. 

36 2.2.8.4 Visual Aesthetics and Noise 

37 CNS-1 can be seen from the river, but is partly shielded by vegetation along the river. 

38 Predominant features are the reactor building, which is approximately 290 feet tall, the elevated 

39 release point (325 feet) and meteorological tower (328.8 feet). The turbine building and reactor 

40 containment structures dominate the landscape of the site. The 239 undeveloped acres of 

41 CNS-1 site on the Missouri (east) side of the river provides a wooded view from the river. 

42 Noise from nuclear plant operations can be detected offsite. Sources of noise at CNS-1 include 

43 the turbines and large pump motors. Given the industrial nature of the station, noise emissions 

44 from the station are generally nothing more than an intermittent minor nuisance. However, noise 
Affected Environment 

February 2010 2-63 Draft NUREG-1437, Supplement 41 

1 levels may sometimes exceed the 55 dBA level that the EPA uses as a threshold level to protect 

2 against excess noise during outdoor activities (EPA, 1974). However, according to the EPA this 

3 threshold does “not constitute a standard, specification, or regulation,” but was intended to 

4 provide a basis for State and local governments establishing noise standards. 

5 2.2.8.5 Demography 

6 According to the 2000 Census, approximately 18,318 people lived within 20 miles of CNS-1, 

7 which equates to a population density of 15 persons per square mile (NPPD, 2008). This 

8 density translates to Category 1, Most sparse (less than 40 persons per square mile and no 

9 community with 25,000 or more persons within 20 miles). Approximately 160,211 people live 

10 within 50 miles of CNS-1 (NPPD, 2008). This equates to a population density of 20 persons per 

11 square mile. Applying the Generic Environmental Impact Statement (GEIS) for License Renewal 

12 of Nuclear Plants NUREG-1437 proximity measures, CNS-1 is classified as proximity Category 

13 1 (no city with 100,000 or more persons and less than 50 persons per square mile within 50 

14 miles). Therefore, according to the sparseness and proximity matrix presented in the GEIS, 

15 CNS-1 rankings of sparseness Category 1 and proximity Category 1 result in the conclusion that 

16 CNS-1 is located in a low population area. 

17 Table 2.2.8.5-1 shows population projections and growth rates from 1970 to 2050 in Nemaha, 

18 Otoe, and Richardson County, Nebraska, and Atchison County, Missouri. The growth rate in 

19 Nemaha County showed a decrease of 5.1 percent for the period of 1990 to 2000. County 

20 populations are expected to continue to decline in Nemaha, Richardson, and Atchison counties 

21 in the next decades although Otoe County’s population is expected to increase through 2050. 

22 Table 2.2.8.5-1. Population and Percent Growth in Nemaha, Otoe, and Richardson 

23 County, Nebraska, and Atchison County, Missouri, from 1970 to 2000 and projected for 

24 2006 to 2050 

Nemaha, NE Otoe, NE Richardson, NE Atchison, MO 

Year Population 

Percent 

Growtha Population 

Percent 

Growtha Population 

Percent 

Growtha Population 

Percent 

Growtha

1970 8,976 — 15,576 — 12,277 — 9,240 — 

1980 8,367 -6.8 15,183 -2.5 11,315 -7.8 8,605 -6.9 

1990 7,980 -4.6 14,252 -6.1 9,937 -12.2 7,457 -13.3 

2000 7,576 -5.1 15,396 8.0 9,531 -4.1 6,430 -13.8 

2007 7,039 -7.1 15,647 1.6 8,351 -12.4 6,108 -5.0 

2010 6,767 -10.7 15,704 2.0 8,408 -11.8 5,927 -7.8 

2020 6,456 -4.6 16,399 4.4 7,892 -6.1 5,559 -6.2 

2030 6,033 -6.6 17,414 6.2 7,398 -6.3 5,280 -5.0 

2040 5,685 -5.8 18,216 4.6 6,889 -6.9 4,942 -6.4 

2050 5,318 -6.5 19,071 4.7 6,384 -7.3 4,618 -6.5 

— = No data available. 

a

Percent growth rate is calculated over the previous decade. 

Sources: Population data for 1970 through estimated population data for 2006 (USCB, 2009); population projections 

for 2010–2030 by Bureau of Business Research (BBR), University of Nebraska-Lincoln, Nebraska Population 

Projections (2008) and Missouri State Demographer, Office of Administration, No Date; population projections for 

2040 and 2050 (calculated). 
Affected Environment 

Draft NUREG-1437, Supplement 41 2-64 February 2010 

1 Demographic Profile

2 The 2000 and 2006 (estimate) demographic profiles of the four-county ROI population is 

3 presented in Table 2.2.8.5-2 and Table 2.2.8.5-3. In 2000, minorities (race and ethnicity 

4 combined) comprised 3.8 percent of the total four-county population. The minority population is 

5 composed of Hispanic or Latino and American Indian residents. 

6 Table 2.2.8.5-2. Demographic Profile of the Population in the Cooper Nuclear Station 

7 Unit 1 Four-County Socioeconomic Region of Influence in 2000 

Nemaha, NE Otoe, NE Richardson, NE Atchison, MO 

Region of 

Influence 

Total Population 7,576 15,396 9,531 6,430 38,933 

Race (percent of total population, Not-Hispanic or Latino) 

White 97.1 96.3 95.1 96.6 96.2 

Black or African American 0.4 0.2 0.2 2.1 0.5 

American Indian and Alaska 

Native 0.2 0.2 2.1 0.2 0.7 

Asian 0.6 0.2 0.1 0.1 0.3 

Native Hawaiian and Other 

Pacific Islander 0.0 0.0 0.0 0.0 0.0 

Some other race 0.0 0.0 0.0 0.0 0.0 

Two or more races 0.6 0.6 1.4 0.3 0.7 

Ethnicity 

Hispanic or Latino 76 377 100 43 596 

Percent of total population 1.0 2.4 1.0 0.7 1.5 

Minority Population (including Hispanic or Latino ethnicity) 

Total minority population 218 574 469 219 1,480 

Percent minority 2.9 3.7 4.9 3.4 3.8 

8 Source: USCB, 2009 

9 According to the USCB’s 2007 estimates published in 2009, minority populations in the four10 county region were estimated to have increased by over 500 persons and comprised 5.4 

11 percent of the total four county population (see Table 2.2.8.5-3). Most of this increase was due 

12 to an estimated influx of Hispanic or Latinos (over 320 persons), an increase in population of 

13 over 55 percent from 2000. This was the largest percentage increase of any minority population 

14 and a one percent increase in Hispanic or Latino population when compared to the total four15 county population. The next highest percentage increase in minority population was Asian, an 

16 increase of over 51 percent from 2000. However, this resulted in only a very slight increase in 

17 population as a percentage of the total four-county population. 
Affected Environment 

February 2010 2-65 Draft NUREG-1437, Supplement 41 

1 Table 2.2.8.5-3. Demographic Profile of the Population in the Cooper Nuclear Station 

2 Four-County Socioeconomic Region of Influence in 2007, Estimated 

Nemaha, NE Otoe, NE Richardson, NE Atchison, MO 

Region of 

Influence 

Total Population 7,039 15,647 8,351 6,108 37,145 

Race (percent of total population, not Hispanic or Latino) 

White 95.9 94.1 93.9 95.6 94.6 

Black or African American 0.6 0.5 0.3 2.3 0.7 

American Indian and Alaska 

Native 0.3 0.4 2.6 0.3 0.9 

Asian 0.8 0.3 0.5 0.3 0.4 

Native Hawaiian and Other 

Pacific Islander 0.0 0.0 0.0 0.0 0.0 

Some other race * * * * * 

Two or more races 0.6 0.8 1.4 0.3 0.8 

Ethnicity 

Hispanic or Latino 126 612 111 73 922 

Percent of total population 1.8 3.9 1.3 1.2 2.5 

Minority Population (including Hispanic or Latino ethnicity) 

Total minority population 288 930 506 269 1,993 

Percent minority 4.1 5.9 6.1 4.4 5.4 

3 * Some other race was eliminated from the Census estimate. 

4 Source: USCB, 2009 

5 Transient Population

6 Within 50 miles (80 km) of the CNS-1, colleges and recreational opportunities attract daily and 

7 seasonal visitors who create demand for temporary housing and services. In 2009, there were 

8 approximately 8,018 students attending colleges and universities within 50 miles (80 km) of the 

9 CNS-1 (IES, 2009). 

10 In 2000 in Nemaha County, 1.6 percent of all housing units are considered temporary housing 

11 for seasonal, recreational, or occasional use. By comparison, seasonal housing accounted for 

12 0.6 percent, 1.3 percent, and 1.6 percent of total housing units in Otoe and Richardson counties 

13 and Nebraska, respectively (USCB, 2009). Seasonal housing accounted for 1.2 percent and 

14 2.7 percent of total housing units in Atchison County and Missouri, respectively (USCB, 2009). 

15 Table 2.2.8.5-4 provides information on seasonal housing for the 24 counties located all or 

16 partly within 50 miles of the CNS-1. 
Affected Environment 

Draft NUREG-1437, Supplement 41 2-66 February 2010 

1 Table 2.2.8.5-4. Seasonal Housing in Counties Located within 50 Miles of the Cooper 

2 Nuclear Station, Unit 1 

County a Housing units 

Vacant housing units: For 

seasonal, recreational, or 

occasional use Percent 

Iowa 1,232,511 16,472 1.3 

Fremont 3,514 56 1.6 

Mills 5,671 64 1.1 

Montgomery 5,399 38 0.7 

Page 7,302 47 0.6 

Taylor 3,199 19 0.6 

County Subtotal 25,085 224 0.9 (avg.) 

Kansas 1,131,200 9,639 0.9 

Atchison 6,818 47 0.7 

Brown 4,815 36 0.7 

Doniphan 3,489 28 0.8 

Jackson 5,094 42 0.8 

Marshall 4,999 46 0.9 

Nemaha 4,340 35 0.8 

County Subtotal 29,555 234 0.8 (avg.) 

Missouri 2,442,017 66,053 2.7 

Andrew 6,662 58 0.9 

Atchison 3,103 38 1.2 

Holt 2,931 391 13.3 

Nodaway 8,909 60 0.7 

County Subtotal 21,605 547 4.0 (avg.) 

Nebraska 722,668 11,912 1.6 

Cass 10,179 541 5.3 

Gage 10,030 56 0.6 

Johnson 2,116 14 0.7 

Lancaster 104,217 303 0.3 

Nemaha 3,439 56 1.6 

Otoe 6,567 37 0.6 

Pawnee 1,587 78 4.9 

Richardson 4,560 59 1.3 

Sarpy 44,981 211 0.5 

County Subtotal 187,676 1,355 1.7 (avg.) 

County Total 263,921 2,360 1.2 (avg.) 

Source: USCB, 2009 

a

 Counties within 50 miles of the CNS-1 that are totally or partially located within the 50-mile radius. 

avg. = percent average for counties within the CNS-1 50-mile radius and excludes State percentage.
Affected Environment 

February 2010 2-67 Draft NUREG-1437, Supplement 41 

1 Migrant Farm Workers

2 Migrant farm workers are individuals whose employment requires travel to harvest agricultural 

3 crops. These workers may or may not have a permanent residence. Some migrant workers 

4 follow the harvesting of crops, particularly fruit, throughout rural areas of the United States. 

5 Others may be permanent residents near the CNS-1 who travel from farm to farm harvesting 

6 crops. 

7 Migrant workers may be members of minority or low-income populations. Because they travel 

8 and can spend a significant amount of time in an area without being actual residents, migrant 

9 workers may be unavailable for counting by census takers. If uncounted, these workers would 

10 be “underrepresented” in USCB minority and low-income population counts. 

11 Information on migrant farm and temporary labor was collected in the 2007 Census of 

12 Agriculture. Table 2.2.8.5-5 provides information on migrant farm workers and temporary farm 

13 labor (less than 150 days) within 50 miles of the CNS-1. According to the 2007 Census of 

14 Agriculture, approximately 7,000 farm workers were hired to work for less than 150 days and 

15 were employed on 3,300 farms within 50 miles of the CNS-1. The county with the largest 

16 number of temporary farm workers (774 workers on 280 farms) was Lancaster County, 

17 Nebraska (USDA, 2009). 

18 In the 2007 Census of Agriculture, farm operators were asked for the first time whether or not 

19 any hired migrant workers, defined as a farm worker whose employment required travel that 

20 prevented the migrant worker from returning to their permanent place of residence the same 

21 day. A total of 87 farms in the 50-mile radius of the CNS-1 reported hiring migrant workers in the 

22 2007 Census of Agriculture. Nodaway County, Missouri, and Lancaster County, Nebraska 

23 reported the most farms (18 and 17, respectively) with hired migrant workers, followed by 

24 Nemaha County, Nebraska with 10 farms (USDA, 2009). 

25 According to the 2007 Census of Agriculture estimates, 195 temporary farm laborers (those 

26 working fewer than 150 days per year) were employed on 84 farms in Nemaha County, and 311 

27 and 323 temporary farm workers were employed on 145 and 143 farms in Otoe and Richardson 

28 counties, respectively (USDA, 2009). Atchison County, Missouri, had 226 temporary farm 

29 workers employed on 99 farms (USDA, 2009). 
Affected Environment 

Draft NUREG-1437, Supplement 41 2-68 February 2010 

1 Table 2.2.8.5-5. Migrant Farm Workers and Temporary Farm Labor in Counties Located 

2 within 50 Miles of the Cooper Nuclear Station, Unit 1 

County a

Number of 

farms with hired 

farm labor b

Number of farms 

hiring workers for 

less than 150 days b

Number of farm 

workers working for 

less than 150 days b

Number of farms 

reporting migrant 

farm labor b

Iowa 23,287 19,204 50,266 123 

Fremont 126 95 247 2 

Mills 91 70 NA 0 

Montgomery 118 100 187 0 

Page 189 158 276 0 

Taylor 134 103 259 1 

County Subtotal 658 526 969 3 

Kansas 14,437 11,558 30,682 193 

Atchison 115 105 231 0 

Brown 171 142 333 3 

Doniphan 130 108 211 0 

Jackson 145 128 319 2 

Marshall 246 209 498 3 

Nemaha 289 250 584 10 

County Subtotal 1,096 942 2,176 18 

Missouri 18,263 15,052 33,424 745 

Andrew 134 113 258 2 

Atchison 134 99 226 2 

Holt 136 105 214 1 

Nodaway 308 251 472 18 

County Subtotal 712 568 1,170 23 

Nebraska 14,603 11,261 29,583 468 

Cass 148 119 273 4 

Gage 322 272 585 7 

Johnson 120 105 NA 5 

Lancaster 310 280 774 17 

Nemaha 107 84 195 3 

Otoe 175 145 311 2 

Pawnee 91 83 NA 0 

Richardson 164 143 323 3 

Sarpy 87 69 218 2 

County Subtotal 1,524 1,300 2,679 43 

County Total 3,990 3,336 6,994 87 

Source: 2007 Census of Agriculture - County Data (USDA, 2009) 

a

 Counties within 50 miles of the CNS-1 that are totally or partially located within the 50-mile radius 

b

 Table 7. Hired Farm Labor - Workers and Payroll: 2007 
Affected Environment 

February 2010 2-69 Draft NUREG-1437, Supplement 41 

1 2.2.8.6 Economy 

2 This section contains a discussion of the economy, including employment and income, 

3 unemployment, and taxes. 

4 Employment and Income

5 Between 2000 and 2007, the civilian labor force in Nemaha County decreased 9.4 percent from 

6 3,931 to 3,560. During the same time period, the civilian labor force in Otoe County grew by 13 

7 percent. By 2007, the civilian labor force in Richardson and Atchison counties decreased by 

8 6.3 and 2.4 percent, respectively (USCB, 2009). 

9 In 2000, educational, health, and social services represented the largest sector of employment 

10 in the four-county region followed by manufacturing. The educational, health, and social 

11 services sector employed the most people in Nemaha County followed by transportation, 

12 warehousing, and utilities sectors. A list of some of the major employers in Nemaha County is 

13 provided in Table 2.2.8.6-1. As shown in the table, the largest employer in Nemaha County is 

14 the CNS-1. 

15 Table 2.2.8.6-1. Major Employers in Nemaha County 

Firm Number of Employees 

Cooper Nuclear Station 750 

Armstrong Cabinets 162 

Peru State College 160 

Auburn Public Schools 142 

Nemaha County Good Samaritan Home 75 

Magnolia Metals, Inc. 65 

Nemaha County Hospital 65 

Nemaha County Government 48 

Johnson-Brock Public Schools 44 

 Source: NDE, 2009 and NPPD, 2009 

16 Estimated income information for the CNS-1 region of influence is presented in Table 2.2.8.6-2. 

17 According to the USCB’s 2007 estimates, median household income averages in Nemaha, 

18 Otoe, Richardson, and Atchison counties were below their respective State median household 

19 income averages. In 1999, per capita income in the four counties was also below both State 

20 averages. In 2007, an estimated 13.3 and 13.4 percent of the county populations in Nemaha 

21 and Richardson counties were living below the official poverty level, while the percentage for the 

22 State of Nebraska as a whole was 11.1 percent. Conversely, Otoe County was estimated to 

23 have the smallest percentage of persons living in poverty (9.4 percent). In Atchison County an 

24 estimated 14.0 percent of the county population was living below the official poverty level, while 

25 the percentage for the State of Missouri as a whole was 13.3 percent. 
Affected Environment 

Draft NUREG-1437, Supplement 41 2-70 February 2010 

1 Table 2.2.8.6-2. Estimated Income Information for the Cooper Nuclear Station Region of 

2 Influence in 2007 

Nemaha Otoe Richardson Nebraska Atchison Missouri

Median household income 

(dollars) 41,024 45,018 36,092 47,072 38,114 45,012 

Per capita income in 1999 

(dollars) 17,004 17,752 16,460 19,613 16,956 19,936 

Percent of individuals living 

below the poverty level 13.3 9.4 13.4 11.1 14.0 13.3 

3 Source: USCB 2009 

4 Unemployment

5 According to the USCB’s 2007 estimates, the unemployment rates in Nemaha, Otoe, and 

6 Richardson counties were 3.9, 3.0 and 4.0 percent, respectively, which was slightly lower than 

7 the unemployment rate of 4.8 percent for the State of Nebraska (USCB, 2009). The 

8 unemployment rate in Atchison County was 4.3 percent, which was much lower than the 

9 6.5 percent for the State of Missouri (USCB, 2009). 

10 Taxes

11 As a not-for-profit public corporation and political subdivision of the State of Nebraska, NPPD is 

12 exempt from paying income or property taxes. Instead, in lieu of tax, other payments are made 

13 to State, county, and local governments in which NPPD provides retail electric power. 

14 According to the Nebraska State Constitution Article VIII, Section 11: 

15 Every public corporation and political subdivision organized primarily to provide 

16 electricity or irrigation and electricity shall annually make the same payments in 

17 lieu of taxes as it made in 1957, which payments shall be allocated in the same 

18 proportion to the same public bodies or their successors as they were in 1957. 

19 The legislature may require each such public corporation to pay to the treasurer 

20 of any county in which may be located any incorporated city or village, within the 

21 limits of which such public corporation sells electricity at retail, a sum equivalent 

22 to five (5) per cent of the annual gross revenue of such public corporation derived 

23 from retail sales of electricity within such city or village, less an amount 

24 equivalent to the 1957 payments in lieu of taxes made by such public corporation 

25 with respect to property or operations in any such city or village. The payments in 

26 lieu of taxes as made in 1957, together with any payments made as authorized in 

27 this section shall be in lieu of all other taxes, payments in lieu of taxes, franchise 

28 payments, occupation and excise taxes, but shall not be in lieu of motor vehicle 

29 licenses and wheel taxes, permit fees, gasoline tax and other such excise taxes 

30 or general sales taxes levied against the public generally. 

31 So much of such five percent as is in excess of an amount equivalent to the 

32 amount paid by such public corporation in lieu of taxes in 1957 shall be 

33 distributed in each year to the city or village, the school districts located in such 

34 city or village, the county in which such city or village is located, and the State of 

35 Nebraska, in the proportion that their respective property tax mill levies in each 

36 such year bear to the total of such mill levies (Neb. Const. art. VIII, sec. 11 

37 (1958); Adopted 1958,). 
Affected Environment 

February 2010 2-71 Draft NUREG-1437, Supplement 41 

1 NPPD is Nebraska's largest electric utility, with a chartered territory including all or parts of 91 of 

2 Nebraska's 93 counties. NPPD pays monies in lieu of property taxes to the counties in which it 

3 provides retail electric power. As part of NPPD's generation capacity, a portion of the in lieu of 

4 tax payments and payments to retail communities may be attributed to CNS-1. 

5 NPPD paid approximately $6.6 million in 2006 and $7.0 million in 2007 in lieu of taxes to the 91 

6 counties in which NPPD is chartered (NPPD, 2008). Each county receives 5 percent of the total 

7 gross revenues NPPD receives from electricity sales within the county. The actual in lieu of tax 

8 allocation attributable to CNS-1 is not recorded by NPPD. NPPD's power generation units 

9 provide power to the grid, and county retail sales are then from the grid. However, CNS-1 

10 represents approximately 24 percent of NPPD's power generation capacity. Based on 24 

11 percent generation, the payments in lieu of tax that could be attributed to CNS-1 were 

12 approximately $1.6 million in 2006 and $1.7 million in 2007 (see Table 2.2.8.6-3). 

13 NPPD also pays back 12 percent of the total gross revenues received from retail communities, 

14 which amounted to approximately $17.5 million in 2006 and $18.3 million in 2007 (NPPD, 2008). 

15 Based on 24 percent of NPPD's total generation capacity, CNS-1's contribution to retail 

16 communities was $4.2 million in 2006 and $4.4 million in 2007 (see Table 2.2.8.6-3). 

17 Since NPPD's charter is to provide electricity to customers throughout the State, these 

18 payments would continue regardless of whether or not the CNS-1 is operating. 

19 NPPD pays sales/use taxes on purchases made by CNS-1. As shown in Table 2.2.8.6-3, 

20 CNS 1 paid $943,020 in sales/use taxes in 2007; $1,353,435 in 2006. City sales taxes are paid 

21 to the town of Auburn, Nebraska. NPPD also pays a special assessment for the Brownville22 Nemaha Levee District that is paid to the county treasurer (NPPD, 2008b). As shown in Table 

23 2.2.8.6-3, the total taxes and payments to the State, counties, and retail communities 

24 attributable to CNS-1 in 2006 were approximately $7.2 million and $7.1 million in 2007. 

25 Table 2.2.8.6-3. Cooper Nuclear Station, Unit 1 Estimated Tax Distribution, 2005–2007 

Tax 2005 2006 2007 

Nebraska State Sales/Use Tax $1,082,780 $1,353,435 $943,020 

City of Auburn, NE Sales/Use Tax 240 455 40 

Special Assessment on Brownville-Nemaha Levee Paid to 

Nemaha County 

5,090 5,090 5,090 

Nemaha County, NE Real Estate Taxes 10,865 10,980 11,140 

Atchison County, MO Real Estate Taxes 145 145 140 

Nebraska in Lieu of Taxes to Counties with NPPD Retail 

Electric Sales Attributed to the CNS-1 

1,607,135 1,595,752 1,687,056 

Payments to Retail Communities Attributed to CNS-1 4,267,771 4,233,381 4,436,089 

 Total $6,976,031 $7,201,244 $7,084,582 

26 Source: NPPD, 2008b 
Affected Environment 

Draft NUREG-1437, Supplement 41 2-72 February 2010 

1 2.2.9 Historic and Archaeological Resources 

2 This section discusses the cultural background and the known historic and archaeological 

3 resources at the CNS-1 site and in the surrounding area. 

4 2.2.9.1 Cultural Background 

5 CNS-1 is located on a 1,120 acre tract in the floodplain on the west bank of the Missouri River in 

6 Nemaha County, Nebraska. To the west of the site are bluffs. CNS-1 also owns an additional 

7 239 acres on the eastern side of the river in Atchison County, Missouri. The eastern bank is a 

8 densely forested area that periodically floods, with bluffs that run parallel to the river. The region 

9 around CNS-1 site contains prehistoric and historic Native American and Euro-American cultural 

10 resources. Twelve properties in Nemaha County are listed in the National Register of Historic 

11 Places (NRHP) (NPS, 2009). The nearest NRHP property is the Captain Meriwether Lewis 

12 Dredge. Seven NRHP properties are located in Atchison County. 

13 2.2.9.2 Prehistoric Periods 

14 First Arrivals

15 CNS-1 is situated in the Missouri River Valley on the eastern edge of the Central Great Plains 

16 and northwest edge of the Missouri Prairie-Timberlands. The first peoples began emigrating into 

17 the region toward the end of the Pleistocene (pre-Clovis ca. 11,500 years ago). There is a 

18 growing body of evidence indicating that a "First Arrivals" archeological period (circa. 13,000 

19 and 17,000 years ago) preceded the Paleo-Indian period. A handful of sites in the Central Plains 

20 date between about 13,000 and 17,000 years ago, however, most of these sites have limited 

21 evidence of human occupation (Hofman, 1996). Acceptance of archeological remains older than 

22 the long accepted Clovis Culture remains controversial (Hofman, 1996; Holen, 1994). 

23 Paleo-Indian Period

24 The Clovis Culture (ca. 11,500 years ago) is the earliest dated and accepted evidence of human 

25 habitation during the Paleo-Indian period in the New World. The climate during the Paleo-Indian 

26 period was much cooler and wetter than today. The eastern edge of the Central Plains was 

27 broad open grassland occupied by great herds of now extinct animals. Paleo-Indian populations 

28 were highly mobile and left little evidence of their activities. Most Paleo-Indian sites would have 

29 been short-term occupations (campsites). Paleo-Indian peoples subsisted on hunted game and 

30 gathered plant material. Distinctive point styles and variations in other tool types defined the 

31 Clovis, Folsom, Midland, and later Paleo-Indian groups (Hofman, 1996). To date, no early sites 

32 have been identified in Nemaha or Atchison counties, but such resources may exist as deeply 

33 buried deposits along relic terraces. 

34 Archaic Period

35 During the Archaic Period, subsistence hunting and gathering underwent changes to adapt to 

36 resource availability. As glaciers retreated northward and larger animals disappeared from the 

37 region, humans adapted to modern plants and smaller game animals. The Dalton Culture 

38 (circa 8,500 to 7,500 years ago) is generally identified as late Paleo-Indian or Early Archaic 

39 period or as a transition between the two (O’Brien and Wood, 1995). The Archaic period is 

40 subdivided into the following periods: Early Archaic Logan Creek Complex (circa 7,500 to 6,000 

41 years ago), Middle Archaic Jacomo Complex (circa 5,500 to 5,000 years ago) and Late Archaic 

42 Nebo Hill Complex (circa 4,500 to 2,500 years ago). Early Archaic people did not appear to 

43 establish permanent settlements, though there is evidence that some locations were utilized 
Affected Environment 

February 2010 2-73 Draft NUREG-1437, Supplement 41 

1 frequently. Archaic people collected, hunted, and gathered most of what they needed for 

2 survival in their home territory with a wider range of tools. 

3 Climatic conditions during the Archaic Period entered a warmer/dryer phase around 5,500 years 

4 ago. Late Archaic cultures began to settle in the Missouri River Valley about 3,000 years ago. 

5 Archaeological evidence indicates that larger; semi-permanent warm weather settlements were 

6 established along the higher terraces, while winter encampments were located in upland areas 

7 along small streams. Archaic sites identified in the CNS-1 area typically consist of lithic scatters 

8 with various dart points identified as “Archaic”. 

9 Woodland Period

10 The Woodland period (circa. 2,500 to 1,000 years ago) is defined by the introduction of 

11 agriculture to augment subsistence hunting and gathering. The reliance on agriculture led to the 

12 establishment of permanent settlements during this period. Other characteristics of Woodland 

13 culture include increased population, emergence of social hierarchy, expanded interregional 

14 trade, elaborate ceremonialism with stone-lined graves and burial mounds, and the introduction 

15 of the bow and arrow. 

16 During the middle Woodland period (circa 2,000 to 1,500 years ago), indigenous groups began 

17 increasing in population). Woodland peoples spread along valleys over the entire eastern half of 

18 Nebraska, western part of Iowa, and parts of South Dakota and Kansas. These people were 

19 forager-gardeners living in small villages along the higher valley terraces. Several Middle 

20 Woodland sites have been identified in Nemaha and Atchison counties. 

21 During the late Woodland period (circa 1,500 to 1,100 years ago), larger middle Woodland 

22 villages were abandoned in favor of smaller camps and individual home sites, generally in the 

23 uplands away from the river bottoms. The number of burial mounds increased dramatically. 

24 Most of the mounds were small and low with distinctive rock structures. Many mounds have 

25 been lost to plowing, but rock structures around graves are commonly found on bottom terraces 

26 and points on both sides of the river. 

27 Plains Village Period

28 Around 1,000 years ago, most groups had established permanent villages. The Plains Village 

29 peoples were farmers and bison hunters living in larger villages along the river terraces. Smaller 

30 hamlets, hunting camps, and kill sites have also been recorded in the uplands. This culture 

31 disappeared about 700 years ago for unknown reasons. Climatic conditions during this time 

32 were becoming warmer and dryer, and drought may have forced people out of traditional 

33 farming areas. Additionally, there was an influx of people coming onto the Plains from the 

34 northeast and west that may have made living in the region untenable. 

35 2.2.9.3 Historic Period 

36 Historic Tribes and Fur Traders

37 The eighteenth and nineteenth centuries brought the first wave of Europeans to the east Central 

38 Plains region. French, and later Spanish land claims, inspired trade and exploration of the 

39 Missouri River Valley. French fur traders were known to visit the area. Indian populations were 

40 subsequently displaced. 

41 Traffic along the Missouri River increased after the Louisiana Purchase in 1803. The Lewis and 

42 Clark expedition of 1804 paved the way for subsequent U.S. military expeditions and the 
Affected Environment 

Draft NUREG-1437, Supplement 41 2-74 February 2010 

1 establishment of trading posts and missions. On July 13, 1804, the Lewis and Clark expedition 

2 passed the remains of a trading post said to have been where Benet of St. Louis traded with the 

3 Otoe and Pawnee for two years. Other American Indian groups that passed through the area 

4 included the Omaha, Osage, Delaware, Pottawatomi, Sauk and Fox, Winnebago, and Miami. 

5 On July 15, 1804, the Lewis and Clark party camped along a rise on the west side of a bend in 

6 the river. There is some dispute about the actual location of the encampment. Nebraska 

7 researchers place the camp on the Missouri side of the present river channel and Missouri 

8 historians place the camp roughly where the CNS-1 is located. 

9 Historic accounts of the Lewis and Clark expedition describe a beautiful valley filled with grape 

10 vines and wild cherries, which first attracted settlers to the area in the 1840s 

11 (Plamondon, 2000). Settlement was gradual, but steadily spread along the eastern side of the 

12 river (National Historical Company, 1882). The Kansas-Nebraska Act of 1854 created the 

13 Nebraska Territory. Nemaha County was established a year later (Heritage, 2004). Settlement 

14 along the river increased in the 1850s with Brownville, Nebraska, being established as a major 

15 steamboat port and shipping point. The towns of Nemaha, Brownville, and Peru prospered 

16 along the bluffs above the Missouri River, and settlement of the interior away from the river 

17 remained low until the Nebraska Railway Company reached the area in 1874 (Heritage, 2004). 

18 An 1865 Government Land Office plat showed two farmsteads located on or near the area 

19 occupied by the CNS-1. By 1911, there were nine homesteads and a school. 

20 The arrival of railroads spurred the development of the interior areas away from the river at the 

21 expense of the towns located along the bluff tops. Brownville rapidly declined because of this. 

22 The building of the Brownville Bridge in 1939 connected the two sides of the river but did little to 

23 alleviate the town's economic downfall. 

24 Construction of CNS-1 began in 1968. Consumers Public Power District (CPPD) planned and 

25 financed the construction and became NPPD on January 1, 1970 (NPPD, 2008). 

26 2.2.10 Historic and Archaeological Resources at the Cooper Nuclear Station, Unit 1 Site 

27 No prehistoric or historic sites listed or eligible for listing on the NRHP or the State historic 

28 registers are located on the CNS-1 site. Historic archaeological sites have been identified within 

29 a 6-mile radius of the site. A great deal of archaeological and historical research has been 

30 conducted within both Nemaha County, Nebraska and Atchison County, Missouri. The bluffs 

31 along either side of the Missouri River and the higher terraces along the river valley bottom 

32 lands were favored habitation sites for prehistoric and historic people. 

33 Only one previous historical survey has been conducted on the CNS-1 property. This survey 

34 evaluated the eligibility of the William Dawson House located in the southwest corner of the 

35 CNS-1 site near the bluff for listing on the NRHP. The William Dawson House (Site # NH00-69) 

36 was recorded in Nebraska historic archives but was not included on the NRHP. The Dawson 

37 House was torn down in 1970, shortly after it was recorded. 

38 A formal survey of the entire CNS-1 property has not been completed, however, a number of 

39 archaeological surveys have been conducted in the surrounding area. In the 1930s, A.T. Hill 

40 and Paul Cooper walked the bluffs along both sides of the river valley in search of Woodland 

41 mound sites. The Whitten Archeological Site, Archeological Survey No. 25NH4, was excavated 

42 along the bluffs north of the CNS-1 site. Despite the fact that the mounds were reportedly 

43 leveled by cultivation, excavations succeeded in locating two concentrations of human remains 
Affected Environment 

February 2010 2-75 Draft NUREG-1437, Supplement 41 

1 along with grave goods and other artifacts (Hill and Cooper, 1937). The Nebraska State 

2 Historical Society Site Survey Form notes that: “... (two) skeletons were sent to U.S. National 

3 Museum in accordance with our WPA (Works Progress Administration) contract.” The note is 

4 dated June 21, 1944. It is unclear from the archaeological site description if the Whitten site 

5 extended onto the CNS-1 property. 

6 In April 2007 and March 2008, NPPD contracted with Enercon Services, Inc. to conduct a 

7 Phase 1A Literature Review and Archeological Sensitivity Assessment for the CNS-1 site. The 

8 55 acres occupied by the CNS-1 were heavily disturbed. The Enercon study identified two 

9 probable prehistoric lithic scatters and three former historic home sites on the CNS-1 site. The 

10 report also noted the potential for additional prehistoric and historic resources to be found 

11 throughout the area. Enercon also noted the potential for a camp site occupied by the Lewis and 

12 Clark Expedition in 1804 being located on CNS-1 property. The exact location of this campsite 

13 remains unknown. 

14 2.3 RELATED FEDERAL AND STATE ACTIVITIES 

15 The NRC staff reviewed the possibility that activities of other Federal agencies might impact the 

16 renewal of the operating license for the CNS-1. Any such activity could result in cumulative 

17 environmental impacts and the possible need for a Federal agency to become a cooperating 

18 agency in the preparation of the CNS-1 SEIS. 

19 The NRC has determined that there are no Federal projects that would make it desirable for 

20 another Federal agency to become a cooperating agency in the preparation of the SEIS. 

21 Federal lands, facilities, national wildlife refuges, forests, and parks within 50 miles of the CNS-1 

22 are listed below. 

23 ● Langdon Bend, 1 mile south-southeast (USACE) 

24 ● Derion Bend, 8 miles southeast (USACE) 

25 ● Nishnabotna, 9 miles north-northwest (USACE) 

26 ● Corning, 12 miles southeast (USACE) 

27 ● Kansas Bend, 12 miles north-northwest (USACE) 

28 ● Thurnau, 15 miles southeast (USACE) 

29 ● Lower Hamburg Bend, 15 miles north-northwest (USACE) 

30 ● Hamburg Bend, 17 miles north-northwest (USACE) 

31 ● Rush Bottom Bend, 22 miles southeast (USACE) 

32 ● Sac and Fox Reservation, 23 miles south-southeast (U.S. Department of 

33 the Interior, Bureau of Indian Affairs) 

34 ● Iowa Reservation, 26 miles south-southeast (U.S. Department of the 

35 Interior, Bureau of Indian Affairs) 
Affected Environment 

Draft NUREG-1437, Supplement 41 2-76 February 2010 

1 ● Squaw Creek National Wildlife Refuge, 28 miles southeast (USFWS) 

2 ● Copeland Bend, 29 miles north-northwest (USACE) 

3 ● Auldon Bar, 36 miles north-northwest (USACE) 

4 ● Noddleman Island, 39 miles north-northwest (USACE) 

5 ● Tobacco Island, 43 miles north-northwest (USACE) 

6 NRC is required under Section 102(2)(c) of the National Environmental Policy Act of 1969 

7 (NEPA) to consult with and obtain the comments of any Federal agency that has jurisdiction by 

8 law or special expertise with respect to any environmental impact involved. Federal Agency 

9 consultation correspondence and comments on the SEIS are presented in Appendix E. 

10 2.4 REFERENCES 

11 10 CFR Part 20. Code of Federal Regulations, Title 10, Energy, Part 20, “Standards for 

12 Protection Against Radiation.” 

13 10 CFR Part 50. Code of Federal Regulations, Title 10, Energy, Part 50, “Domestic Licensing of 

14 Production and Utilization Facilities.” 

15 10 CFR Part 61. Code of Federal Regulations, Title 10, Energy, Part 61, “Licensing 

16 Requirements for Land Disposal of Radioactive Waste.” 

17 10 CFR Part 71. Code of Federal Regulations, Title 10, Energy, Part 71, “Packaging and 

18 Transportation of Radioactive Material.” 

19 50 CFR Part 22. Code of Federal Regulations, Title 50.Wildlife and Fisheries, Part 22, 

20 “Pastports and Visas.” 

21 Abell, R., Olson, D., et al. 2000. Freshwater Ecoregions of North America. Island Press, 

22 Washington, D.C. 

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24 for Freshwater Biodiversity Conservation. BioScience 58(5), pp. 403–414. 

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28 Barbour, M.T., J. Gerritsen, B.D. Snyder, and J.B. Stribling. 1999. Rapid Bioassessment 

29 Protocols for Use in Streams and Wadeable Rivers: Periphyton, Benthic Macroinvertebrates 

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31 Water; Washington, D.C. 

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34 Preserving North America’s Most Endangered Ecosystem. Island Press, Washington, D.C. 

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36 Program. Ferret Facts. Available URL: http://www.blackfootedferret.org/history-decline.htm

37 (accessed July 30, 2009). 
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February 2010 2-77 Draft NUREG-1437, Supplement 41 

1 Bureau of Business Research (BBR). 2008. University of Nebraska-Lincoln. College of Business 

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3 Available URL: http://www.bbr.unl.edu/PopProjections/ (accessed April 17, 2009). 

4 Carter, S.R., K.R. Bazata, and D.L. Anderson. 1982. Chapter 7: Macroinvertebrate communities 

5 of the channelized Missouri River near Two Nuclear Power Stations. Hesse, L.W., G.L. 

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7 Collection of Papers on the Biology with Special Reference to Power Station Effects. The 

8 Missouri River Group, Norfolk, Nebraska, pp. 146–182. 

9 Conestoga Rover and Associates (CRA). 2007. Hydrogeologic Investigation Work Plan, Ground 

10 Water Protection Initiative, Cooper Nuclear Station, Brownsville, Nebraska. 

11 Cornell University. 2008. Insect Conservation Biology. Cicindela nevadica lincolniana, Salt 

12 Creek tiger beetle. Available URL: http://courses.cit.cornell.edu/icb344/abstracts/salt-creek13 tiger-beetle.htm (accessed March 9, 2009). 

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15 S. Postel, S.H. Schneider, D. Tilman, and G.M. Woodwell. 1997. Ecosystem services: Benefits 

16 supplied to human societies by natural ecosystems. Issues in Ecology 2:1–16. 

17 Defenders of Wildlife. 2009. Black-footed ferret (Mustela nigripes). Available URL: 

18 http://www.defenders.org/wildlife_and_habitat/wildlife/black-footed_ferret.php 

19 (accessed March 9, 2009). 

20 Dryer, M.P., and A.J. Sandvol 1993. “Recovery plan for the pallid sturgeon Scaphirhynchus 

21 albus.” U.S. Fish and Wildlife Service, Bismarck, North Dakota. 55 pp. 

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23 Requisite to Protect Public Health and Welfare with an Adequate Margin of Safety." Report 

24 550/9-74-004, Washington, D.C. Available URL: 

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28 Environmental Protection Agency (EPA). 2002. Short-term Methods for Estimating the Chronic 

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32 http://www.epa.gov/osw/ (accessed May 2009). 

33 Environmental Protection Agency (EPA). 2009b. “Safe Drinking Water Information System, 

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35 Atchison County, Missouri. Available URL: http://www.epa.gov/safewater/dwinfo/index.html. 

36 (accessed April 7, 2009). 

37 Environmental Protection Agency (EPA). 2009c. “Waste minimization.” Available URL: 

38 http://www.epa.gov/osw/hazard/wastemin/minimize/faqs.htm#wastemin (accessed May 2009). 

39 Federal Register, Vol 63, Number 109. Page 31267-31317 (63 FR 31268). Emergency 

40 Planning and Community Right-to-Know Programs; Amendments to Hazardous Chemical 

41 Reporting Thresholds, Streamlining Requirements, June 8, 1998 

42 Farrell, J.R. and M.A. Tesar. 1982. Chapter 5: Periphytic algae in the channelized Missouri 

43 River with special Emphasis on apparent optimal temperatures. Hesse, L.W., G.L. Hergenrader, 

44 H.S. Lewis, S.D. Reetz, and A.B. Schlesinger (eds.), The Middle Missouri River: A Collection of 
Affected Environment 

Draft NUREG-1437, Supplement 41 2-78 February 2010 

1 Papers on the Biology with Special Reference to Power Station Effects. The Missouri River 

2 Group, Norfolk, Nebraska, pp. 84–123. 

3 Galat, D.L., C.R. Berry, Jr., E.J. Peters, and R.G. White. 2005a. Missouri River Basin. A.C. 

4 Benke and C.E. Cushing (eds.), Rivers of North America. Elsevier Academic Press, New York, 

5 pp. 84–123. 

6 Galat, D.L., C.R. Berry, Jr., W.M. Gardner, J.C. Hendrickson, G.E. Mestl, G.J. Power, C. Stone, 

7 and M.R. Winston. 2005b. Spatiotemporal patterns and changes in Missouri River Fishes. 

8 American Fisheries Society Symposium 45:249–291. 

9 Gerrity, P.C. and C. Guy. 2006. Juvenile pallid sturgeon are piscivorous: A call for conserving 

10 native cyprinids. Transactions of the American Fisheries Society 135:604–609. 

11 Great Plains Energy, Inc. 2009. LocationOne® Copyright 2001–2009, Nebraska City, Nebraska 

12 and Falls City, Nebraska. Available URL: http://www.fallscityedge.com/linkslibrary.asp 

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14 (accessed April 10, 2009). 

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16 Heritage Research Ltd. Historical/Environmental Consultants, Menomonee Falls, Wisconsin. 

17 August 2004. 

18 Hergenrader, G.L., L.G. Harrow, R.G. King, G.F. Cada, and A.B. Schlesinger, 1982. Chapter 8: 

19 Larval fishes in the Missouri River and the effects of entrainment. Hesse, L.W., G.L. 

20 Hergenrader, H.S. Lewis, S.D. Reetz, and A.B. Schlesinger (eds.), The Middle Missouri River: A 

21 Collection of Papers on the Biology with Special Reference to Power Station Effects. The 

22 Missouri River Group, Norfolk, Nebraska, pp. 184–223. 

23 Hesse, L.W., Q.P. Bliss, and G.J. Zuerlein. 1982a. Chapter 9: Some aspects of the ecology of 

24 adult fishes in the channelized Missouri River with special reference to the effects of two nuclear 

25 power generating plants. Hesse, L.W., G.L. Hergenrader, H.S. Lewis, S.D. Reetz, and A.B. 

26 Schlesinger (eds.), The Middle Missouri River: A Collection of Papers on the Biology with 

27 Special Reference to Power Station Effects. The Missouri River Group, Norfolk, Nebraska, 

28 pp. 224–276. 

29 Hesse, L.W., G.L. Hergenrader, H.S. Lewis, S.D. Reetz, and A.B. Schlesinger. 1982b. The 

30 Middle Missouri River: A Collection of Papers on the Biology with Special Reference to Power 

31 Station Effects. The Missouri River Group, Norfolk, Nebraska. 

32 Hill, A.T., and P. Cooper. 1937. “The Archaeological Campaign of 1937.” Nebraska History 

33 Magazine. 18(4):241–359. 

34 Hofman, Jack L. 1996. “Early Hunter-Gatherers of the Central Great Plains: Paleoindian and 

35 Mesoindian (Archaic) Cultures.” Archeology and Paleoecology of the Central Great Plains. 

36 Arkansas Archeological Survey Research Series No. 48. 

37 Holen, Steven R. 1994. “Did Someone Eat the La Sena Mammoth? The Cellars of Time: 

38 Paleontology and Archaeology in Nebraska. NEBRASKAland Magazine. Vol. 72, No. 1. 

39 Nebraska Game and Parks Commission. 

40 Hrabik, R. A., Herzog, D. P., Ostendorf, D. E., and Petersen, M. D. 2007. Larvae provide first 

41 evidence of successful reproduction by pallid sturgeon, Scaphirhynchus albus, in the Mississippi 

42 River. Journal of Applied Ichthyology 23(4):436–443. 

43 Hurleya, K.L., R.J. Sheehan, R.C. Heidinger, P.S. Wills, and B. Clevenstine. 2004. Habitat Use 

44 by Middle Mississippi River Pallid Sturgeon. Transactions of the American Fisheries Society 

45 133:1033–1041. 
Affected Environment 

February 2010 2-79 Draft NUREG-1437, Supplement 41 

1 Illinois Wildflowers. 2009. Available URL: http://www.illinoiswildflowers.info/index.htm (accessed 

2 May 11, 2009). 

3 Institute of Educational Science (IES). 2009. U.S. Department of Education, National Center for 

4 Educational Statistics. “College Opportunities Online Locator.” Zip Code 68321. Data release 

5 date March 6, 2009. Available URL: http://nces.ed.gov/ipeds/cool/RefineSearch.aspx (accessed 

6 April 17, 2009). 

7 Kansas Wildflowers and Grasses. 2009. Available URL: http://www.kswildflower.org/index.php

8 (accessed May 11, 2009). 

9 Karr, J.R., L.A. Toth, and D.R. Dudley. 1985. Fish Communities of Midwestern Rivers: A History 

10 of Degradation. BioScience 15(2):90–95. 

11 Kynard, B., E. Henyey, and M. Horgan. 2002. Ontogenetic behavior, migration, and social 

12 behavior of pallid sturgeon, Scaphirhynchus albus, and shovelnose sturgeon, S. platorynchus, 

13 with notes on the adaptive significance of body color. Environmental Biology of Fishes 

14 63:389–403. 

15 Missouri Conservation Department. 2009. Missouri Species and communities of Concern 

16 Checklist. January 2009. Available at URL: http://mdc4.mdc.mo.gov/Documents/145.pdf

17 (accessed March 17, 2009). 

18 Missouri Department of Natural Resources (MDNR). 2008. Census of Missouri Public Water 

19 Systems 2008. Division of Environmental Quality. Water Protection Program, Public Drinking 

20 Water Branch. January 24, 2008. Available URL: http://www.dnr.mo.gov/pubs/pub2250.pdf

21 (accessed April 7, 2009). 

22 Missouri Plants. 2007. Photographs and descriptions of the flowering and non-flowering plants 

23 of Missouri, USA. February 2007. Available URL: http://www.missouriplants.com/ (accessed 

24 April 21, 2009). 

25 Missouri State Demographer. (ND). Missouri Population Projections by County 2000 to 2030. 

26 Available URL: http://oa.mo.gov/bp/projections/totalpop.html 

27 (accessed April 17, 2009). 

28 Missouri Botanical Garden (MOBOT). 2009. Plant Finder. Available URL: 

29 http://www.mobot.org/gardeninghelp/plantfinder/Alpha.asp (accessed May 6, 2009). 

30 Missouri Department of Conservation (MDC). 2009a. Endangered Species Guidesheet. Indiana 

31 bat – Myotis sodalis. Available URL: http://mdc.mo.gov/nathis/endangered/endanger/bat/

32 (accessed March 4, 2009). 

33 Missouri Department of Conservation (MDC). 2009b. MDC Heritage Database Results for 

34 Atchison County. Available URL: http://mdc.mo.gov/cgi35 bin/heritage/search.cgi?county=Atchison (accessed April 21, 2009). 

36 Missouri Department of Conservation (MDC). 2009c. Missouri Species and Communities of 

37 Conservation Concern, Checklist. January 2009. 

38 Missouri Department of Conservation (MDC). 2009d. Letter from D. Brown, Policy Coordinator, 

39 Missouri Department of Conservation, Headquarters, to R. Bulavinetz, Aquatic Ecologist, 

40 Division of License Renewal, Nuclear Regulatory Commission. Subject: Cooper Nuclear Plant. 

41 March 26, 2009. ADAMS Accession No. ML091030465. 

42 Minnesota Department of Natural Resources (MN DNR) 1991. Western prairie fringed orchid: a 

43 threatened Midwestern prairie plant. Available URL: 
Affected Environment 

Draft NUREG-1437, Supplement 41 2-80 February 2010 

1 http://files.dnr.state.mn.us/natural_resources/ets/fringed_orchid.pdf?bcsi_scan_B6C3A1920618

2 BACA=0&bcsi_scan_filename=fringed_orchid.pdf (accessed March 4, 2009). 

3 Missouri Botanical Garden (MOBOT). 2009. Plant Finder. Available URL: 

4 http://www.mobot.org/gardeninghelp/plantfinder/Alpha.asp (accessed May 6, 2009). 

5 Michigan State University (MSU). 2007. Michigan Natural Features Inventory. 

6 Rare Species Explorer (Web Application). Available URL: 

7 http://web4.msue.msu.edu/mnfi/explorer/species.cfm?id=15154 (accessed May 11, 2009). 

8 National Academies of Sciences (NAS). 2002. The Missouri River Ecosystem. National 

9 Research Council, National Academies Press, Washington, D.C. 

10 National Climatic Data Center (NCDC). 2009. Wind - Average wind speed. Available URL: 

11 http://lwf.ncdc.noaa.gov/oa/climate/online/ccd/avgwind.html (accessed May, 2009). 

12 National Climatic Data Center (NCDC). 2009a. Query results: Tornado occurrences in Nemaha 

13 County, NE, 1950 – 2009. ADAMS Accession No. ML091750118. 

14 National Historical Company. 1882. History of Holt and Atchison Counties, Missouri. National 

15 Historical Company, St. Joseph, Missouri. 

16 National Park Service (NPS). 2009. National Register of Historic Places Information System, 

17 Nemaha County, Nebraska. Available URL: www.nr.nps.gov (accessed July 28, 2009). 

18 National Park Service (NPS). 2009. National Register of Historic Places Information System, 

19 Atchison County, Missouri. Available online at: www.nr.nps.gov (accessed July 28, 2009). 

20 National Research Council, Committee on Missouri River Ecosystem Science. 2002. The 

21 Missouri River Ecosystem: Exploring the Prospects for Recovery. National Academy Press, 

22 Washington, D.C. 188 pp. [Note: on CD from Cooper] 

23 Natural Resource Conservation Service (NRCS). 2000. Missouri EPA Ecoregion Map. Available 

24 URL: http://www.mo.nrcs.usda.gov/technical/nat_res_data/mo_ecoregion/out/usepa.pdf 

25 (accessed April 17, 2009). 

26 Natural Resource Conservation Service (NRCS). 2007. List of common plants found along the 

27 Missouri River in Atchison Co., Missouri. 

28 Natural Resource Conservation Service (NRCS). 2009. Plants Database. Plants Profile. 

29 Available URL: http://plants.usda.gov/index.html (accessed May 6, 2009). 

30 NatureServe. 2008a. NatureServe Explorer. Version 7.1. Whooping Crane. Available URL: 

31 http://www.natureserve.org/explorer/servlet/NatureServe?searchSciOrCommonName=whoopin

32 g+crane (accessed March 9, 2009). 

33 NatureServe. 2008b. NatureServe Explorer. Version 7.1. Salt Creek tiger beetle. Available URL: 

34 http://www.natureserve.org/explorer/servlet/NatureServe?searchSciOrCommonName=salt+cree

35 k+tiger+beetle (accessed March 9, 2009). 

36 NatureServe. 2009a. NatureServe Explorer. Version 7.1. Piping Plover. Available URL: 

37 http://www.natureserve.org/explorer/servlet/NatureServe?searchSciOrCommonName=piping+pl

38 over&x=8&y=10 (accessed March 3, 2009). 

39 NatureServe. 2009b. NatureServe Explorer. Version 7.1. Interior least tern. Available URL: 

40 http://www.natureserve.org/explorer/servlet/NatureServe?searchName=Sterna+antillarum

41 (accessed March 3, 2009). 
Affected Environment 

February 2010 2-81 Draft NUREG-1437, Supplement 41 

1 NatureServe. 2009c. NatureServe Explorer. Version 7.1. Black-footed ferret. Available URL: 

2 http://www.natureserve.org/explorer/servlet/NatureServe?searchSciOrCommonName=black+fo

3 oted+ferret (accessed March 9, 2009). 

4 NatureServe. 2009d. NatureServe Explorer. Version 7.1. Plant/Animal Records for Atchison 

5 County, Missouri. Available URL: 

6 http://www.natureserve.org/explorer/servlet/NatureServe?loadTemplate=tabular_report.wmt&pa

7 ging=home&save=all&sourceTemplate=reviewMiddle.wmt (accessed March 9, 2009). 

8 NatureServe. 2009e. NatureServe Explorer. Version 7.1. Plant/Animal Records for Nebraska 

9 Counties. Available URL: http://www.natureserve.org/explorer/servlet/NatureServe 

10 (accessed March 9, 2009). 

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12 December 5, 2004 

13 Nebraska State Constitution Article VIII-11. Nebraska State Constitution 

14 Nebraska Department of Agriculture (NDA). 2008. Press Release: NDA Adds Phragmites to 

15 Noxious Weed List Under Temporary Order. April 15, 2008. Available URL: 

16 http://www.agr.state.ne.us/newsrel/april2008/phragmites.htm (accessed March 9, 2009). 

17 Nebraska Department of Economic Development (NDED) and Nebraska Public Power District 

18 (NPPD). 2008. Nebraska Community “Fast Facts” Profile, Auburn, Nebraska. Available URL: 

19 http://sites.nppd.com/aedc/fastfacts.asp?city=Auburn (accessed April 10, 2009). 

20 Nebraska Department of Economic Development and Nebraska Public Power District (NPPD). 

21 2009. “Nebraska Community 'Fast Facts' Profile, Auburn, Nebraska—Date Generated: 

22 4/10/2009.” Fast Facts Community Profiles sponsored by Nebraska Department of Economic 

23 Development and Nebraska Public Power District. Available online at 

24 http://sites.nppd.com/aedc/fastfacts.asp?form=CP&city=Auburn&submit=Run+Report. 

25 Accessed on April 10, 2009. 

26 Nebraska Department of Education (NDE) Data Center. 2009. 2008–2009 County Membership 

27 by Grade. March 6, 2009. Available URL: 

28 http://ess.nde.state.ne.us/DataCenter/DataInformation/ and link to County Membership by 

29 Grade(accessed April 15, 2009). 

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31 Class V Underground Injection Wells. 

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33 Quality Integrated Report. Lincoln, Nebraska. March 2004. 

34 Nebraska Department of Environmental Quality (NDEQ). 2008. Annual Air Quality Report 

35 Nebraska Air Quality 2007. Nebraska Department of Environmental Quality, Air Quality Division.

36 ADAMS Accession No. ML091750103 

37 Nebraska Department of Environmental Quality (NDEQ). 2009. 2009 Ambient Air Monitoring 

38 Network Plan. ADAMS Accession No. ML091750088

39 Nebraska Health and Human Services System (NHHSS). 2000. Permit No. NE3150505 for 

40 Non-Community Public Water Supply System. 

41 Nebraska Department of Natural Resources (NDNR) 2009. Statewide aerial maps. Available 

42 URL: http://dnrmap2.dnr.state.ne.us/website/doqviewer/viewer.htm (accessed April 16, 2009). 
Affected Environment 

Draft NUREG-1437, Supplement 41 2-82 February 2010 

1 Nebraska Department of Natural Resources (NDNR). 2008. Registered Ground Water Wells 

2 Data Retrieval. Available URL http://www.dnr.state.ne.us/dnrnews/news2009/April2009.pdf 

3 (accessed February 13, 2009). 

4 Nebraska Department of Roads (NDOR). 2007. Traffic Volume Maps and Info. Available URL: 

5 http://www.nebraskatransportation.org/maps/#traffvol. (accessed April 14, 2009). 

6 Nebraska Legislature. 2008. Constitution Article VIII, Section 11. Available URL: 

7 http://uniweb.legislature.ne.gov/laws/articles.php?article=VIII-11. (accessed April 16, 2009). 

8 Nebraska Public Power District (NPPD). 1971. Applicant’s Environmental Report, Operating 

9 License Stage, Cooper Nuclear Station. 

10 Nebraska Public Power District (NPPD). 2004a. Cooper Nuclear Station, Annual Radioactive 

11 Effluent Release Report for 2003. Brownville, Nebraska. ADAMS Accession No. ML041190422. 

12 Nebraska Public Power District (NPPD). 2005a. Cooper Nuclear Station, Annual Radioactive 

13 Effluent Release Report for 2004. Brownville, Nebraska. ADAMS Accession No. ML051220511. 

14 Nebraska Public Power District (NPPD). 2006a. Cooper Nuclear Station, Annual Radioactive 

15 Effluent Release Report for 2005. Brownville, Nebraska. ADAMS Accession No. ML061240548. 

16 Nebraska Public Power District (NPPD). 2006b. Nebraska Public Power District Power Line 

17 Rights-of-way Vegetation Management Program. 

18 Nebraska Public Power District (NPPD). 2006c. Proposal for Information Collection, Cooper 

19 Nuclear Station. January 2006. ADAMS Accession No. ML092510103 

20 Nebraska Public Power District (NPPD). 2007a. Cooper Nuclear Station, Annual Radioactive 

21 Effluent Release Report for 2006. Brownville, Nebraska. ADAMS Accession No. ML071240393. 

22 Nebraska Public Power District (NPPD). 2007b. Corporate Environmental Manual. Chapter 3: 

23 Land Disturbing Activities. December 2007. 

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25 http://www.nppd.com/newsroom/annual_report_2006/06financials.pdf. (accessed April 16, 

26 2009). 

27 Nebraska Public Power District (NPPD). 2008. License Renewal Application, Cooper Nuclear 

28 Station, Appendix E, Applicant’s Environmental Report, Operating License Renewal Stage. 

29 ADAMS Accession No. ML083030246. 

30 Nebraska Public Power District (NPPD). 2008b. Cooper Nuclear Station, Annual Radioactive 

31 Effluent Release Report for 2007. Brownville, Nebraska. ADAMS Accession No. ML081300029. 

32 Nebraska Public Power District (NPPD). 2008c. 2007 Annual Report. Available URL: 

33 http://www.nppd.com/newsroom/annual_report_2007/07financials.pdf. 

34 (accessed April 16, 2009). 

35 Nebraska Public Power District (NPPD). 2008d. Letter from Joe Citta, NPPD to Robert Harms, 

36 USFWS re: Cooper Nuclear Station License Renewal—Habitat Development Proposal. 

37 September 26, 2008. ADAMS Accession No. ML092520156. 

38 Nebraska Public Power District (NPPD). 2009a. Letter from Joe L. Citta, Jr., Corporate 

39 Environmental Manager, NPPD, to June M. DeWeese, Nebraska Field Supervisor, U.S. Fish 

40 and Wildlife Service, Grand Island. Subject: Cooper Nuclear Plant. May 8, 2009. 

41 ADAMS Accession No. ML091830056. 

42 Nebraska Public Power District (NPPD). 2009b. “About Us.” Available URL: 

43 http://www.nppd.com/About%5FUs/. (accessed April 14, 2009). 
Affected Environment 

February 2010 2-83 Draft NUREG-1437, Supplement 41 

1 Nebraska Public Power District (NPPD). 2009c. Response to Request for Additional Information 

2 for License Renewal Application Environmental Report Cooper Nuclear Station, Docket No. 50-

3 298, DPR-46, Attachment 1: Low Emitter Status for NPPD’s Cooper Nuclear Station, NDEQ 

4 Facility ID #36750. March 27, 2009. ADAMS Accession No. ML091600712. 

5 Nebraska Game and Parks Commission (NGPC). 2008. Estimated Current Ranges of 

6 Threatened and Endangered Species: List of Species by County. Available URL: 

7 http://www.ngpc.state.ne.us/wildlife/programs/nongame/TandESpecies.pdf 

8 (accessed April 21, 2009). 

9 Nebraska Game and Parks Commission (NGPC). Spring Migration Guide. About Whooping 

10 Cranes. Available URL: http://www.ngpc.state.ne.us/wildlife/guides/migration/whooping.asp

11 (accessed March 9, 2009). 

12 Nebraska Game and Parks Commission (NGPC). 2009b. Nebraska Wildlife Species. Least 

13 Tern, an Endangered Species. Available URL: http://www.ngpc.state.ne.us/wildlife/ltern.asp

14 (accessed March 3, 2009). 

15 Nebraska Game and Parks Commission (NGPC). 2009c. Species-by-County List for Selected 

16 Nebraska Counties. May 8, 2009. ADAMS Accession No. ML092110589. 

17 New York State Department of Environmental Conservation (NYSDEC). 2009. Indiana Bat Fact 

18 Sheet. Available URL: http://www.dec.ny.gov/animals/6972.html (accessed March 4, 2009). 

19 Ohio Department of Natural Resources (ODNR). 1998. Species Fact Sheet. Carex bushii 

20 Mackenzie, Bush’s Sedge. Available URL: 

21 http://www.dnr.state.oh.us/Portals/3/Abstracts/Abstract_pdf/C/Carex_bushii.pdf 

22 (accessed May 11, 2009). 

23 O’Brien, Michael J. and Raymond Wood. 1995. The Prehistoric Archeological Record. Holocene 

24 Human Adaptations in the Missouri Prairie – Timberlands. Arkansas Archeological Survey 

25 Research Series No. 45. 

26 Plamondon II, Martin. 2000. Lewis and Clark Trail Maps: A Cartographic Reconstruction, Vol. 1. 

27 Washington State University Press. 

28 Rabeni, C.F. 1996. Chapter 8: Prairie Legacies—Fish and Aquatic Resources. Pages 111-

29 124 in F.B. Samson and F.L. Knopf (eds.), Prairie Conservation: Preserving North America’s 

30 Most Endangered Ecosystem. Island Press, Washington, D.C. 

31 Reetz, S.D. 1982. Chapter 4: Phytoplankton studies in the Missouri River at Fort Calhoun 

32 Station and Cooper Nuclear Station. Hesse, L.W., G.L. Hergenrader, H.S. Lewis, S.D. Reetz, 

33 and A.B. Schlesinger (eds.), The Middle Missouri River: A Collection of Papers on the Biology 

34 with Special Reference to Power Station Effects. The Missouri River Group, Norfolk, Nebraska, 

35 pp. 71–83. 

36 Repsys, A.J. and G.D. Rogers. 1982. Chapter 6: Zooplankton studies in the channelized 

37 Missouri River. Hesse, L.W., G.L. Hergenrader, H.S. Lewis, S.D. Reetz, and A.B. Schlesinger 

38 (eds.), The Middle Missouri River: A Collection of Papers on the Biology with Special Reference 

39 to Power Station Effects. The Missouri River Group, Norfolk, Nebraska, pp.124–145. 

40 Stehn, Tom. 2009. Tom Stehn’s Whooping Crane Report. Update: April 20, 2009, from the 

41 USFWS Whooping Crane Census Flight. Available URL: 

42 http://www.birdrockport.com/tom_stehn_whooping_crane_report.htm (accessed April 20, 2009). 

43 University of Nebraska-Lincoln (UNL). 2009. Lincoln, NE Weather and Climate. Lincoln monthly 

44 and annual normals 1971–2000. Available URL: http://www.lincolnweather.org/Lincoln-Monthly45 Normals.html (accessed June, 2009). 
Affected Environment 

Draft NUREG-1437, Supplement 41 2-84 February 2010 

1 University of Nebraska State Museum-Division of Zoology (UNSM). 2007a. Database report, 

2 Birds of Nemaha County. T.E. Labedz. 

3 University of Nebraska State Museum-Division of Zoology (UNSM) 2007b. Database report, 

4 Reptiles and amphibians of Nemaha County. T.E. Labedz. 

5 University of Wyoming (UWYO). 2002. State Species Abstract. Wyoming Natural Diversity 

6 Database. Dalea enneandra. Nine-anther dalea. January 2002. Available URL: 

7 http://www.uwyo.edu/wynddsupport/docs/Reports/SpeciesAbstracts/Dalea_enneandra.pdf

8 (accessed May 6, 2009). 

9 U.S. Army Corps of Engineers (USACE). 2002. Permit No. NE01-10322 for Maintenance 

10 Dredging of the CNS-1 Water Intake Structure. 

11 U.S. Army Corps of Engineers (USACE). 2004. Missouri River Master Water Control Manual, 

12 Final Environmental impact Statement Review and Update. March 2004. Northwestern Division, 

13 Omaha, Nebraska. 

14 U.S. Army Corps of Engineers (USACE). 2004b. Missouri River Mitigation Project. July 2004. 

15 Available URL: 

16 http://www.nwk.usace.army.mil/projects/mitigation/sites/hamburg_area/lanben.htm (accessed 

17 April 15, 2004). 

18 U.S. Army Corps of Engineers (USACE). 2007. Missouri River Mitigation Project. Available 

19 URL: http://www.nwk.usace.army.mil/projects/mitigation/

20 U.S. Department of Agriculture (USDA). 2009. 2007 Census of Agriculture. Iowa, Kansas, 

21 Missouri, Nebraska. Released February 4, 2009. Available URL: 

22 http://www.agcensus.usda.gov/Publications/2007/Online_Highlights/County_Profiles/index.asp. 

23 (accessed April 17, 2009). 

24 U.S. Census Bureau (USCB). 2009a. Surveys of Nemaha, Otoe, and Richardson Counties 

25 Nebraska and Atchison County, Missouri. Housing data for 2000 and 2007. Available URL: 

26 http://factfinder.census.gov and http://quickfacts.gov

27 U.S. Census Bureau (USCB). 2009b. Decennial Census 1900 to 1990 and 2000 Data and State 

28 and County QuickFacts for Nemaha County, Otoe County, and Richardson County, Nebraska, 

29 and Atchison County, Missouri. Available URL: http://quickfacts.census.gov (accessed March 

30 25, 2009). 

31 U.S. Census Bureau (USCB). 2009c. State and County QuickFacts for Nemaha County, Otoe 

32 County, and Richardson County, Nebraska, and Atchison County, Missouri. Available URL: 

33 http://quickfacts.census.gov (accessed March 25, 2009). 

34 U.S. Fish and Wildlife Service (USFWS). 1978. 50 CFR Part 17. Endangered and Threatened 

35 Wildlife and Plants; Determination of Critical habitat for the Whooping Crane, Vol. 43, pp. 

36 20938–20942. 

37 U.S. Fish and Wildlife Service (USFWS). 1997. “Piping plover (Charadrius melodius). An 

38 example of U.S./Canada Cooperation in the protection and recovery of endangered species”. 

39 Available URL: http://www.fws.gov/endangered/canada/plover.htm (accessed March 3, 2009). 

40 U.S. Fish and Wildlife Service (USFWS). 2000. Fact Sheet. Black-footed ferret (Mustela 

41 nigripes). Available URL: 

42 http://www.fws.gov/mountain-prairie/species/mammals/blackfootedferret/revfact.chy.pdf

43 (accessed March 9, 2009). 
Affected Environment 

February 2010 2-85 Draft NUREG-1437, Supplement 41 

1 U.S. Fish and Wildlife Service (USFWS). 2000b. Biological Opinion Regarding Missouri River 

2 Operations. November 2000. Available URL: 

3 http://www.nwd-mr.usace.army.mil/mmanual/opinion.html. (accessed June 16, 2009). 

4 U.S. Fish and Wildlife Service (USFWS). 2002. 50 CFR Part 17. Endangered and Threatened 

5 Wildlife and Plants; Designation of Critical Habitat for the Northern Great Plains Breeding 

6 Population of the Piping Plover; Final Rule, Vol. 67, pp. 57637–57717. 

7 U.S. Fish and Wildlife Service (USFWS). 2003a. Questions and Answers Regarding the U.S. 

8 Fish and Wildlife Service’s Supplemental Biological Opinion for the 2003 Missouri River 

9 Operations. Mountain Prairie Region. Updated March 21, 2003. Available URL: 

10 http://www.fws.gov/mountain%2Dprairie/missouririver/q&a_04222003.htm. 

11 (accessed June 17, 2009). 

12 U.S. Fish and Wildlife Service (USFWS). 2003. U.S. Fish and Wildlife Service 2003 Biological 

13 Opinion on the Operation of the Missouri River Main Stem Reservoir System, Operation and 

14 Maintenance of the Missouri River Bank Stabilization and Navigation Project, and Operation of 

15 the Kansas River Reservoir System. December 16, 2003. Available URL: 

16 http://www.nwd-mr.usace.army.mil/mmanual/FinalBO2003.pdf. (accessed June 17, 2009). 

17 U.S. Fish and Wildlife Service (USFWS). 2005. News Release October 6, 2005. “Service lists 

18 Salt Creek tiger beetle as endangered”. Available URL: 

19 http://www.fws.gov/mountain-prairie/PRESSREL/05-72.htm (accessed March 4, 2009). 

20 U.S. Fish and Wildlife Service (USFWS). 2007a. Species Profile, Pallid sturgeon, 

21 Scaphirhynchus albus. Available URL: http://www.fws.gov/moriver/PSPROFILE.htm. 

22 (accessed March 16, 2007). 

23 U.S. Fish and Wildlife Service (USFWS). 2007b. National Wetlands Inventory, Wetlands 

24 Mapper. Available URL: http://www.fws.gov/wetlands/data/index.html 

25 (accessed April 17, 2009). 

26 U.S. Fish and Wildlife Service (USFWS). 2008a. Endangered Species, Missouri, County 

27 Distribution of Federally-Listed, Threatened, Endangered, Proposed, and Candidate Species. 

28 USFWS, Columbia, Missouri. November 2008. Available URL: 

29 http://www.fws.gov/midwest/endangered/lists/missouri-cty.html (accessed April 17, 2009). 

30 U.S. Fish and Wildlife Service (USFWS). 2008b. North Dakota Field Office. Mountain-Prairie 

31 Region. Least Tern (Sterna antillarum). December 2008. Available URL: 

32 http://www.fws.gov/northdakotafieldoffice/endspecies/species/least_tern.htm 

33 (accessed February 26, 2009). 

34 U.S. Fish and Wildlife Service (USFWS). 2008c. Indiana Bat. Finding on Petition to Revise 

35 Critical Habitat. December 2008. Available URL: 

36 http://www.fws.gov/midwest/endangered/mammals/inba/inba_chpetfindg_qandas.html 

37 (accessed June 3, 2009). 

38 U.S. Fish and Wildlife Service (USFWS). 2009a. National Wetlands Inventory. Nemaha quad. 

39 Available URL: http://www.fws.gov/wetlands/data/ (accessed April 15, 2009). 

40 U.S. Fish and Wildlife Service (USFWS). 2009b. Endangered Species, Nebraska, Federally 

41 Listed and Proposed, Endangered, Threatened, Experimental, and Candidate Species - 

42 Nebraska Counties. Ecological Services, Nebraska Field Office. Available URL: 

43 http://www.fws.gov/mountain-prairie/endspp/countylists/nebraska.pdf 

44 (accessed April 17, 2009). 
Affected Environment 

Draft NUREG-1437, Supplement 41 2-86 February 2010 

1 U.S. Fish and Wildlife Service (USFWS). 2009c. Personal e-mail from Robert Harms, Fish and 

2 Wildlife Biologist, Grand Island Field Office, to R. Bulavinetz, Aquatic Ecologist, Division of 

3 License Renewal, Nuclear Regulatory Commission. Subject: Cooper Nuclear Plant. March 16, 

4 2009. ADAMS Accession No. ML092110590. 

5 U.S. Fish and Wildlife Service (USFWS). 2009d. National Wetlands Inventory. Nemaha quad. 

6 Available URL: http://www.fws.gov/wetlands/data/ (accessed April 15, 2009). 

7 U.S. Fish and Wildlife Service (USFWS). 2009e. Endangered Species,Nebraska, Federally 

8 Listed and Proposed, Endangered, Threatened, Experimental, and Candidate Species - 

9 Nebraska Counties. Ecological Services, Nebraska Field Office. Available URL: 

10 http://www.fws.gov/mountain-prairie/endspp/countylists/nebraska.pdf 

11 (accessed April 17, 2009). 

12 U.S. Fish and Wildlife Service (USFWS). 2009f. Personal e-mail from Robert Harms, Fish and 

13 Wildlife Biologist, Grand Island Field Office, to R. Bulavinetz, Aquatic Ecologist, Division of 

14 License Renewal, Nuclear Regulatory Commission. Subject: Cooper Nuclear Plant. March 16, 

15 2009. ADAMS Accession No. ML092110590. 

16 U.S. Fish and Wildlife Service (USFWS). 2009g. Whooping crane (Grus americana). Available 

17 URL: http://ecos.fws.gov/speciesProfile/SpeciesReport.do?spcode=B003 (accessed March 9, 

18 2009). 

19 U.S. Fish and Wildlife Service (USFWS). 2009h. Endangered Species Fact Sheet. Salt Creek 

20 tiger beetle. February 2009. Available URL: http://www.fws.gov/mountain21 prairie/species/invertebrates/saltcreektiger/ 

22 (accessed March 9, 2009). 

23 U.S. Fish and Wildlife Service (USFWS). 2009i. “Designation of Critical Habitat for the Salt 

24 Creek tiger beetle (Cicindela nevadica lincolniana).” Federal Register Vol. 72, No. 238, 

25 pp. 70715–70758. 

26 U.S. Fish and Wildlife Service (USFWS). 2009j. Black-footed ferret (Mustela nigripes). Available 

27 URL: http://ecos.fws.gov/speciesProfile/SpeciesReport.do?spcode=A004 (accessed March 9, 

28 2009). 

29 U.S. Fish and Wildlife Service (USFWS). 2009k. Rainwater Basin Wetland Management District. 

30 Available URL: http://www.fws.gov/Refuges/profiles/index.cfm?id=64530 (accessed April 29, 

31 2009). 

32 U.S. Fish and Wildlife Service (USFWS). 2009l. Letter from June M. DeWeese, Nebraska Field 

33 Supervisor, U.S. Fish and Wildlife Service, Grand Island, to Joe L. Citta, Jr., Corporate 

34 Environmental Manager, NPPD. Subject: Cooper Nuclear Station. June 8, 2009. ADAMS 

35 Accession No. ML091830055. 

36 U.S. Geological Survey (USGS). 1997. Ground Water Atlas of the United States, Kansas, 

37 Missouri, and Nebraska, HA 730-D. Available URL: http://capp.water.usgs.gov. 

38 U.S. Geological Survey (USGS). 2001. Ecoregions of Nebraska and Kansas (color poster with 

39 map, descriptive text, summary tables, and photographs). Available URL: 

40 http://www.epa.gov/wed/pages/ecoregions/ksne_eco.htm (accessed April 29, 2009). 

41 U.S. Geological Survey (USGS). 2006. Northern Prairie Wildlife Research Center. Native 

42 Grasslands of the North Dakota Grasslands. August 2006. Available URL: 

43 http://www.npwrc.usgs.gov/resource/plants/wildflwr/ (accessed May 6, 2009). 

44 U.S. Geological Survey (USGS). 2007. Sturgeon Research Update: Confirmed Pallid Sturgeon 

45 Spawning in the Missouri River in 2007. USGS Fact Sheet 2007–3053, July 2007. 
Affected Environment 

February 2010 2-87 Draft NUREG-1437, Supplement 41 

1 U.S. Geological Survey (USGS). 2008. Search USGS. September 2008. Available URL: 

2 http://search.usgs.gov/ (accessed March 9, 2009). 

3 U.S. Nuclear Regulatory Commission (NRC). 2003. Generic Environmental Impact Statement 

4 for License Renewal of Nuclear Plants Supplement 12 Regarding Fort Calhoun Station, Unit 1. 

5 NUREG-1437, Supplement 12. ADAMS Accession No. ML032230075. 

6 Utah State University (USU) 2006. Fact Sheet. Carex frankii Kunth. Available URL: 

7 http://utc.usu.edu/factsheets/CarexFSF/Carex_frankii.htm (accessed May 11, 2009). 

8 University of Texas (UT). 2009. Wildflower Center. Native Plant Database. February 2009. 

9 Available URL: http://www.wildflower.org/plants/result.php?id_plant=PAGL17. 

10 (accessed May 11, 2009). 

11 University of Wisconsin (UW). 2009. Robert W. Freckmann Herbarium. Available URL: 

12 http://wisplants.uwsp.edu/scripts/searchphotographer.asp?photographer=Robert%20R.%20Kow

13 al (accessed April 21, 2009). 

14 University of Wyoming. (UWYO) 2002. State Species Abstract. Wyoming Natural Diversity 

15 Database. Dalea enneandra. Nine-anther dalea. January 2002. Available URL: 

16 http://www.uwyo.edu/wynddsupport/docs/Reports/SpeciesAbstracts/Dalea_enneandra.pdf

17 (accessed May 6, 2009). 

18 Wildhaber, M.L., DeLonay, A.J., Papoulias, D.M., Galat, D.L., Jacobson, R.B., Simpkins, D.G., 

19 Braaten, P.J., Korschgen, C.E., and Mac, M.J. 2007. A conceptual life-history model for pallid 

20 and shovelnose sturgeon. U.S. Geological Survey Circular 1315. U.S. Geological Survey, 

21 Reston, Virginia. 18 pp. 

22 Wishart, David J., ed. 2004. Encyclopedia of the Great Plains. University of Nebraska Press 

February 2010 3-1 Draft NUREG-1437, Supplement 41 

1 3.0 ENVIRONMENTAL IMPACTS OF REFURBISHMENT 

2 Environmental issues associated with refurbishment activities are discussed in NUREG-1437, 

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

4 Volumes 1 and 2 (NRC 1996). The GEIS includes a determination of whether or not the analysis 

5 of the environmental issues can be applied to all plants and whether or not additional mitigation 

6 measures are warranted. Issues are then assigned a Category 1 or a Category 2 designation. 

7 As set forth in the GEIS, Category 1 issues are those that meet all of the following criteria: 

8 (1) The environmental impacts associated with the issue have been determined to apply to 

9 all plants, or for some issues, apply only to plants having a specific type of cooling 

10 system or other specified plant or site characteristics. 

11 (2) A single significance level (SMALL, MODERATE, or LARGE) has been assigned to the 

12 impacts (except for collective offsite radiological impacts from the fuel cycle and from 

13 high-level waste and spent fuel disposal). 

14 (3) Mitigation of adverse impacts associated with the issue has been considered in the 

15 analysis. It has been determined that additional plant-specific mitigation measures are 

16 likely not to be sufficiently beneficial to warrant implementation. 

17 For issues that meet the three Category 1 criteria, no additional plant-specific analysis is 

18 required in this supplemental environmental impact statement (SEIS) unless new and significant 

19 information is identified. 

20 Category 2 issues are those that do not meet one or more of the criteria for Category 1, 

21 therefore, an additional plant-specific review of these issues is required. 

22 License renewal actions include refurbishment for the extended plant life. These actions may 

23 have an impact on the environment that requires evaluation, depending on the type of action 

24 and the plant-specific design. Environmental issues associated with refurbishment, which were 

25 determined to be Category 1 issues, are listed in Table 3-1. 

26 Environmental issues related to refurbishment considered in the GEIS that are inconclusive for 

27 all plants, or for specific classes of plants, are Category 2 issues. These are listed in Table 3-2. 

28 The potential environmental effects of refurbishment actions are identified, and the analysis will 

29 be summarized within this section, if such actions are planned. Nebraska Public Power District 

30 (NPPD) indicated that it has performed an evaluation of systems, structures, and components 

31 pursuant to Section 54.21 of Title 10 of the Code of Federal Regulations (10 CFR 54.21) to 

32 identify the need to undertake any major refurbishment activities that are necessary to support 

33 continued operation of CNS-1 during the requested 20-year period of extended operation. Items 

34 that are subject to aging and might require refurbishment to support continued operation during 

35 the renewal period are listed in Table B.2 of the GEIS. 
Environmental Impacts of Refurbishment 

Draft NUREG-1437, Supplement 41 3-2 February 2010 

1 Table 3-1. Category 1 Issues for Refurbishment Evaluation 

ISSUE—10 CFR Part 51, Subpart A, Appendix B, Table B-1 GEIS Sections 

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

Impacts of refurbishment on surface water quality 3.4.1 

Impacts of refurbishment on surface water use 3.4.1 

Aquatic Ecology (for all plants) 

Refurbishment 3.5 

Ground Water Use and Quality 

Impacts of refurbishment on ground water use and quality 3.4.2 

Land Use 

Onsite land use 3.2 

Human Health 

Radiation exposures to the public during refurbishment 3.8.1 

Occupational radiation exposures during refurbishment 3.8.2 

Socioeconomics 

Public services: public safety, social services, and tourism and recreation 3.7.4; 3.7.4.3; 

 3.7.4.4; 3.7.4.6 

Aesthetic impacts (refurbishment) 3.7.8 
Environmental Impacts of Refurbishment 

February 2010 3-3 Draft NUREG-1437, Supplement 41 

1 Table 3-2. Category 2 Issues for Refurbishment Evaluation 

ISSUE–10 CFR Part 51, Subpart 

A, Appendix B, 

Table B-1 

GEIS 

Sections 

10 CFR 51.53 

(c)(3)(ii) Subparagraph 

Terrestrial Resources 

Refurbishment impacts 3.6 E 

Threatened or Endangered Species (for all plants) 

Threatened or endangered species 3.9 E 

Air Quality 

Air quality during refurbishment 

(nonattainment and maintenance 

areas) 

3.3 F 

Socioeconomics 

Housing impacts 3.7.2 I 

Public services: public utilities 3.7.4.5 I 

Public services: education 

(refurbishment) 3.7.4.1 I 

Offsite land use (refurbishment) 3.7.5 I 

Public services, transportation 3.7.4.2 J 

Historic and archaeological 

resources 

3.7.7 K 

Environmental Justice 

Environmental justice2 Not addressed Not addressed 

2 The results of the evaluation of systems, structures, and components for CNS-1, as required by 

3 10 CFR 54.21, do not identify the need to undertake any major refurbishment or replacement 

4 actions associated with license renewal to support the continued operation of 

5 CNS-1 beyond the end of the existing operating license. 

 

2

 Guidance related to environmental justice was not in place at the time the U.S. Nuclear Regulatory Commission 

(NRC) prepared the GEIS and the associated revision to 10 CFR Part 51. If an applicant plans to undertake 

refurbishment activities for license renewal, the applicant’s environmental report (ER) and the NRC staff’s 

environmental impact statement must address environmental justice. 
Environmental Impacts of Refurbishment 

Draft NUREG-1437, Supplement 41 3-4 February 2010 

1 3.1 REFERENCES 

2 10 CFR Part 51. Code of Federal Regulations, Title 10, Energy, Part 51, “Environmental 

3 Protection Regulations for Domestic Licensing and Related Regulatory Functions.” 10 CFR 

4 Part 54. Code of Federal Regulations, Title 10, Energy, Part 54, “Requirements for Renewal of 

5 Operating Licenses for Nuclear Power Plants.” 

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

7 for License Renewal of Nuclear Plants. NUREG-1437, Volumes 1 and 2, Office of Nuclear 

8 Regulatory Research, Washington, D.C. ADAMS Accession Nos. ML040690705 and 

9 ML040690738 

10 U.S. Nuclear Regulatory Commission (NRC). 1999. Generic Environmental Impact Statement 

11 for License Renewal of Nuclear Plant. NUREG-1437, Volume 1, Addendum 1, Office of Nuclear 

12 Reactor Regulation, Washington, D.C.ADAMS Accession No. ML0400690720.
February 2010 4-1 Draft NUREG-1437, Supplement 41 

1 4.0 ENVIRONMENTAL IMPACTS OF OPERATION 

2 This chapter addresses potential environmental impacts related to the period of extended 

3 operation of Cooper Nuclear Station, Unit 1 (CNS-1). These impacts are grouped and presented 

4 according to resource. Generic issues (Category 1) rely on the analysis provided in NUREG–

5 1437, "Generic Environmental Impact Statement for License Renewal of Nuclear Plants" (May 

6 1996) (GEIS) prepared by the U.S. Nuclear Regulatory Commission (NRC,1996) and are 

7 discussed briefly. NRC staff analyzed site-specific issues (Category 2) for CNS-1 and assigned 

8 them a significance level of SMALL, MODERATE, LARGE or not applicable to CNS-1 because 

9 of site characteristics or plant features. Section 1.4 of this report explains the criteria for 

10 Category 1 and Category 2 issues and defines the impact designations of SMALL, MODERATE, 

11 and LARGE. 

12 4.1 LAND USE 

13 Section 2.2.1 of this report describes the land use around CNS-1. 

14 Table 4-1, “Land Use Issues” lists Category 1 issues (from 10 CFR Part 51, Subpart A, 

15 Appendix B, Table B–1), which are applicable to onsite land use and power line right-of-way 

16 impacts during the renewal term. As stated in the GEIS, the impacts associated with the 

17 Category 1 issues were determined to be SMALL, and plant-specific mitigation measures would 

18 not be sufficiently beneficial to be warranted. 

19 The NRC staff reviewed and evaluated the CNS-1 environmental report (ER), scoping 

20 comments, other available information, and visited the CNS-1 in search of new and significant 

21 information that would change the conclusions presented in the GEIS. No new and significant 

22 information was identified during this review and evaluation. The staff did not identify any 

23 Category 2 issues for land use. Therefore, it is expected that there would be no impacts related 

24 to the Category 1 issues during the renewal term beyond those discussed in the GEIS. 

25 Table 4-1. Land Use Issues 

Issues GEIS Section Category 

Onsite land use 4.5.3 1 

Power line right-of-way 4.5.3 1 

26 4.2 AIR QUALITY 

27 Section 2.2.2 of this report describes air quality in the vicinity of CNS-1. One Category 1 air 

28 quality issue is applicable to CNS-1: air quality effects of transmission lines. No Category 2 

29 issues have been identified for air quality. The NRC staff did not identify any new and significant 

30 information during the review of NPPD’s ER, the site audit, or during the scoping process. No 

31 major facility construction or refurbishments are planned to occur during the license renewal 

32 period. Therefore, there are no impacts related to this issue beyond those discussed in the 

33 GEIS. For these issues, the GEIS concluded that the impacts are designated as SMALL. 
Environmental Impacts of Operation 

Draft NUREG-1437, Supplement 41 4-2 February 2010 

1 4.3 GROUND WATER 

2 4.3.1 Generic Ground Water Issues 

3 Section 2.2.3 of this report discusses ground water use and quality at CNS-1.The staff did not 

4 identify any new and significant information in regard to Category 1 or generic ground water 

5 issues during the review of the NPPD’s ER, the site visit, or the scoping process. Therefore, no 

6 impacts are related to these issues beyond those discussed in the GEIS. For these issues, the 

7 NRC staff in the GEIS concludes that the impacts are SMALL and additional site-specific 

8 mitigation measures are not warranted. 

9 4.3.2 Ground Water Use Conflicts 

10 The Category 2 ground water issue applicable to CNS-1 is ground water use conflicts (potable 

11 and service water, plants using >100 gpm). CNS-1 has two potable water supply wells 

12 completed in the alluvial aquifer that have a current combined pumping capacity of 250 gallons 

13 per minute (gpm) Normal operations require only one well to be pumped at a time, supplying 

14 125 gallons per minute. The water is chlorinated, distributed onsite, and operated with 

15 preventive maintenance and cross connection or backflow prevention programs. The two 

16 drinking water wells are scheduled to be replaced with two similar new wells in the near future 

17 (NPPD, 2008). 

18 A third alluvial aquifer well at CNS-1 is used for fire protection training and has a capacity of 750 

19 gallons per minute. Two additional wells, River Wells A and B, are used to supply water for 

20 facility pump seals. These wells each have a capacity of 150 gallons per minute (NPPD, 2008). 

21 As part of a hydrogeologic investigation for the study of radioisotopes in ground water and water 

22 use in the area surrounding the station, NPPD searched the Nebraska Department of Natural 

23 Resources (NDNR) water well database for all wells in Nemaha County. Three irrigation wells, 

24 completed in the shallow unconsolidated aquifer, are located between 2 and 3 miles southwest 

25 of CNS-1. Four farm wells within 1 mile of the station, all only 15 feet deep, produce a limited 

26 amount of ground water. None of these wells are impacted by ground water pumping at CNS-1 

27 because the station wells are screened in an unconfined aquifer and have limited radii of 

28 influence. A search of wells by NPPD in Atchison County, Missouri, across the river from CNS29 1, identified no wells within 2 miles of the station. In addition, the Missouri River serves as a 

30 ground water recharge and discharge boundary. Therefore, the NRC staff concludes no effect of 

31 pumping the shallow aquifer at CNS-1 would likely be measurable on the Missouri side of the 

32 river. 

33 Because of the limited radius of influence of CNS-1 wells completed in the unconfined aquifer, 

34 no public ground water supplies are close enough to CNS-1 to be impacted by ground water 

35 use at the station. There are no well-head protection areas or EPA designated sole source 

36 aquifers in the vicinity of CNS-1 (CRA, 2007). Therefore, the impact of ground water use by 

37 CNS-1 is SMALL and no mitigation measures are warranted. 

38 4.4 SURFACE WATER 

39 4.4.1 Generic Surface Water Issues 

40 The following sections discuss the surface water quality issues applicable to CNS-1, which are 

41 listed in Table 4-2. The staff did not identify any Category 2 issues related to surface water 
Environmental Impacts of Operation 

February 2010 4-3 Draft NUREG-1437, Supplement 41 

1 issues in the GEIS. In addition, the staff did not identify any new and significant information with 

2 respect to the Category 1 issues below during the review of NPPD’s ER, the site audit, or the 

3 scoping process. Therefore, no impacts are related to these issues beyond those discussed in 

4 the GEIS. For these issues, the NRC staff in the GEIS concludes that the impacts are SMALL, 

5 and additional site-specific mitigation measures are not warranted. 

6 Table 4-2. Category 1 Surface Water Issues 

Issues GEIS Section Category 

Altered current patterns at intake and discharge structures 4.2.1.2.1 1 

Temperature effects on sediment transport capacity 4.2.1.2.3 1 

Scouring caused by discharged cooling water 4.2.1.2.3 1 

Discharge of chlorine or other biocides 4.2.1.2.4 1 

Discharge of sanitary wastes and minor chemical spills 4.2.1.2.4 1 

Discharge of other metals in wastewater 4.2.1.2.4 1 

Water use conflicts for plants with once-through cooling 

systems 4.2.1.3 1 

7 The following briefly describes the GEIS conclusions for these issues: 

8 Altered current patterns at intake and discharge structures. Altered current 

9 patterns have not been found to be a problem at operating nuclear power plants 

10 and are not expected to be a problem during the license renewal term. 

11 Temperature effects on sediment transport capacity. These effects have not 

12 been found to be a problem at operating nuclear power plants and are not 

13 expected to be a problem during the license renewal term. 

14 Scouring caused by discharged cooling water. Scouring has not been found to be 

15 a problem at most operating nuclear power plants and has caused only localized 

16 effects at a few plants. It is not expected to be a problem during the license 

17 renewal term. 

18 Discharge of chlorine or other biocides. The effects are not a concern among 

19 regulatory and resource agencies, and are not expected to be a problem during 

20 the license renewal term. 

21 Discharge of sanitary wastes and minor chemical spills. Effects are readily 

22 controlled through the National Pollutant Discharge Elimination System (NPDES) 

23 permit. Periodic modifications are granted, if needed, and are not expected to be 

24 a problem during the license renewal term. 

25 Discharge of other metals in wastewater. These discharges have not been found 

26 to be a problem at operating nuclear power plants and are permitted through the 

27 NPDES system. They are not expected to be a problem during the license 

28 renewal term. 

29 With respect to “water use conflicts for plants with once through cooling systems” the 

30 NRC staff notes that continuing operation of CNS-1 depends on the availability of water 

31 from the Missouri River. The volume of water available may be susceptible to droughts 

32 and to competing water uses within the basin. In cases of extreme drought, these 

33 facilities may be required to curtail operations if the volume of water available is not 

34 sufficient. As described in Section 2.0, the flow in the Missouri River is not expected to 
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Draft NUREG-1437, Supplement 41 4-4 February 2010 

1 decrease to the point cooling water restrictions would be imposed. This remains a 

2 Category 1 issue with SMALL impact. 

3 For all of these Category 1 issues in Table 4-2, the NRC staff has not identified any new and 

4 significant information during its review of the NPPD’s ER, the staff’s site visit, the scoping 

5 process, or the evaluation of other available information. Therefore, the NRC staff concludes 

6 that there were no other surface water issues. 

7 4.4.2 Water Use Conflicts 

8 There were no Category 2 surface water issues identified for the CNS-1 license renewal term. 

9 4.5 AQUATIC RESOURCES 

10 Section 2.1.6 of this report describes the CNS-1 cooling water system; Section 2.2.5 describes 

11 the aquatic resources. The Category 1 and Category 2 issues related to aquatic resources 

12 applicable to CNS-1 are discussed below and listed in Table 4-3. 

13 Table 4-3. Aquatic Resources Issues

Issues GEIS Sections Category 

For All Plants 

Accumulation of contaminants in sediments or biota 4.2.1.2.4 1 

Entrainment of phytoplankton and zooplankton 4.2.2.1.1 1 

Cold shock 4.2.2.1.5 1 

Thermal plume barrier to migrating fish 4.2.2.1.6 1 

Distribution of aquatic organisms 4.2.2.1.6 1 

Premature emergence of aquatic insects 4.2.2.1.7 1 

Gas supersaturation (gas bubble disease) 4.2.2.1.8 1 

Low dissolved oxygen in the discharge 4.2.2.1.9 1 

Losses from predation, parasitism, and disease among organisms 

exposed to sublethal stresses 

4.2.2.1.10 1 

Stimulation of nuisance organisms 4.2.2.1.11 1 

For Plants with Once-Through and Cooling Pond Heat Dissipation Systems 

Entrainment of fish and shellfish in early life stages 4.1.2 2 

Impingement of fish and shellfish 4.1.3 2 

Heat shock 4.1.4 2 

14 4.5.1 Generic Aquatic Ecology Issues 

15 The NRC staff did not identify any new and significant information related to the Category 1 

16 issues listed above during the review of the NPPD’s ER, the site audit, or the scoping process. 

17 Therefore, there are no impacts related to these issues beyond those discussed in the GEIS. 

18 For these issues, the GEIS concludes that the impacts are designated as SMALL, and 

19 additional site-specific mitigation measures are not likely to be sufficiently beneficial to be 

20 warranted. 
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February 2010 4-5 Draft NUREG-1437, Supplement 41 

1 4.5.2 Entrainment and Impingement 

2 4.5.2.1 Introduction 

3 Entrainment and impingement of aquatic organisms are site-specific (Category 2) issues for 

4 assessing impacts of license renewal at plants with once-through cooling systems. Entrainment 

5 is the taking in of organisms with the cooling water. The organisms involved are generally of 

6 small size, dependent on the screen mesh size, and include phyto- and zooplankton, fish eggs 

7 and larvae, shellfish larvae, and many other forms of aquatic life. Impingement is the 

8 entrapment of organisms against the cooling water intake screens. 

9 A particular life stage of a species can be subject to both entrainment and impingement if some 

10 individuals are impinged on screens while others pass through and are entrained (EPA, 1977). 

11 Section 316(b) of the Clean Water Act (33 United States Code (U.S.C.) §1326(b)) requires that: 

12 Any standard established pursuant to section 1311 of this title or section 1316 of 

13 this title and applicable to a point source shall require that the location, design, 

14 construction, and capacity of cooling water intake structures reflect the best 

15 technology available for minimizing adverse environmental impact available for 

16 minimizing adverse environmental impact. 

17 The adverse environmental impacts of cooling water intake occur through both 

18 impingement and entrainment. Exhaustion, starvation, asphyxiation, descaling, and 

19 physical stresses may kill or injure impinged organisms. Heat, physical stress, or 

20 chemicals used to clean the cooling system may kill or injure the entrained organisms. 

21 4.5.2.2 History of Cooper Nuclear Station’s 316(b) Compliance 

22 The ER section 4.2.5 provides the history of CNS-1’s compliance with the Section 316(a) and 

23 316(b) of the Clean Water Act (33 United States Code (U.S.C.) §1326(a) and1326(b)). NDEQ 

24 (1977) found, after reviewing CNS-1’s revised 316(b) documentation on the effects of the intake 

25 structure on fish populations, that the structure met the minimum requirements of Section 316(b) 

26 of the CWA. NDEQ (1977) also voiced concerns regarding the fate of fish entrapped in the 

27 forebay area, however, and noted that “should problems develop in this area in the future, more 

28 adequate fish protection devices may be warranted.” NPPD (2008, pages 4–25) discontinued 

29 entrapment monitoring at CNS-1 about a year later in January 1978. 

30 CNS-1 conducted impingement sampling from 1974 through 1978. NPPD (2008) lists the 

31 annual impingement rates from 1975, 1976, and 1977, respectively, as follows: 45,990 fish, 

32 63,245 fish, and 40,296 fish. NPPD (2008) does not present the annual impingement rate for 

33 1974, but gives the daytime and nighttime rates as 19.8 and 38.1 fish/hour. Assuming 12-hour 

34 day and night sampling periods (Hazleton, 1979) and extrapolating to 365 days per year, the 

35 NRC staff calculated a yearly rate of 253,600 fish impinged in 1978. NPPD (2008) also did not 

36 present the annual rate for 1978. The total impingement for 27 hours of sampling in 1978 was 

37 266 fish (Hazleton, 1979). Extrapolating to 365 days per year, the NRC staff calculated a yearly 

38 rate of about 86,300 fish impinged in 1978. These annual rates can only be rough estimates 

39 accompanied by a moderate degree of uncertainty, but they are useful for understanding the 

40 order of magnitude of impingement. 

41 NPPD (2008) reports that gizzard shad, freshwater drum, and river carpsucker make up the 

42 majority of impinged fish in the 1974 through 1978 studies. Based on data from the ER (NPPD, 

43 2008, Table 1.3-1), the contribution of these three species to total impingement numbers ranged 
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Draft NUREG-1437, Supplement 41 4-6 February 2010 

1 from 73 to 91 percent for the period of 1974 through 1978. Hazleton (1979, Table 7.1) 

2 categorizes the occurrence of gizzard shad, freshwater drum, and river carpsucker in the area 

3 around the CNS-1 as “common” based on electroshocking and seining during the pre- and post4 operational period, 1970 through 1978. The age class of the majority of fish impinged each year 

5 was young of the year, and most impingement occurred at night (NPPD, 2008, page 4–24). 

6 According to NPPD’s (NPPD, 2008d) 316(b) Compliance Strategy Report for 2007, “to help 

7 address the 316(b) requirements, NPPD installed Brackett-Green dual flow screens with 

8 modified Ristroph fish buckets in 2005 and 2006.” CNS-1 has not completed the fish protection 

9 system and plans to install, during a 2011 refueling outage, a fish handling system consisting of 

10 inside and outside sprays to wash fish from the screens and a separate fish return trough 

11 (NPPD, 2008, pgs 4–11). The plant’s service water system would supply water for the spray 

12 wash. The new screens, fish handling system, and fish return trough primarily affect 

13 impingement but not entrainment. 

14 CNS-1’s original 316(a) and 316(b) demonstration (Nalco, 1975, Tables 4.4-48 through 4.4-50) 

15 reported entrainment mortality (intake vs. discharge and after an unspecified holding period) but 

16 not the number of fish entrained, both of which are necessary for a full assessment of the 

17 effects of entrainment. Nalco (1975, Tables 4.4-50 and 4.451) also reported mortality of fish 

18 larvae after an unspecified holding period, after passage through the thermal plume. Following 

19 NDEQ’s (1977) review of CNS-1’s revised 316(b) documentation, NPDES permits have not 

20 required subsequent entrainment monitoring and assessment (NPPD, 2008, page 4–11). U.S. 

21 Atomic Energy Commission (AEC) (1973, page V–15) found that it could describe the potential 

22 loss of fish eggs and larvae only in terms of the fraction of river flow taken by the plant, which in 

23 spring and early summer when many of the fish species spawned, was about 4 percent. During 

24 unusually low summer flows, this fraction would be greater and the fraction of river flow taken by 

25 the plant should be no more than 20 percent (NPPD, 2008). AEC (1973) found that the 

26 percentage loss of fish eggs and larvae originating upstream of the plant was probably much 

27 less than the fractional flow because the sampled fish species were spawning in protected 

28 areas. 

29 In its guidelines for ecological risk assessment, the EPA (1998) recommends use of multiple 

30 lines of evidence for characterizing and describing risk. The use of lines of evidence can be 

31 quantitative or qualitative. The NRC staff adopted a qualitative approach for the impact analysis 

32 here. One line of evidence is the regulatory history itself. Although any final determinations 

33 regarding CNS-1’s 316(b) demonstration await the EPA’s publication of new Phase II rules. 

34 Phase II rules were published in 2004, suspended in 2007, and are awaiting new Phase II rules 

35 at the time this SEIS was developed. 

36 The NRC staff find that the history of regulation reviewed above does not show regulatory 

37 concern that the potential effects of impingement and entrainment constitute adverse impacts. 

38 4.5.2.3 Analysis 

39 At NRC’s environmental audit at CNS-1 in 2009 and in scoping comments (EPA, 2009), the 

40 EPA voiced concern regarding the age of the data (over three and a half decades) used in the 

41 ER to support NPPD’s assertion in their ER that CNS-1’s impingement and entrainment 

42 produced a SMALL impact level on aquatic populations. To assess whether the Missouri River 

43 aquatic resources near CNS-1 are stable (as described in Section 2.2.5 of this SEIS), the NRC 

44 staff performed the following analysis. 
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February 2010 4-7 Draft NUREG-1437, Supplement 41 

1 The NRC staff examined the question of how the age of the data might affect the conclusions 

2 regarding entrainment and impingement at CNS-1. The NRC staff found that the argument used 

3 in the NPPD’s ER is inconsistent because it assumed at different points that the aquatic 

4 resources are both stable and unstable, although in fact they cannot be both. In describing the 

5 aquatic resources, the ER stated that fish communities have long been responding to changes 

6 in the river brought on by man’s activities. 

7 The NRC staff reached the conclusion of resource instability from a review of literature 

8 (presented in Chapter 2) on the natural and human history of the watershed. The changes are 

9 well documented: The present Missouri River is relatively new in geological terms and was 

10 partly formed by the last glaciation. As a result, most species in the region have not evolved in 

11 place but have colonized from surrounding environments that may have had somewhat different 

12 ecologies. Man has changed the river almost constantly, particularly since European settlement. 

13 Particularly influential were the early impoundments and withdrawals for irrigation and later 

14 dams built for various purposes (e.g., flood control, hydroelectric power, transportation, 

15 irrigation). Numerous diversions now withdraw river water for both consumptive and non16 consumptive uses. Dredging, bank stabilization, construction of levies, dikes, revetments, and 

17 other structures have changed the course of the river, its hydrological cycles, water current 

18 velocity, water levels, patterns of sediment suspension and deposition, suspended sediment 

19 levels, substrate types, and other aspects of fish habitat. Agriculture, industrialization, the CWA, 

20 and other regulations and associated activities have affected levels of contaminants in water 

21 and sediments, dissolved oxygen levels, and other water quality parameters that affect aquatic 

22 populations. Future changes to the Missouri River, for example, those flowing from the Missouri 

23 River Ecosystem Restoration Plan, can be foreseen. Aquatic populations respond to these 

24 habitat changes. 

25 The effects of impingement and entrainment on fish populations depend in part on the identity, 

26 numbers, and population structure of the affected populations. But the reviews of aquatic 

27 resources in the NPPD’s ER and Section 2.2.5 in this supplemental environmental impact 

28 statement (SEIS) show that the aquatic populations are not static or stable. 

29 The observation that the aquatic resources of the Missouri River are not static or stable affects 

30 NRC’s assignment of its level of impact in two ways. First is the concern voiced by the EPA 

31 (2009): the age of the impingement and entrainment data brings into question “whether these 

32 data are representative of current river condition and ecological impact.” Second, NRC partially 

33 defines its levels of impact in terms of stability: for example, NRC’s definition of a small impact 

34 level is that “environmental effects are not detectable or are so minor that they will neither 

35 destabilize nor noticeably alter any important attribute of the resource” and the definition of large 

36 impact is that “environmental effects are clearly noticeable and are sufficient to destabilize 

37 important attributes of the resource.” In applying its definitions of impact levels to effects of 

38 CNS-1 on Missouri River aquatic resources, NRC chose an approach that can accommodate 

39 the observations that the aquatic resources are changing constantly in response to many 

40 environmental variables and are not stable in the sense of unchanging or static. 

41 Another line of evidence is the ecology of adult and juvenile fish living in the Missouri River. The 

42 ER reports that water velocity at CNS-1’s intake screens is about 2 feet per second, whereas 

43 “historical river velocities were usually 0.98–2.62 feet per second, but downstream from Gavins 

44 Point Dam velocities between 2.62 feet per second and 4.27 feet per second occur more 

45 frequently than they did historically (Berry et al. p. 6).” These observations suggest that fish in 

46 the Missouri River should be adapted to living in water with velocities well in excess of the 

47 current that occurs at the intake screens. So while the identity, numbers, and population 
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Draft NUREG-1437, Supplement 41 4-8 February 2010 

1 structure of the potentially affected fish populations may have changed over the last decades, 

2 present fish populations are most likely no less able to escape or avoid adverse impact than 

3 those present when the impingement and entrainment studies were performed. 

4 A third line of evidence lies in the general ecology of fish eggs and larvae subject to 

5 entrainment. The generalities about the pattern of fish eggs and larvae in the Missouri River drift 

6 vulnerable to entrainment at CNS-1 are probably similar to those reported by Hergenrader et al. 

7 (1982) in the vicinity of CNS-1 in 1974 through 1976, although the relative and absolute 

8 abundances, and perhaps some species, may have changed. Fish eggs and juveniles are 

9 probably still a small part of all ichthyoplankton and most common from May through July. The 

10 numerically dominant fish larvae are probably still those of pelagic spawners such as freshwater 

11 drum, catastomids (e.g., suckers), cyprinids (e.g., minnows), common carp (Cyprinus carpio), 

12 gizzard shad (Dorosoma cepedianum), and goldeneye (Hiodon alosoides). The larvae of fish 

13 that build nests or spawn randomly, have adhesive and demersal (sinking) eggs, or provide 

14 parental care of the eggs and larvae, such as centrarchids (e.g., white bass (Morone chrysops), 

15 sunfish (Lepomis spp.), and crappie (Pomoxis spp.)), percids (e.g., sauger (Stizostedion 

16 canadense) and walleye (Sander vitreus)), and channel catfish (Ictalurus punctatus) are 

17 probably still relatively under-represented. 

18 Another line of evidence is the fraction of Missouri River flow withdrawn by CNS-1. AEC (1973, 

19 page V–15) found that it could describe the potential loss of fish eggs and larvae only in terms 

20 of the fraction of river flow taken by the plant, which in spring and early summer when many of 

21 the fish species spawned was estimated at 4 percent. During unusually low summer flows, the 

22 fraction of river flow taken by the plant should be no more than 20 percent (NPPD, 2008). AEC 

23 (1973) also found that the percentage loss of fish eggs and larvae originating upstream of the 

24 plant was probably much less than this because of the protected areas that these species used 

25 for spawning. These are very general ways of analyzing impact, and, within their limitations, 

26 these generalities are probably still true today, although once again, the identity of the species 

27 affected may have changed over time. 

28 The available lines of evidence for assessing impact level for aquatic resources subject to 

29 impingement and entrainment at CNS-1 are as follows: (1) the lack of a history of regulatory 

30 action indicates no appreciable adverse impact; (2) while fish populations may have changed 

31 over the decades, present fish populations are most likely no less able to escape or avoid 

32 adverse impact than those present when the impingement and entrainment studies were 

33 performed; (3) the generalities about the pattern of fish eggs and larvae in the Missouri River 

34 drift vulnerable to entrainment at CNS-1 are probably similar to those reported in past studies 

35 that found little or no adverse effects of plant operation; (4) the relative fraction of river flow 

36 withdrawn by the plant remains small, and most fish species still have refugia that protect the 

37 populations from adverse effects of impingement and entrainment; (5) CNS-1 now has dual flow 

38 screens with modified Ristroph fish buckets and NPPD plans to install a fish handling system 

39 consisting of inside and outside sprays to wash fish from the screens and a separate fish return 

40 trough to mitigate adverse effects of impingement, and (6) the NDEC conclusion based on 

41 monitoring and studies conducted by the Omaha Public Power District near both Fort Calhoun 

42 Station and CNS-1that losses due to entrainment were within the acceptable range. 

43 Although the NRC staff reached the conclusion that aquatic resources are not stable, the NRC 

44 staff finds that, although these changes may have occurred, the impact on aquatic resources 

45 due to impingement and entrainment at CNS-1 is SMALL. The NRC staff has reviewed the 

46 available information, including that provided by the applicant, the staff’s site visit, the State of 

47 Missouri, the 316(b) demonstration, and other public sources. Although no recent impact studies 
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February 2010 4-9 Draft NUREG-1437, Supplement 41 

1 have been performed, the NRC staff concludes that the weight of evidence from past studies, 

2 biological inference, and regulatory history indicates a SMALL level of impact on aquatic 

3 resources due to impingement and entrainment at CNS-1. NPPD has implemented some 

4 impingement mitigation measures and plans to implement others. 

5 4.5.3 Thermal Effects 

6 For plants with once-through cooling systems and cooling pond heat dissipation systems, 

7 NRC’s GEIS (1996) lists the effects of heat shock as an issue requiring plant-specific evaluation 

8 before license renewal (Category 2). NRC (1996) made impacts on fish and shellfish resources 

9 resulting from heat shock a site-specific issue because of continuing concerns about thermal 

10 discharge effects and the possible need to modify thermal discharges in the future in response 

11 to changing environmental conditions. 

12 Information considered includes the type of cooling system (once-through in this case), 

13 evidence of a CWA Section 316(a) variance or equivalent State documentation, and other 

14 information. To perform this evaluation, the staff reviewed the CNS-1’s ER to NRC (NPPD, 

15 2008); visited the CNS-1 site; reviewed the facility’s 316(a) demonstration (Nalco, 1975) dated 

16 October 23, 1975 and submitted to the NDEQ; and reviewed the applicant’s State of Nebraska 

17 NPDES Permit No. NE0001244 issued on July 1, 2007 and in force until July 30, 2012 (found in 

18 Attachment C of NPPD, 2008). 

19 The latest fact sheet for the NPDES permit summarizes the thermal limits for the effluent and 

20 the bases of the limits. The EPA assisted NDEQ in conducting the assessment of mixing cooling 

21 water from CNS-1 with ambient Missouri River water for the permit. The permit limits are based 

22 on a modeled limit of a 90 °F “heat cap” or maximum at the end of the 5,000-foot mixing zone. 

23 According to the fact sheet: “Based on a ∆T of 23.9°F, the permit limit for the Cooper Nuclear 

24 power plant is 109.4 °F. The maximum instream river temperature where the heat cap is met is 

25 85.54 °F (29.7 °C)” (NDEQ, 2007). 

26 The NPDES permit limits are set for the protection of aquatic life (NDEQ, 2007). In addition to 

27 upper thermal limits, shutdown of the plant in winter could cause sudden decreases of 

28 temperature that could cause thermal shock and mortality in fish attracted to or living in the 

29 thermal discharge and discharge canal (NPPD, 2008), although these events would probably be 

30 rare. 

31 After reviewing the available information, NRC concludes that the level of thermal impacts to the 

32 aquatic community due to renewing CNS-1’s operating license is designated as SMALL. 

33 4.5.4 Total Impacts on Aquatic Resources 

34 In addition to the information presented for impingement, entrainment, and thermal effects 

35 individually, the results of some field studies performed in the past and summarized in section 

36 2.2.5 provide information on the total impacts of CNS-1’s cooling water system operation on 

37 aquatic resources. Field studies comparing aquatic communities at locations upstream and 

38 downstream from CNS-1 reflect the total impact of entrainment, impingement, and thermal 

39 effects. 

40 Reetz (1982) reported that initial (7-hour) differences in carbon fixation rates of phytoplankton at 

41 CNS-1 between intake and discharge sampling locations ranged from an average of about 17 

42 percent inhibition during summer to no change during winter. The inhibition in the summer 
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Draft NUREG-1437, Supplement 41 4-10 February 2010 

1 months appeared to depend on absolute discharge temperature: the highest inhibition rates 

2 (above 26 percent) occurred when absolute discharge temperatures exceeded 38.5 °C (101 °F). 

3 Recovery from initial inhibition at CNS-1 occurred within 48 hours. While the river would carry 

4 phytoplankton far downstream in 48 hours so that a substantial part of the river would be 

5 affected, Reetz (1982) concluded that the low rate of water use by CNS-1 compared to river 

6 flow combined with the rapid mixing of the thermal plume would make the effects relatively 

7 unnoticeable. 

8 Periphytic algae are those algae that are attached to solid surfaces under water such as rocks, 

9 logs, pilings, and other structures. Farrall and Tesar (1982) reported results of periphytic algae 

10 studies conducted in the Missouri River in the vicinity of CNS-1 from 1972 through 1977. 

11 Because they remain in one place, periphytic algae colonizing natural and artificial substrata are 

12 used as indicators of environmental effects. Farrell and Tesar (1982) did not detect changes in 

13 the diversity, density, and biovolume of periphytic algae related to water temperature in the 

14 vicinity of CNS-1, although species composition did reflect water temperature. Although these 

15 results may generally be indicative of periphyton responses and processes at CNS-1 today, 

16 species composition and magnitude of response, which depends on the species involved, may 

17 have changed over the decades since Ferral and Tesar’s (1982) studies. 

18 Repsys and Rogers (1982) investigated the effects of CNS-1 on zooplankton populations in 

19 1974 through 1978. High absolute discharge temperatures (≥ 35 °C or 95 °F) critically affected 

20 zooplankton survival, as did duration of exposure. Repsys and Rogers (1982) concluded that 

21 entrainment losses were small when compared to the large downstream decreases in 

22 zooplankton. Without further studies, NRC concludes that these general patterns and processes 

23 most likely still occur, although species composition and magnitude of response, which depends 

24 on the species involved, may have changed over the decades since Repsys and Rogers’ (1982) 

25 studies. 

26 Carter et al. (1982) reported results of benthic infaunal and epifaunal invertebrate studies 

27 conducted in the Missouri River in the vicinity of CNS-1 and Fort Calhoun Station (FCS) from 

28 1973 through 1977. Benthic infauna refers to the organisms that live in underwater sediments, 

29 and benthic epifauna refers to organisms that live on underwater surfaces. Like periphyton, 

30 benthic invertebrates are often used as indicators of impacts because they are relatively 

31 immobile and sensitive to local environmental conditions. Carter et al. (1982) were not able to 

32 detect consistent changes in the epifaunal invertebrate community due to operation of CNS-1. 

33 Hergenrader et al. (1982) reported the results of both field and entrainment studies on larval fish 

34 in the vicinity of CNS-1 in 1974 through 1976. In order to determine if entrainment (and 

35 impingement) were having an effect on the fish populations in the area, Hergenrader et al. 

36 (1982) looked for changes in adult fish populations resulting from impacts to larval fish, but 

37 detected none. They concluded that either no significant changes occurred or “Too few 

38 resources (financial, technical, equipment, labor) were applied over too small a time frame in too 

39 restricted an area to detect the changes which had occurred.” 

40 The aquatic community, particularly the fish community, may not be stable and may still be 

41 changing in response to historical changes in land use, river regulation, and other human 

42 activities. For example, the U.S. Army Corps of Engineers (USACE) (2004) reports that the 

43 benthic fish community appears to be changing based on 1996 and 1997 studies. Whatever the 

44 total effects of CNS-1 on the fish community were in the past, the installation of the modified 

45 dual-flow traveling screens in 2006 and future installation of a low-pressure screen wash and 

46 fish return trough would mitigate those impacts. 
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February 2010 4-11 Draft NUREG-1437, Supplement 41 

1 While the species and their numbers would have changed over the last decades, the results 

2 summarized above reflect general ecological responses. 

3 The NRC staff concludes level of impact on aquatic resources due to all aspects of CNS-1’s 

4 cooling system operation is SMALL. 

5 4.6 TERRESTRIAL RESOURCES 

6 Section 2.2.6 of this document provides a description of the terrestrial resources at CNS-1 and 

7 in the surrounding area. The issues related to terrestrial resources applicable to CNS-1 are 

8 discussed below and listed in Table 4-4. No Category 2 issues are related to terrestrial 

9 resources for license renewal. The NRC staff did not identify any additional new and significant 

10 information during review of the NPPD ER, the site audit, the scoping process, or the evaluation 

11 of other available information. Therefore, the NRC staff concludes that there would be no 

12 impacts related to these issues beyond those discussed in the GEIS (NRC, 1996). The GEIS 

13 concludes that the impacts are SMALL and additional site-specific mitigation measures are not 

14 likely to be sufficiently beneficial to implement. 

15 Table 4-4. Terrestrial Resources Issues

Issues GEIS Section Category 

Power line right-of-way management (cutting herbicide application) 4.5.6.1 1 

Bird collisions with power lines 4.5.6.1 1 

Impacts of electromagnetic fields on flora and fauna (plants, 

agricultural crops, honeybees, wildlife, livestock) 4.5.6.3 1 

Floodplains and wetlands on power line right-of-way 4.5.7 1 

16 4.7 PROTECTED SPECIES 

17 4.7.1 Aquatic Species 

18 Section 2.2.7 of this document describes the threatened or endangered species on or near 

19 CNS-1.The impact to threatened and endangered species is a Category 2 issue and is 

20 discussed below. 

21 One Federally-listed aquatic species may occur in the Missouri River near CNS-1: pallid 

22 sturgeon. NPPD (2008) summarizes interactions between NPPD and both State and Federal 

23 agencies regarding conservation of pallid sturgeon. 

24 In March 2006, before filing a license renewal application with NRC, NPPD voluntarily 

25 participated in meetings with the U.S. Fish and Wildlife Service (USFWS), the Nebraska Game 

26 and Parks Commission (NGPC), the NDEQ, the NDNR, the EPA, and the USACE regarding 

27 conservation actions to improve the habitat of pallid sturgeon. NPPD (2008) summarizes those 

28 meetings. Early in the discussions, the USFWS and NGPC showed interest in developing 

29 existing habitat on a parcel of property south of CNS-1 at Langdon Bend and later also on CNS30 1 property on the Nebraska side of the Missouri River adjacent to Langdon Bend. They hoped to 

31 enhance pallid sturgeon habitat by building a chute to connect the active river channel with the 

32 old river area. 
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Draft NUREG-1437, Supplement 41 4-12 February 2010 

1 NPPD had problems with this proposal. Implementing the proposal would reduce CNS-1’s 

2 mixing zone, which now extends 5,000 feet south of CNS-1 along the Nebraska side of the 

3 Missouri River, to less than 2,500 feet. Reducing the mixing zone would reduce CNS-1’s 

4 capacity to generate electricity, particularly during summer. The proposal also posed other 

5 negative safety and environmental concerns for CNS-1. As an alternative, NPPD then offered to 

6 contribute funds toward other new or existing projects on the Missouri River. The USFWS 

7 rejected this funding alternative in favor of increasing the amount of land for habitat 

8 development. 

9 To meet the goal of improving habitat for pallid sturgeon, NPPD offered a conservation 

10 easement of about 230 acres of land that it owns on the Missouri side of the Missouri River, 

11 opposite CNS-1, for the purposes of habitat development. USFWS indicated interest in the 

12 proposal, and asked NPPD to also acquire an adjacent property of about 150 acres so that the 

13 entire bend in the river could be developed into better habitat. When the property owner refused 

14 to sell the land, NPPD offered a revised, final proposal to participate in and promote habitat 

15 development along the Missouri River. It proposed to revisit the USFWS’s and NGPC’s interest 

16 in a suitable conservation easement and Memorandum of Understanding to enable habitat 

17 development on NPPD’s approximately 230 acre parcel on the Missouri side of the river. 

18 Further, because NPPD recognized that this parcel alone would not meet USFWS’s and 

19 NGPC’s conservation habitat development goals, NPPD indicated its willingness to make an 

20 additional payment of $250,000 to be applied toward another conservation habitat development 

21 project on the Missouri River at the direction of USFWS and NGPC. At the time of writing this 

22 SEIS, the involved parties are discussing details of the conservation agreement. 

23 Plans for and construction of a chute on the parcel may also involve the owners of the 

24 transmission lines and supports that cross the property. 

25 NPPD does not own these lines, although CNS-1 provides power to them. 

26 The probability that CNS-1 will entrain, impinge, or otherwise affect pallid sturgeon eggs or 

27 larvae is low. Hazleton (1979) collected adult and juvenile fish from seven locations in the 

28 vicinity of CNS-1 from 1970 through 1978 and reported no pallid sturgeon captured. They also 

29 conducted impingement sampling from 1974 through 1978 and reported no pallid sturgeon 

30 impinged. Based on 374 trawl hauls that captured over 21,735 fish in a 1998 through 2000 

31 survey, Hrabik et al. (2007) concluded pallid sturgeon may reproduce in the lower Missouri 

32 River and the upper and lower Mississippi River, although no fish may survive to recruitment. 

33 NPPD’s involvement in the conservation agreement for pallid sturgeon; however, could have a 

34 positive impact on the population. 

35 The information available indicates that NRC level of impact associated with license renewal is 

36 SMALL. Although NRC also concludes that the continued operation of CNS-1 for an additional 

37 20 years may affect, but is not likely to adversely affect, the pallid sturgeon, the NRC staff 

38 prepared a biological assessment, which appears in Appendix D. 

39 4.7.2 Terrestrial Species 

40 An evaluation of impacts to threatened and endangered terrestrial species requires consultation 

41 with appropriate agencies to determine whether or not such species are present and whether or 

42 not these species would be adversely affected by continued operation of the CNS-1 site during 

43 the license renewal term. 
Environmental Impacts of Operation 

February 2010 4-13 Draft NUREG-1437, Supplement 41 

1 NPPD has coordinated efforts with the USFWS to address the potential risk of 

2 Federally-listed migratory birds colliding with transmission line NPPD TL3502, as discussed in 

3 section 2.2.7. 

4 Four Federally-listed endangered and threatened species, the Indiana bat (Myotis sodalis), the 

5 western prairie fringed orchid (Platanthera praeclara), the piping plover, and the interior least 

6 tern are potentially found in the vicinity of the CNS-1 site (NPPD, 2008). Seven Federally-listed 

7 species are also found or potentially found within the counties spanning the transmission line 

8 corridor, including the western prairie fringed orchid, the Salt Creek tiger beetle (Cincindela 

9 nevadica lincolniana), the black-footed ferret (Mustela nigripes), the interior least tern, the piping 

10 plover, the Eskimo curlew (Numenius borealis), and the only known wild population of whooping 

11 cranes (USFWS 2007; USFWS 2008; USFWS 2009). The Eskimo curlew is listed as extirpated 

12 from Nebraska, and is globally extinct or near-extinct (NatureServe, 2009). 

13 There are 115 State-listed threatened or endangered species that occur or have the potential to 

14 occur in the vicinity of CNS-1 in Nemaha County, within the counties spanning the transmission 

15 line corridor in Nebraska, and in Atchison County, Missouri (NGPC, 2008; MDC, 2009b). These 

16 115 species are listed in Table 2.2.7-1 along with information on their habitat requirements. No 

17 longer included in this list is the American bald eagle (Halieatus leucocephalus), which was 

18 formerly a Federally-listed bird. There is an active bald eagle’s nest on the Missouri side of the 

19 CNS-1 property with a breeding pair of eagles that have produced a number of chicks over the 

20 past several years (NPPD, 2008). Although no longer protected under the Endangered Species 

21 Act (ESA), the bald eagle is still protected under the Migratory Bird Treaty Act, and is also 

22 protected under the Bald and Golden Eagle Protection Act from any take of a bald eagle without 

23 a permit. According to the ER, NPPD attempts to minimize disturbance to the eagles during the 

24 infrequent site activities performed on the Missouri side of the CNS-1 site (NPPD, 2008). 

25 The staff requests that NPPD report the existence of any Federally-listed or State-listed 

26 endangered or threatened species within the CNS-1 site or near the transmission line corridor to 

27 NGPC, MDC, and the USFWS, if any such species are identified during the license renewal 

28 term. In addition, the NPPD is required to promptly report to the appropriate wildlife 

29 management agencies and to NRC, any evidence of injury to, or mortality of, migratory birds or 

30 threatened or endangered species observed within the transmission line corridor, especially 

31 injury to, or mortality of, Federally-listed whooping cranes, interior least terns, and piping plovers 

32 along the Platte River near the western limit of CNS-1 transmission line NPPD TL3502, near 

33 Grand Island, NE. 

34 From the review of the available information, NRC staff finds that operation of the CNS-1 site 

35 and its associated transmission lines has not been known to, nor is it expected to, adversely 

36 affect any threatened or endangered species during the license renewal term. Mitigation 

37 measures currently in place at the CNS-1 site include bird flight diverters on the transmission 

38 lines within the CNS-1 facility, minimization of activity near the eagle’s nest on the Missouri side 

39 of the CNS-1 site, a right-of-way (ROW) vegetation management program, and best 

40 management practices. The NPPD is also coordinating with USFWS staff to install bird diverters 

41 on transmission line NPPD TL3502 where it traverses the Platte River. These bird flight 

42 diverters will minimize potential impacts to whooping cranes, interior least terns, piping plovers, 

43 and other migratory birds. All of these current and proposed mitigation measures minimize the 

44 effects of plant operation on terrestrial species, and are found to be adequate. Therefore, the 

45 NRC staff concludes that adverse impacts to threatened or endangered species during the 

46 license renewal term would be SMALL. 
Environmental Impacts of Operation 

Draft NUREG-1437, Supplement 41 4-14 February 2010 

1 4.8 HUMAN HEALTH 

2 Table B-1 of Appendix B to Subpart A of 10 CFR Part 51 contains more information on these 

3 issues. The human health issues applicable to CNS-1 are discussed below and listed in Table 

4 4-5 for Category 1, Category 2, and uncategorized issues. 

5 Table 4-5. Human Health Issues

Issues GEIS Section Category 

Microbiological organisms (occupational health) 4.3.6 1 

Microbiological organisms (public health, for plants using small 

rivers) 4.3.6 2 

Noise 4.3.7 1 

Radiation exposures to public (license renewal term) 4.6.1, 4.6.2 1 

Occupation radiation exposures (license renewal term) 4.6.3 1 

Electromagnetic fields – acute effects (electric shock) 4.5.4.1 2 

Electromagnetic fields – chronic effects 4.5.4.2 Uncategorized 

6 4.8.1 Generic Human Health Issues 

7 The staff did not identify any new and significant information during its review of the NPPD’s ER, 

8 the site audit, or the scoping process. Therefore, there are no impacts related to these issues 

9 beyond those discussed in the GEIS. For these issues, the NRC staff in the GEIS concluded 

10 that the impacts are SMALL, and additional site-specific mitigation measures are not likely to be 

11 sufficiently beneficial to be warranted. 

12 CNS-1 conducts an annual radiological environmental monitoring program (REMP) in which 

13 radiological impacts to the employees, the public, and the environment in the environs around 

14 the CNS-1 site are documented. The report contains a discussion of the data relative to pre15 plant operation baseline data. The objectives of the REMP include the following: 

16 ● Measure and evaluate the levels of radiation and radioactive material in the 

17 environs around the CNS-1 site to assess the radiological impacts, if any, of 

18 plant operation on the environment. 

19 ● Supplement the results of the radiological effluent monitoring program by 

20 verifying that the measurable concentrations of radioactive material and 

21 levels of radiation are not higher than expected based on the measurement 

22 of radioactive effluents and modeling for the applicable exposure pathways. 

23 ● Demonstrate compliance with the requirements of applicable Federal 

24 regulatory agencies. 

25 Two reports summarize radiological information about the CNS-1 site; the annual radiological 

26 environmental operating report and the annual radioactive effluent release report. The media 

27 samples are intended to be representative of the radiation exposure pathways to the public from 

28 all plant radioactive effluents. The REMP measures the aquatic, terrestrial, and atmospheric 

29 environment, as well as the ambient gamma radiation, for radioactivity. Ambient gamma 
Environmental Impacts of Operation 

February 2010 4-15 Draft NUREG-1437, Supplement 41 

1 radiation pathways include radiation from buildings and plant structures and airborne material 

2 that may be released from the plant. In addition, the REMP also measures background radiation 

3 (i.e., cosmic sources, global fallout, and naturally occurring radioactive material, including 

4 radon). Thermoluminescent dosimeters (TLDs) are used to measure direct radiation. The 

5 atmospheric environmental monitoring consists of sampling the air for particulates and 

6 radioiodine. Terrestrial environmental monitoring consists of analyzing samples of milk and food 

7 products. The aquatic environmental monitoring consists of analyzing samples of surface water, 

8 drinking water, ground water, fish, and sediment from the Missouri River. There is also an onsite 

9 ground water protection program designed to monitor the onsite plant environment for 

10 indications of leaks from plant systems and pipes carrying radioactive liquid. 

11 The NRC staff reviewed the CNS-1 radioactive environmental operating reports for 2003 

12 through 2007 to look for any significant impacts to the environment or any unusual trends in the 

13 data (NPPD 2004, 2005, 2006, 2007, 2008e). The staff’s review of the REMP reports showed 

14 no unusual trends in the data and showed no measurable impact from the operations at CNS-1 

15 on the environment. 

16 Historical data on radioactive releases from CNS-1 and the resultant dose calculations 

17 demonstrate that the amount of radiation received to a hypothetical maximally exposed 

18 individual in the vicinity of CNS-1 is a small fraction of the dose limits specified in 10 CFR Part 

19 20, the as low as reasonably achievable (ALARA) dose design objectives in Appendix I to 10 

20 CFR Part 50, and the EPA’s radiation standards in 40 CFR Part 190, “Environmental Radiation 

21 Protection Standards for Nuclear Power Operations.” Dose estimates for members of the public 

22 are calculated based on liquid and gaseous effluent release data and atmospheric and aquatic 

23 transport models. The CNS-1 2007 annual radioactive effluent release report (NPPD, 2008f) 

24 contains a detailed presentation of the radioactive discharges and the resultant calculated 

25 doses. The following summarizes the calculated hypothetical maximum dose to an individual 

26 located at the CNS-1 site boundary from radioactive liquid and gaseous effluents released 

27 during 2007: 

28 ● The maximum whole-body dose to an offsite member of the general public 

29 from liquid effluents was 0 milliroentgen equivalent man (mrem) (0 mSv 

30 (milli-siervert)) because there were no radioactive liquid discharges during 

31 2007. In 2006, the maximum whole-body dose to an offsite member of the 

32 general public from liquid effluents was 0.1326 mrem (0.0031mSv), which is 

33 below the 3 mrem (0.03 mSv) dose criteria in Appendix I to 10 CFR Part 50. 

34 ● The maximum air dose at the site boundary from gamma radiation in 

35 gaseous effluents was 6.22 E-04 milliradiation absorbed dose (mrad) (6.22 

36 E-6 mGy), which is below the 10 mrad (0.05 mGy (milligray)) dose criteria 

37 in Appendix I to 10 CFR Part 50. 

38 ● The maximum air dose at the site boundary from beta radiation in gaseous 

39 effluents was 4.03 E-04 mrad (4.03 E-06 mGy), which is below the 20 mrad 

40 dose criteria in Appendix I to 10 CFR Part 50. 

41 ● The maximum whole-body dose to an offsite member of the general public 

42 from direct radiation shine was approximately 0.5 mrem (0.005 mSv). 

43 (NPPD; 2009a) 
Environmental Impacts of Operation 

Draft NUREG-1437, Supplement 41 4-16 February 2010 

1 The NRC staff’s reviewed and assessed the CNS-1 radioactive waste system performance in 

2 controlling radioactive effluents and the resultant doses to members of the public in 

3 conformance with the ALARA criteria. The NRC staff found that the 2007 radiological data for 

4 CNS-1 are consistent, with reasonable variation attributable to operating conditions and outages 

5 and with the 5-year historical radiological effluent releases and resultant doses (NPPD, 2004a, 

6 2005a, 2006a, 2007a, 2008f). These results demonstrate that CNS-1 is operating in compliance 

7 with Federal radiation protection standards contained in Appendix I to 10 CFR Part 50, 10 CFR 

8 Part 20, and 40 CFR Part 190. Continued compliance with regulatory requirements is expected 

9 during the license renewal term; therefore, the impacts from radioactive effluents are not 

10 expected to change during the license renewal term. 

11 The applicant has no plans to conduct refurbishment activities during the license renewal term. 

12 The applicant is expected to maintain radiological releases in accordance with its Offsite Dose 

13 Assessment Manual (ODAM) and regulatory requirements as it has in the past. Thus, their 

14 radiological effluent releases are not expected to be significantly different from the historical 

15 radiological effluent releases. The dose to a maximally exposed individual in the vicinity of CNS16 1 for the refurbishment period is expected to continue to be a small fraction of the limits and 

17 standards specified in 10 CFR Part 20, Appendix I to 10 CFR Part 50, and 40 CFR Part 190. 

18 4.8.2 Microbiological Organisms 

19 The effects of thermophilic microbiological organisms on human health, listed in Table B-1 of 

20 Appendix to Subpart A of 10 CFR Part 51, are categorized as a Category 2 issue and require 

21 plant-specific evaluation during license renewal process for the plants located on the small river, 

22 that use closed-cycle cooling. The average annual flow of the Missouri River at the nearest point 

to a CNS-1 measuring station is approximately 1.2x1012 ft3

/yr (3.4x1010 m3 23 /yr), which is less than 

24 3.15x1012 ft3/year (9x1010m3/year), the rate for which an assessment of the impact of the 

25 proposed action on public health from thermophilic organisms in the affected water is required 

26 by 10 CFR 51.53(c)(3)(ii)(G). Therefore, the effects on public health must be addressed. 

27 The Category 2 designation is based on the magnitude of the potential public health impacts 

28 associated with thermal enhancement of the enteric pathogens such as Salmonella spp. and 

29 Shigella spp., the Pseudomonas aeruginosa bacterium, the pathogenic strain of the free-living 

30 amoebae Naegleria spp., and Legionella spp. bacteria (NRC, 1996). Thermophilic 

31 microorganisms generally occur at temperatures of 77 °F to 176 °F (25 °C to 80 °C) with an 

32 optimal growth temperature range of 122 °F–150 °F (50 °C– 66 °C), minimum and maximum 

33 temperature tolerances of 68 °F (20 °C) and 158 °F (70 °C), respectively; however, thermal 

34 preferences and tolerances vary across bacterial groups. Pathogenic thermophilic 

35 microbiological organisms that are of concern during nuclear power reactor operation typically 

36 have optimal growing temperatures of approximately 99 °F (37 °C) (Joklik and Smith, 1972). 

37 Pseudomonas aeruginosa is an opportunistic pathogen that causes serious and sometimes fatal 

38 infections in immunocompromised individuals. The organism produces toxins harmful to 

39 humans and animals. It has an optimal growth temperature of 99 °F (37 °C) (Todar, 2007) 

40 Legionella spp. consists of at least 46 species and 70 serogroups. It is responsible for 

41 Legionnaires’ disease, with the onset of pneumonia in the first two weeks of exposure. Risk 

42 groups for Legionella spp. include elderly, cigarette smokers, persons with chronic lung or 

43 immunocompromising diseases, and persons receiving immunosuppressive drugs. 

44 The ambient temperatures of the Missouri River near CNS-1 vary from freezing (approximately 

45 32 °F (0 °C)) in the winter to 87 °F–89 °F (30.5 °C–31.6 °C) in the summer; therefore, ambient 
Environmental Impacts of Operation 

February 2010 4-17 Draft NUREG-1437, Supplement 41 

1 river conditions are not likely to support the proliferation of the pathogenic organisms of 

2 concern. According to the data submitted by NPPD to the NDEQ for the period January 2003 to 

3 September 2005, the mean monthly average temperature of the thermal discharge at outfall 001 

4 was 75.7 °F (24.3 °C). The reported maximum daily temperature, which occurs temporarily for 

5 the short time during periodic condenser backwash, was 109.2 °F (42.9 °C). The highest 

6 monthly average discharge temperature was 101.7 °F (38.7 °C) in August 2003 and 101.3 °F 

7 (38.5 °C) in July 2005, which is consistent with the historical data showing that monthly average 

8 discharge temperatures at or above 95 °F (35 °C) occur only during July and August. Ambient 

9 temperatures of the Missouri River stay below 77 °F (25 °C) from October to April; therefore, 

10 ambient river conditions are not likely to support the proliferation of pathogenic organisms of 

11 concern. 

12 NPPD consulted the Nebraska Department of Public Health and Human Services (DHHS) and 

13 the Missouri Department of Public Safety (DPS) to determine if there was any concern about the 

14 potential occurrence of thermophilic microbiological organisms in the Missouri River at the CNS15 1 location. Nebraska DHHS and Missouri DPS stated that no occurrences of infections caused 

16 by Naegleria fowleri from the Missouri River in the CNS-1 vicinity were documented (NPPD, 

17 2008). 

18 Available data assembled into biannual reports by the Center for Disease Control (CDC) for the 

19 years 1999 to 2006 (CDC 2000, 2002, 2004, 2006) indicate no occurrence of waterborne 

20 disease outbreaks in the State of Nebraska resulting from exposure to the thermophilic 

21 microbiological organisms Naegleria fowleri and Pseudomonas aeruginosa from the operation 

22 of CNS-1. 

23 The NRC staff reviewed all documents, applicable to this Category 2 issue, including NPPD’s 

24 ER, NPDES permit, and CDC reports. The NRC staff concludes that, thermophilic 

25 microbiological organisms are not likely to present a public health hazard as a result of CNS-1 

26 discharges to the Missouri River. 

27 The NRC staff concludes that impacts on public health from thermophilic microbiological 

28 organisms from continued operation of CNS-1 in the license renewal period would be SMALL. 

29 4.8.3 Electromagnetic Fields – Acute Shock 

30 Based on the GEIS, the Commission found that electric shock resulting from direct access to 

31 energized conductors or from induced charges in metallic structures has not been a problem at 

32 most operating plants and generally is not expected to be a problem during the period of 

33 extended operation; however, a site-specific review is required to determine the significance of 

34 the electric shock potential along the portions of the transmission lines within the scope of the 

35 SEIS. 

36 The GEIS states that it is not possible to determine the significance of the electric shock 

37 potential without a review of the conformance of each nuclear plant transmission line with 

38 National Electric Safety Code (NESC) (Institute of Electrical and Electronics Engineers (IEEE) 

39 2007) criteria. Evaluation of individual plant transmission lines is necessary because the issue 

40 of electric shock safety was not addressed in the licensing process for some plants. For other 

41 plants, land use in the vicinity of transmission lines may have changed, or power distribution 

42 companies may have chosen to upgrade line voltage. To comply with 10 CFR 51.53(c)(3)(ii)(H), 

43 the applicant must provide an assessment of the potential shock hazard if the transmission lines 

44 that were constructed for the specific purpose of connecting the plant to the transmission 
Environmental Impacts of Operation 

Draft NUREG-1437, Supplement 41 4-18 February 2010 

1 system do not meet the recommendations of the NESC for preventing electric shock from 

2 induced currents. 

3 All transmission lines associated with CNS-1 were constructed in accordance with NESC and 

4 industry guidance in effect at that time (1973). The transmission facilities are maintained to 

5 ensure continued compliance with current standards. The transmission line assessment 

6 program, implemented at CNS-1, ensures continued monitoring and documenting of current 

7 conditions of the transmissions lines, along with maintenance, and compliance with current 

8 standards. Bimonthly aerial patrols and additional special patrols after severe storms are 

9 performed in order to identify any ground clearance problems and the integrity of the 

10 transmission line structures. Ground inspections are conducted by transmission line technicians 

11 on an annual basis (NPPD, 2008). 

12 Since the lines were constructed, a new criterion has been added to the NESC for power lines 

13 with voltages exceeding 98 kV. NPPD has reviewed the transmission line clearances and 

14 configurations for compliance with this criterion (NPPD, 2008) and determined that all 

15 transmission lines within the scope of this review meet the NESC code. No induced shock 

16 hazard to the public should occur, since the lines are operating within original design 

17 specifications and meet current NESC clearance standards. 

18 The NRC staff has reviewed the available information, including the applicant’s evaluation and 

19 computational results. Based on this information, the NRC staff evaluated the potential impacts 

20 for electric shock resulting from the operation of CNS-1 and its associated transmission lines. 

21 NRC staff concludes that the potential impacts from electric shock during the renewal period 

22 would be SMALL. 

23 4.8.4 Electromagnetic Fields–Chronic Effects 

24 In the GEIS, the chronic effects of 60-Hz EMFs from power lines were not designated as 

25 Category 1 or 2, and will not be until a scientific consensus is reached on the health implications 

26 of these fields. The Commission rules do not require the license renewal application to include 

27 information on this issue. 

28 4.9 SOCIOECONOMICS 

29 Category 1 issues in 10 CFR Part 51, Subpart A, Appendix B, Table B-1, that are applicable to 

30 socioeconomic impacts during the renewal term are listed in Table 4-6. As stated in the GEIS, 

31 the impacts associated with these Category 1 issues were determined to be SMALL, and plant32 specific mitigation measures would not be sufficiently beneficial to be warranted. 

33 NRC staff reviewed and evaluated the CNS-1 ER, scoping comments, other available 

34 information, and visited CNS-1 in search of new and significant information that would change 

35 the conclusions presented in the GEIS. No new and significant information was identified during 

36 this review and evaluation. Therefore, it is expected that there would be no impacts related to 

37 these Category 1 issues during the renewal term beyond those discussed in the GEIS. 
Environmental Impacts of Operation 

February 2010 4-19 Draft NUREG-1437, Supplement 41 

1 Table 4-6. Category 1 Issues Applicable to Socioeconomics during the Renewal Term 

Issues GEIS Section Category 

Public Services: public safety, social services, and tourism and 

recreation 

4.7.3.3; 4.7.3.4; 

4.7.3.6 

1 

Public Services: education (license renewal) 4.7.3.1 1 

Aesthetic Impacts (license renewal term) 4.7.6 1 

Aesthetic impacts of transmission lines (license renewal term) 4.5.8 1 

2 4.9.1 Generic Socioeconomic Issues 

3 The following briefly describes the GEIS conclusions, as stated in Table B-1 of 10 CFR Part 51, 

4 Subpart A, Appendix B, for each of the socioeconomic Category 1 issues: 

5 Public services: public safety, social services, and tourism and recreation. Impacts to 

6 public safety, social services, and tourism and recreation are expected to be of small 

7 significance at all sites. 

8 Public services: education (license renewal term). Only impacts of small significance are 

9 expected.

10 Aesthetic impacts (license renewal term). No significant impacts are expected during the 

11 license renewal term. 

12 Aesthetic impacts of transmission lines (license renewal term). No significant impacts 

13 during the license renewal term. 

14 No new and significant information was identified for these issues during the review. Therefore, 

15 it is expected that there would be no impacts during the renewal term beyond those discussed 

16 in the GEIS. 

17 Table 4-7 lists the Category 1 socioeconomic issues, which require plant-specific analysis, and 

18 an environmental justice impact analysis, that was not addressed in the GEIS. 

19 Table 4-7. Category 1 Issues Applicable to Socioeconomics and Environmental Justice 

20 during the Renewal Term 

Issues GEIS Section Category 

Public Services: public safety, social services, and tourism and 

recreation 

4.7.3; 4.7.3.3; 4.7.3.4; 

4.7.3.6 

1 

Public Services: education (license renewal) 4.7.3.1 1 

Aesthetic Impacts (license renewal term) 4.7.6 1 

Aesthetic impacts of transmission lines (license renewal term) 4.5.8 1 

Environmental Justice Not addressed(a) Uncategorized(a)

(a) Guidance related to environmental justice was not in place at the time the GEIS was prepared. Environmental 

justice must be addressed in plant-specific reviews. 
Environmental Impacts of Operation 

Draft NUREG-1437, Supplement 41 4-20 February 2010 

1 4.9.2 Housing Impacts 

2 According to the 2000 Census, approximately 18,318 people lived within 20 miles of CNS-1, 

3 which equates to a population density of 15 persons per square mile (NPPD, 2008). The NRC 

4 staff defined in the GEIS this density to be most sparse (less than 40 persons per square mile 

5 and no community with 25,000 or more persons within 20 miles) and determined it to be 

6 Category 1. Approximately 160,211 people live within 50 miles of CNS-1 (NPPD, 2008). This 

7 equates to a population density of 20 persons per square mile. Applying the GEIS proximity 

8 measures, CNS-1 is classified as proximity. Category 1 (no city with 100,000 or more persons 

9 and less than 50 persons per square mile within 50 miles). Therefore, according to the 

10 sparseness and proximity matrix presented in the GEIS, rankings of sparseness Category 1 and 

11 proximity Category 1 result in the conclusion that CNS-1 is located in a low population area. 

12 Since Nemaha, Otoe, Richardson, and Atchison counties are not subject to growth control 

13 measures that would limit housing development, any changes in employment at CNS-1 would 

14 have little noticeable effect on housing availability in these counties. Since NPPD has no plans 

15 to add non-outage employees during the license renewal period, employment levels at CNS-1 

16 would remain relatively constant with no additional demand for permanent housing during the 

17 license renewal term. Based on this information, there would be no additional impact on housing 

18 during the license renewal term. 

19 4.9.3 Public Services: Public Utility Impacts 

20 In Section 4.7.4 of the GEIS, the staff defined impacts on public utility services as SMALL if the 

21 existing infrastructure could accommodate any plant-related demand without a noticeable effect 

22 on the level of service. Impacts are defined as MODERATE if the demand for service or use of 

23 the infrastructure is sizeable and would noticeably decrease the level of service or require 

24 additional resources to maintain the level of service. Impacts are defined as LARGE when new 

25 programs, upgraded or new facilities, or substantial additional staff is needed because of plant26 related demand. In the absence of new and significant information to the contrary, the only 

27 impacts on public utilities that could be significant would be impacts on public water supplies. 

28 Analysis of impacts on the public water systems considered both plant demand and plant29 related population growth. Section 2.1.3 describes the permitted withdrawal rate and actual use 

30 of water for reactor cooling at CNS-1. 

31 Since NPPD has no plans to add non-outage employees during the license renewal period, 

32 employment levels at CNS-1 would remain relatively unchanged with no additional demand for 

33 public water services. Public water systems in the region would be adequate to meet the 

34 demands of residential and industrial customers in the area. Therefore, there would be no 

35 additional impact to public water services during the license renewal term. 

36 4.9.4 Offsite Land Use – License Renewal Period 

37 Offsite land use during the license renewal term is a Category 2 issue (10 CFR Part 51, Subpart 

38 A, Appendix B, Table B-1). Table B-1 of 10 CFR Part 51, Subpart A, Appendix B notes that 

39 “significant changes in land use may be associated with population and tax revenue changes 

40 resulting from license renewal.” 
Environmental Impacts of Operation 

February 2010 4-21 Draft NUREG-1437, Supplement 41 

1 In Section 4.7.4 of the GEIS, the NRC staff defines the magnitude of land-use changes as a 

2 result of plant operation during the license renewal term as SMALL when there will be little new 

3 development and minimal changes to an area's land-use pattern, as MODERATE when there 

4 will be considerable new development and some changes to the land-use pattern, and LARGE 

5 when there will be large-scale new development and major changes in the land-use pattern. 

6 Tax revenue can affect land use because it enables local jurisdictions to provide the public 

7 services (e.g., transportation and utilities) necessary to support development. Section 4.7.4.1 of 

8 the GEIS states that the assessment of tax-driven land-use impacts during the license renewal 

9 term should consider (1) the size of the plant’s tax payments relative to the community’s total 

10 revenues, (2) the nature of the community’s existing land-use pattern, and (3) the extent to 

11 which the community already has public services in place to support and guide development. If 

12 the plant’s tax payments are projected to be small relative to the community’s total revenue, tax 

13 driven land-use changes during the plant’s license renewal term would be SMALL, especially 

14 where the community has pre-established patterns of development and has provided public 

15 services to support and guide development. Section 4.7.2.1 of the GEIS states that if new tax 

16 payments are less than 10 percent of the taxing jurisdiction’s revenue, the significance level 

17 would be SMALL. If tax payments are 10 to 20 percent of the community’s total revenue, new 

18 tax-driven land-use changes would be MODERATE. If tax payments are greater than 20 percent 

19 of the community’s total revenue, new tax-driven land-use changes would be LARGE. This 

20 would be especially true where the community has no pre-established pattern of development or 

21 has limited public services available to support and guide development. 

22 4.9.4.1 Population-Related Impacts 

23 Since NPPD has no plans to add non-outage employees during the license renewal period, 

24 there would be no plant operations-driven population increase in the vicinity of CNS-1. 

25 Therefore, there would be no additional population-related offsite land use impacts during the 

26 license renewal term.

27 4.9.4.2 Tax Revenue-Related Impacts 

28 As previously discussed in Chapter 2, NPPD makes annual payments in lieu of taxes (PILOT) to 

29 the municipalities and 91 counties in Nebraska where NPPD sells power. Since NPPD started 

30 making payments to local jurisdictions, population levels and land use conditions have not 

31 changed significantly, which might indicate that these tax revenues have had little or no affect 

32 on land use activities within the county. PILOT payments are based upon the gross revenues 

33 NPPD receives from electricity sales in the 91 counties, regardless of where the power is 

34 generated. The magnitude of the PILOT payments relative to the county's total revenues is not 

35 relevant in assessing tax revenue-related offsite land use impacts since NPPD is responsible for 

36 producing and distributing electricity and PILOT payments even if the CNS-1 does not produce 

37 electricity or the operating license is not renewed. 

38 Since NPPD has no plans to add non-outage employees during the license renewal period, 

39 employment levels at the CNS-1 would remain relatively unchanged. Annual PILOT payments 

40 would also remain relatively unchanged throughout the license renewal period. Based on this 

41 information, there would be no additional tax-revenue-related offsite land use impacts during the 

42 license renewal term. 
Environmental Impacts of Operation 

Draft NUREG-1437, Supplement 41 4-22 February 2010 

1 4.9.5 Public Services: Transportation Impacts 

2 Table B-1 of Appendix B to Subpart A of 10 CFR Part 51 states the following: 

3 Transportation impacts (level of service) of highway traffic generated...during the 

4 term of the renewed license are generally expected to be of SMALL significance. 

5 However, the increase in traffic associated with additional workers and the local 

6 road and traffic control conditions may lead to impacts of MODERATE or LARGE 

7 significance at some sites. 

8 All applicants are required by 10 CFR 51.53(c)(3)(ii)(J) to assess the impacts of highway traffic 

9 generated by the proposed project on the level of service of local highways during the term of 

10 the renewed license and during refurbishment activities. 

11 Since NPPD has no plans to add non-outage employees during the license renewal period and 

12 does not plan any refurbishment activities, there would be no noticeable change in traffic 

13 volume and levels of service on roadways in the vicinity of CNS-1; therefore, there would be no 

14 additional transportation impacts during the license renewal term. 

15 4.9.6 Historic and Archaeological Resources 

16 The National Historic Preservation Act (NHPA) requires Federal agencies to consider the effects 

17 of their undertakings on historic properties. Historic properties are defined as resources that are 

18 eligible for listing on the National Register of Historic Places (NRHP). The criteria for eligibility 

19 are listed in 36 CFR 60.4 and include (1) association with significant events in history,(2) 

20 association with the lives of persons significant in the past, (3) embodies distinctive 

21 characteristics of type, period, or construction, and (4) sites or places that have yielded or are 

22 likely to yield important information (ACHP 2009). The historic preservation review process 

23 (Section 106 of the NHPA) is outlined in regulations issued by the Advisory Council on Historic 

24 Preservation in 36 CFR Part 800. 

25 The issuance of a renewed operating license for a nuclear power plant is a Federal action that 

26 could affect historic properties on or near the nuclear plant site and transmission lines. In 

27 accordance with the provisions of the NHPA, the NRC is required to make a reasonable effort to 

28 identify historic properties included in or eligible for inclusion in the NRHP in the area of 

29 potential effect. The area of potential effect (APE) for license renewal is the nuclear power plant 

30 site, transmission lines, and immediate environs. If historic properties are present, the NRC is 

31 required to contact the State Historic Preservation Office (SHPO), assess the potential impact, 

32 and resolve any possible adverse effects of the undertaking (license renewal) on historic 

33 properties. NRC is also required to notify the SHPO if historic properties would not be affected 

34 by license renewal or if no historic properties are present. 

35 NPPD contacted the Missouri SHPO and the Nebraska State Historical Society (NSHS) in 

36 January 2008, requesting information on historic and archaeological resources in the vicinity of 

37 CNS-1 and described the proposed action (license renewal) (NPPD, 2008). The NSHS 

38 responded in February 2008 that the proposed action (license renewal) would have no effect on 

39 historic structures (NPPD, 2008). The Missouri SHPO requested that an “historic architectural 

40 and archaeological survey” be conducted at the CNS-1 (NPPD, 2008). In response to the 

41 Missouri SHPO’s request, NPPD conducted a survey and submitted a Phase 1A Literature 

42 Review and Archeological Sensitivity Assessment along with NPPD’s “Cultural Resources 

43 Protection Plan” in May 2008 (NPPD, 2008). In June 2008, the Missouri SHPO concurred with 

44 the conclusions in NPPD’s archaeological assessment (NPPD, 2008). 
Environmental Impacts of Operation 

February 2010 4-23 Draft NUREG-1437, Supplement 41 

1 In accordance with 36 CFR 800.8(c), the NRC contacted the Missouri SHPO (NRC, 2008a), the 

2 NSHS (NRC, 2008b), the Advisory Council on Historic Preservation (NRC, 2008c), and 

3 Federally-recognized American Indian Tribes to initiate Section 106 consultation. These letters 

4 are presented in Appendix D. 

5 In April 2007 and March 2008, NPPD contracted with Enercon Services, Inc. to conduct an 

6 “historic architectural and archaeological survey” of the CNS-1 site. A report, Phase 1A 

7 Literature Review and Archeological Sensitivity Assessment of the Cooper Nuclear Station, 

8 Nemaha County, Nebraska, Atchison County Missouri, prepared by Enercon Service for NPPD ( 

9 did not conduct any subsurface testing. The survey determined that 55 acres of the site were 

10 heavily disturbed by construction of the CNS-1 facility and some of the lands have and continue 

11 to be farmed. The study identified one prehistoric site (Whitten) adjacent to CNS-1 property, two 

12 prehistoric lithic scatters, and three former house (farm) sites. All surface structures associated 

13 with the earlier house sites have been demolished; however, remnants of these buildings 

14 remain as historic archaeological sites and could be eligible for inclusion to the NRHP under 

15 Criteria A and D pending further research. Additionally, Lewis and Clark were known to have 

16 camped in the vicinity of CNS-1. The exact location of this campsite has never been 

17 determined. 

18 As discussed in Section 2.2.9, a search of the NSHS site files identified no previously recorded 

19 historic properties on CNS-1 property; however, the Enercon report indicates that portions of the 

20 Whitten site could extend onto CNS-1 property. A formal archaeological survey of the CNS-1 

21 site has not been completed; however, a number of archaeological and historical research 

22 studies have been conducted in both Nemaha and Atchison counties. These surveys identified 

23 several historic and archaeological sites within a 6-mile radius of CNS-1. The resources found 

24 during these surveys tend to occur on the same landforms that occur on the CNS-1 property 

25 suggesting that there is a potential for deeply buried undiscovered historic and archaeological 

26 resources on the plant property. 

27 The Whitten archeological site (25NH4) is a prehistoric mound (Plains Woodland) site 

28 excavated in the late 1930s. It is unclear from the archaeological site description if the Whitten 

29 site was located entirely on private property north of CNS-1, or if the site extended onto the 

30 CNS-1 property. Human remains, grave goods, and other artifacts were recovered from this 

31 site. Artifacts recovered from the site suggest an affiliation with the Sterns Creek variant of the 

32 Plains Woodland tradition (Gibbon and Ames, 1998). The NSHS site form noted that some of 

33 the remains were sent to the U.S. National Museum in accordance with a Works Progress 

34 Administration contract (NSHS, 1937). Historic records indicate that the entire bluff was 

35 surveyed from CNS-1 property to the city of Nemaha. During Enercon’s 2007 and 2008 

36 walkovers, no additional burial mounds were identified; however, there remains a potential for 

37 additional prehistoric sites (camp sites) to be in the area. During NRC’s walkover survey, the 

38 staff noted the presence of prehistoric and historic artifacts on CNS-1 property. 

39 The William Dawson House (Site # NH00-69), located in the southwest corner of the site near 

40 the bluff, was recorded in Nebraska historic archives but not included on the NRHP. The 

41 Dawson House was torn down shortly after it was recorded. No visible remnants of the house 

42 remain; however, subsurface portions of the house could remain. 
Environmental Impacts of Operation 

Draft NUREG-1437, Supplement 41 4-24 February 2010 

1 During the environmental site visit, the NRC staff discovered that archaeological surveys were 

2 not conducted prior to the construction of the firing range. At that time, NPPD did not have 

3 corporate procedures (Cultural Resources Protection Plan) in place. In preparation for license 

4 renewal, NPPD contracted with Enercon to survey the site and established a Cultural 

5 Resources Protection Plan to acknowledge and improve the protection of archaeological 

6 resources at CNS-1. In its plan, NPPD calls for surveys to be conducted by a qualified 

7 archaeologist in areas deemed sensitive prior to work commencing. 

8 In addition, during the construction of the independent spent fuel storage installation (ISFSI) 

9 pad, soil was removed from the top of the bluff (with consent of the landowner). Archaeological 

10 surveys were not conducted prior to this activity. NPPD has since taken corrective actions to 

11 ensure that all aspects of its Cultural Resources Protection Plan are followed. 

12 NPPD currently has no planned changes or ground disturbing activities associated with license 

13 renewal at CNS-1; however, given the high potential for the discovery of additional historic and 

14 archaeological resources at the CNS-1 site, NPPD needs to ensure that these resources are 

15 considered during future plant operations and maintenance activities. The CNS-1 is situated in 

16 an area where historic and archaeological resources could be located several feet beneath the 

17 ground surface. NPPD has instituted a stop work order within its Cultural Resources Protection 

18 Plan to ensure that proper notification is taken to protect these resources should they be 

19 discovered. 

20 Based on review of NSHS files, archaeological surveys, assessments, and other information, 

21 the potential impacts of continued operations and maintenance on historic and archaeological 

22 resources at CNS-1 would be SMALL. NPPD could further reduce potential impacts to historic 

23 and archaeological resources located at the CNS-1 by training NPPD staff in the Section 106 

24 consultation process and cultural awareness training to ensure that informed decisions are 

25 made prior to any ground disturbing activities. In addition, NPPD could also forward its Cultural 

26 Resources Protection Plan to the NSHS and the Missouri SHPO for review and comment. This 

27 will ensure that historic and archaeological resources are protected at the CNS-1 site. Any 

28 revisions to the Cultural Resources Protection Plan should be developed in consultation with the 

29 NRC, NSHS, and Missouri SHPO. In addition, lands not surveyed should be investigated by a 

30 qualified archaeologist prior to any ground disturbing activity. 

31 4.9.7 Environmental Justice 

32 Under Executive Order (E.O.) 12898 (59 Federal Register (FR) 7629) as amended by 60 FR 

33 6381, January 30, 1995, Federal agencies are responsible for identifying and addressing 

34 potential disproportionately high and adverse human health and environmental impacts on 

35 minority and low-income populations. In 2004, the Commission issued a Policy Statement on 

36 the Treatment of Environmental Justice Matters in NRC Regulatory and Licensing Actions (69 

37 FR 52040), which states “The Commission is committed to the general goals set forth in E.O. 

38 12898, and strives to meet those goals as part of its National Environmental Policy Act of 1969 

39 (NEPA) review process.” 

40 The Council on Environmental Quality (CEQ) provides the following information in 

41 Environmental Justice: Guidance under the National Environmental Policy Act (NEPA) (1997): 

42 Disproportionately High and Adverse Human Health Effects. When 

43 determining whether human health effects are disproportionately high and 

44 adverse, agencies are to consider the following three factors to the extent 
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February 2010 4-25 Draft NUREG-1437, Supplement 41 

1 practicable: (a) Whether the health effects, which may be measured in risks and 

2 rates, are significant (as employed by NEPA), or above generally accepted 

3 norms. Adverse health effects may include bodily impairment, infirmity, illness, or 

4 death; and (b) Whether the risk or rate of hazard exposure by a minority 

5 population, low-income population, or Indian tribe to an environmental hazard is 

6 significant (as employed by NEPA) and appreciably exceeds or is likely to 

7 appreciably exceed the risk or rate to the general population or other appropriate 

8 comparison group; and (c) Whether health effects occur in a minority population, 

9 low-income population, or Indian tribe affected by cumulative or multiple adverse 

10 exposures from environmental hazards. (CEQ, 1997). 

11 Disproportionately High and Adverse Environmental Effects. When 

12 determining whether environmental effects are disproportionately high and 

13 adverse, agencies are to consider the following three factors to the extent 

14 practicable: (a) Whether there is or will be an impact on the natural or physical 

15 environment that significantly (as employed by NEPA) and adversely affects a 

16 minority population, low-income population, or Indian tribe. Such effects may 

17 include ecological, cultural, human health, economic, or social impacts on 

18 minority communities, low-income communities, or Indian tribes when those 

19 impacts are interrelated to impacts on the natural or physical environment; and 

20 (b) Whether environmental effects are significant (as employed by NEPA) and 

21 are or may be having an adverse impact on minority populations, low income 

22 populations, or Indian tribes that appreciably exceeds or is likely to appreciably 

23 exceed those on the general population or other appropriate comparison group; 

24 and (c) Whether the environmental effects occur or would occur in a minority 

25 population, low-income population, or Indian tribe affected by cumulative or 

26 multiple adverse exposures from environmental hazards. (CEQ, 1997). 

27 The environmental justice analysis assesses the potential for disproportionately high and 

28 adverse human health or environmental effects on minority and low-income populations that 

29 could result from the operation of CNS-1 during the renewal term. In assessing the impacts, the 

30 following CEQ (1997) definitions of minority individuals and populations and low-income 

31 population were used: 

32 Minority. Individual(s) who are members of the following population groups: 

33 American Indian or Alaskan Native; Asian or Pacific Islander; Black, not of 

34 Hispanic origin; or Hispanic. 

35 Minority populations. Minority populations should be identified where either: (a) 

36 the minority population of the affected area exceeds 50 percent or (b) the 

37 minority population percentage of the affected area is meaningfully greater than 

38 the minority population percentage in the general population or other appropriate 

39 unit of geographic analysis. In identifying minority communities, agencies may 

40 consider as a community either a group of individuals living in geographic 

41 proximity to one another, or a geographically dispersed/transient set of 

42 individuals (such as migrant workers or Native American ), where either type of 

43 group experiences common conditions of environmental exposure or effect. The 

44 selection of the appropriate unit of geographic analysis may be a governing 

45 body’s jurisdiction, a neighborhood, census tract, or other similar unit that is to be 

46 chosen so as to not artificially dilute or inflate the affected minority population. A 

47 minority population also exists if there is more than one minority group present 
Environmental Impacts of Operation 

Draft NUREG-1437, Supplement 41 4-26 February 2010 

1 and the minority percentage, as calculated by aggregating all minority persons, 

2 meets one of the above-stated thresholds. 

3 Low-income population. Low-income populations in an affected area are 

4 identified with the annual statistical poverty thresholds from the U. S. Census 

5 Bureau’s (USCB) Current Population Reports, Series PB60, on Income and 

6 Poverty. 

7 4.9.7.1 Minority Population in 2000 

8 The 50-mile radius around CNS-1 includes 24 counties with nine in Nebraska, six in Kansas, 

9 five in Iowa, and four in Missouri. The geographic area includes any census block with all or part 

10 of its area within the 50-mile radius. According to 2000 census data, 4.3 percent of the 

11 population (approximately 160,248 individuals) residing within a 50-mile (80 km) radius of CNS12 1 identified themselves as minority individuals. The largest minority group was Hispanic or 

13 Latino (2,295 persons or 1.4 percent), followed by American Indian (2,366 or about 1.5 percent) 

14 (USCB, 2003 – LandView 6). About 2.9 percent of the Nemaha County population identified 

15 themselves as minorities, with Hispanic or Latino being the largest minority group (1.0 percent) 

16 followed by some other race (0.7 percent) (USCB, 2009) (see Table 2.2.8.5–2). 

17 Populations within each state were considered individually and as a 

18 four-state geographic area. A combined or aggregate population of the four-state area was 

19 calculated based on these state populations. 

20 Approximately 370 (individual state method) to 380 (four-state combined method) blocks within 

21 50 miles of CNS-1 were determined to have high density minority population percentages that 

22 exceeded the state average by 20 percentage points or more. The largest number of high 

23 density minority blocks was Hispanic or Latino, with 160 (four-state combined) to 170 (individual 

24 state) blocks that exceed the state average by 20 percent or more. The greatest concentrations 

25 of high density minority population blocks are located nearly 50 miles south of CNS-1 in Brown 

26 County, Kansas, and approximately 30 miles south-southeast of CNS-1 where the Nebraska27 Kansas-Missouri state borders come together. The closest high density minority population is 

28 located approximately 10 miles west of CNS-1, near Nemaha (NPPD, 2008). 

29 The Sac and Fox and Iowa Indian Reservations straddle the border of Nebraska (Richardson 

30 County) and Kansas (Brown and Doniphan counties). The Kickapoo Indian Reservation is 

31 located south of CNS-1 in Brown County, Kansas. 

32 Based on 2000 census data, Figure 4-1 (individual state method) and Figure 4-2 

33 (four-state combined method) show the locations of high density minority blocks within a 50-mile 

34 radius of CNS-1. 
Environmental Impacts of Operation 

February 2010 4-27 Draft NUREG-1437, Supplement 41 

1 

2 Figure 4-1. Minority Blocks in 2000 within a 50-Mile Radius of Cooper Nuclear Station 

3 (Individual State) (Source: USCB, 2008)
Environmental Impacts of Operation 

Draft NUREG-1437, Supplement 41 4-28 February 2010 

1 

2 Figure 4-2. Minority Blocks in 2000 within a 50-Mile Radius of Cooper Nuclear Station 

3 (Combined State) (Source: USCB, 2008)

4 4.9.7.2 Low-Income Population in 2000 

5 According to 2000 census data, approximately 3,100 families and 16,000 individuals 

6 (approximately 7.3 and 10.1 percent, respectively) residing within a 50-mile radius of CNS-1 

7 were identified as living below the Federal poverty threshold in 1999 (USCB, 2003-LandView 6). 

8 The 1999 Federal poverty threshold was $17,029 for a family of four. 

9 According to census data estimates, the median household income for Nebraska in 2007 was 

10 $47,072, with 11.1 percent of the state population living below the Federal poverty threshold. 
Environmental Impacts of Operation 

February 2010 4-29 Draft NUREG-1437, Supplement 41 

1 Nemaha County had a lower median household income average ($41,024) and a higher 

2 percentage (13.3 percent) of individuals living below the poverty level when compared to the 

3 state average. Richardson County had the lowest median household income of the four 

4 counties ($36,092) and a higher percentage (13.4 percent) of individuals living below the 

5 poverty level when compared to the state. Otoe County had the highest median household 

6 income ($45,018) and the lowest percentage (9.4 percent) of individuals living below the poverty 

7 level among the four counties (USCB, 2008). Atchinson County, Missouri, had a lower median 

8 household income average ($38,114) than the state and the highest percentage (14.0 percent) 

9 of individuals living below the poverty level among the four counties. The median household 

10 income for Missouri in 2007 was $45,012, with 13.3 percent of the state population living below 

11 the Federal poverty threshold (USCB, 2009). 

12 Census block groups were considered high density low-income block groups if the percentage 

13 of households below the Federal poverty threshold exceeded the state average by 20 percent or 

14 more. Based on 2000 census data, there were 192 block groups within the 50-mile radius of 

15 CNS-1 that exceeded the state average for low income households by 20 percent or more. The 

16 majority of census block groups with low-income populations were located in two counties, Page 

17 County and Nodaway County in Missouri (NPPD, 2008). Figure 4-3 (individual state method) 

18 and Figure 4-4 (four-state combined method) show the location of high density low-income 

19 census block groups within a 50-mile radius of CNS-1. 
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Draft NUREG-1437, Supplement 41 4-30 February 2010 

1 

2 Figure 4-3. Low-Income Block Groups with a 50-Mile Radius of Cooper Nuclear Station 

3 (Individual States) (Source: USCB, 2008)
Environmental Impacts of Operation 

February 2010 4-31 Draft NUREG-1437, Supplement 41 

1 

2 Figure 4-4. Low-Income Block with a 50-Mile Radius of Cooper Nuclear Station 

3 (Combined States) (Source: USCB, 2008)
Environmental Impacts of Operation 

Draft NUREG-1437, Supplement 41 4-32 February 2010 

1 4.9.7.3 Analysis of Impacts 

2 Consistent with the impact analysis for the public and occupational health and safety, the 

3 affected populations are defined as minority and low-income populations who reside within a 

4 50-mile radius of the CNS-1. Based on the analysis of environmental health and safety impacts 

5 presented in Chapter 4 of this SEIS for other resource areas, there would be no 

6 disproportionately high and adverse impacts to minority and low-income populations from the 

7 continued operation of the CNS-1 during the license renewal period. 

8 NRC also analyzed the risk of radiological exposure through the consumption patterns of 

9 special pathway receptors, including subsistence consumption of fish, native vegetation, surface 

10 waters, sediments, and local produce; absorption of contaminants in sediments through the 

11 skin; and inhalation of plant materials. The special pathway receptors analysis is important to 

12 the environmental justice analysis because consumption patterns may reflect the traditional or 

13 cultural practices of minority and low-income populations in the area. This analysis is presented 

14 below. 

15 4.9.7.4 Subsistence Consumption of Fish and Wildlife 

16 Section 4-4 of Exec. Order No. 12898 (1994) directs Federal agencies, whenever practical and 

17 appropriate, to collect and analyze information on the consumption patterns of populations that 

18 rely principally on fish and wildlife for subsistence and to communicate the risks of these 

19 consumption patterns to the public. NRC considered whether or not there were any means for 

20 minority or low-income populations to be disproportionately affected by examining impacts to 

21 American Indian, Hispanic, and other traditional lifestyle special pathway receptors. Special 

22 pathways that took into account the levels of contaminants in native vegetation, crops, soils and 

23 sediments, surface water, fish, and game animals in the vicinity of CNS-1 were considered. 

24 NPPD has an ongoing comprehensive REMP at CNS-1 that assesses the radiological impact of 

25 site operations on the environment. Radiological environmental monitoring began at CNS-1 in 

26 1971 before the plant became operational. The REMP program monitors radiation levels in air, 

27 terrestrial, and aquatic environments. All samples are collected by NPPD personnel and are 

28 shipped to a laboratory for analysis. 

29 To assess the radiological impact of the plant on the environment, the monitoring program at 

30 CNS-1 uses indicator-control sampling. Samples are collected at nearby indicator locations 

31 downwind and downstream from the plant and at distant control locations upwind and upstream 

32 from the plant. A plant effect would be indicated if the radiation level at an indicator location was 

33 significantly larger than at the control location. The difference would also have to be greater 

34 than could be accounted for by typical fluctuations in radiation levels arising from other 

35 naturally-occurring sources. 

36 Samples are collected from the aquatic and terrestrial pathways in the vicinity of CNS-1. The 

37 aquatic pathways include fish, Missouri River surface water, ground water, and shoreline 

38 sediment. The terrestrial pathways include airborne particulates, milk and food product garden 

39 (leaf) vegetation, and direct radiation. During 2007, analyses performed on collected samples of 

40 environmental media showed no significant or measurable radiological impact from CNS-1 

41 operations (NPPD, 2008) 

42 Aquatic sampling at the CNS-1 consists of semi-annual upstream and downstream collections 

43 of fish and shoreline sediments. All samples are analyzed for gamma-emitting isotopes. River 

44 water is collected monthly at two locations, one upstream of the plant and one downstream. 
Environmental Impacts of Operation 

February 2010 4-33 Draft NUREG-1437, Supplement 41 

1 Quarterly composites are analyzed for tritium. All results were below the required lower limit of 

2 detection (NPPD, 2008). 

3 Sediment samples collected during June and October 2007 were analyzed by gamma 

4 spectrometry. A number of naturally occurring radionuclides were detected in these samples. 

5 Naturally occurring potassium-40 and thorium-228 were observed in all samples. All other 

6 gamma emitters were below their detection limits (NPPD, 2008). 

7 Eight samples of fish were collected during the summer and fall of 2007. A middle-top feeding 

8 fish (carp) and a bottom feeding fish (catfish) were collected in June and October. These 

9 samples were analyzed by gamma ray spectroscopy. Only naturally occurring potassium-40 

10 was detected (NPPD, 2008). 

11 According to the 2007 CNS-1 REMP, 17 milk samples from the nearest producers were 

12 collected and analyzed by gamma ray spectroscopy and for low-level iodine-131 by 

13 radiochemical separation. Naturally occurring potassium-40 was measured in all samples. 

14 Thorium-228 was measured in one sample. All other gamma emitters were below their detection 

15 levels. Four milk samples were collected from other producers. Naturally occurring potassium16 40 was detected in all four samples. All other gamma emitters were below their detection levels 

17 (NPPD, 2008). 

18 Ground water was collected from two stations quarterly and analyzed for tritium and for gamma 

19 emitting radionuclides. One station is located 0.15 miles from the plant and another station 25.8 

20 miles from the plant. Naturally occurring potassium-40 was detected in 2 of 24 samples 

21 analyzed. Naturally occurring thorium-228 was detected in 2 of 24 samples analyzed. All other 

22 gamma emitters were below their detection levels. 

23 There were 26 broadleaf vegetation samples were collected June through September from 

24 three locations during 2007. The samples were analyzed by gamma ray spectroscopy and for 

25 low-level iodine-131 by radiochemical separation. Beryllium-7, which is produced continuously 

26 in the upper atmosphere by cosmic radiation, was measured in 24 of 26 samples analyzed. 

27 Naturally occurring potassium-40 was measured in all 26 samples analyzed. All other gamma 

28 emitters were below their detection levels (NPPD, 2008). 

29 The results of the CNS-1 2007 REMP sampling demonstrate that the routine operation at CNS30 1 has had no significant or measurable radiological impact on the environment. No elevated 

31 radiation levels were detected in the offsite environment as a result of plant operations and the 

32 storage of radioactive waste. The results of the REMP continue to demonstrate that the 

33 operation of the CNS-1 did not result in a significant measurable dose to a member of the 

34 general population or adversely impact the environment as a result of radiological effluents. The 

35 REMP continues to demonstrate that the dose to a member of the public from the operation of 

36 CNS-1 remains significantly below the Federally required dose limits specified in 10 CFR Part 

37 20, 10 CFR Part 72, and 40 CFR Part 190. 

38 Based on recent monitoring results, concentrations of contaminants in native leafy vegetation, 

39 soils and sediments, surface water, and fish in areas surrounding CNS-1 have been quite low 

40 (at or near the threshold of detection) and seldom above background levels. Consequently, no 

41 disproportionately high and adverse human health impacts would be expected in special 

42 pathway receptor populations in the region as a result of subsistence consumption of fish and 

43 wildlife. 
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Draft NUREG-1437, Supplement 41 4-34 February 2010 

1 4.10 EVALUATION OF NEW AND POTENTIALLY SIGNIFICANT INFORMATION 

2 New and significant information is (1) information that identifies a significant environmental issue 

3 not covered in the GEIS and codified in Table B-1 of 10 CFR Part 51, Subpart A, Appendix B, or 

4 (2) information that was not considered in the analyses summarized in the GEIS and that leads 

5 to an impact finding that is different from the finding presented in the GEIS and codified in 10 

6 CFR Part 51. 

7 In preparing to submit its application to renew the CNS-1 operating license, NPPD developed a 

8 process to ensure that information not addressed in or available during the GEIS evaluation 

9 regarding the environmental impacts of license renewal for CNS-1 would be properly reviewed 

10 before submitting the ER, and to ensure that such new and potentially significant information 

11 would be identified, reviewed, and assessed during the NRC review period. NPPD reviewed the 

12 Category 1 issues that appear in Table B-1 of 10 CFR Part 51, Subpart A, Appendix B, to verify 

13 that the conclusions of the GEIS remained valid with respect to CNS-1. This review was 

14 performed by personnel from CNS-1 and its support organization that were familiar with NEPA 

15 issues and the scientific disciplines involved in the preparation of a license renewal ER. NRC 

16 also has a process for identifying new and significant information. That process is described in 

17 detail in NUREG-1555, Supplement 1, Standard Review Plans for Environmental Reviews for 

18 Nuclear Power Plants, Supplement 1: Operating License Renewal (NRC, 2000). The search for 

19 new information includes (1) review of an applicant’s ER and the process for discovering and 

20 evaluating the significance of new information; (2) review of records of public comments; (3) 

21 review of environmental quality standards and regulations; (4) coordination with Federal, State, 

22 and local environmental protection and resource agencies; and (5) review of the technical 

23 literature. New information discovered by the NRC staff is evaluated for significance using the 

24 criteria set forth in the GEIS. For Category 1 issues where new and significant information is 

25 identified, reconsideration of the conclusions for those issues is limited in scope to the 

26 assessment of the relevant new and significant information; the scope of the assessment does 

27 not include other facets of the issue that are not affected by the new information. 

28 The NRC staff has not identified any new and significant information on environmental issues 

29 listed in Table B-1 of 10 CFR Part 51, Subpart A, Appendix B, related to the operation of CNS-1 

30 during the period of license extension. The NRC staff also determined that information provided 

31 during the public comment period did not identify any new issues that require site-specific 

32 assessment. The NRC staff reviewed the discussion of environmental impacts in the GEIS 

33 (NRC, 1996) and conducted its own independent review (including the public scoping meetings 

34 held in February 2009) to identify new and significant information. 

35 4.11 CUMULATIVE IMPACTS 

36 The NRC staff considered potential cumulative impacts in the environmental analysis of 

37 continued operation of CNS-1. For the purposes of this analysis, past actions are those related 

38 to the resources at the time of the power plant licensing and construction. Present actions are 

39 those related to the resources at the time of current operation of the power plant, and future 

40 actions are considered to be those that are reasonably foreseeable through the end of plant 

41 operation including the period of extended operation. Therefore, the analysis considers potential 

42 impacts through the end of the current license terms as well as the 20-year renewal license 

43 term. The geographic area over which past, present, and future actions would occur is 

44 dependent on the type of action considered and is described below for each impact area. 
Environmental Impacts of Operation 

February 2010 4-35 Draft NUREG-1437, Supplement 41 

1 The impacts of the proposed action, as described in Sections 4.1–4.9, are combined with other 

2 past, present, and reasonably foreseeable future actions regardless of what agency (Federal or 

3 non-Federal) or person undertakes such other actions. 

4 4.11.1 Cumulative Impacts on Water Resources 

5 NRC staff divided the description and discussion of water resources in previous sections into 

6 ground water and surface water issues in order to follow the regulatory structure presented in 

7 10 CFR Part 51 (2009). Hydrologic conditions at CNS-1 and elsewhere within the Missouri River 

8 Valley, however, indicate a hydraulic connection between surface and ground water, particularly 

9 between the Missouri River and the alluvial aquifer underlying the valley. This connection 

10 reveals the possible impact of reduced river flow on ground water levels. 

11 NPPD (2008) reviewed well records and identified 1,400 registered wells within the Nemaha 

12 River Basin, which includes the Missouri River below its confluence with the Platte River. Of the 

13 wells identified, very few are close to CNS-1. The NGPC installed three wells about 1.5 miles 

14 (2.4 kilometers) south of CNS-1, and the city of Auburn, NE has a public water supply well about 

15 1.9 miles (3 kilometers) south. NPPD (2008) also identified some local shallow farm wells within 

16 2 miles (3.2 kilometers) of the plant property. All of the water supply wells in the area are 

17 completed either in the Missouri River Valley Aquifer or Glacial Drift Aquifer, which are under 

18 unconfined conditions and in hydraulic contact with the Missouri River. 

19 Enercon conducted an operations study of the CNS-1 potable wells which showed an 

20 equilibrium radius of influence of between 100 to 1,250 feet (46 to 381 meters) from each well. 

21 Enercon’s analysis of the drawdown data from the study indicated the radius of influence of 

22 CNS-1’s wells does not extend outside the CNS-1 property boundary. Because all the CNS-1 

23 wells are in hydraulic connection with the Missouri River, recharge from the river is likely 

24 induced by pumping operations. The total maximum pumping rate at CNS-1 of over 1,500 

25 gallons per minute (5,678 liters per minute) is less than one percent of the average flow in the 

26 river. Likewise, the influence of offsite pumping should have no measurable effect on ground 

27 water levels onsite. Because the cumulative effects of pumping ground water on river flow and 

28 vice versa are insignificant, the cumulative impact on water resources in the CNS-1 area is 

29 SMALL. 

30 4.11.2 Cumulative Impacts on Electromagnetic Fields and Thermophilic Microbiological 

31 Organisms 

32 The continued operation of CNS-1 has a low risk of causing outbreaks from thermophilic 

33 microbiological organisms associated with thermal discharges. Available data compiled by the 

34 CDC into biannual reports for the years 1999 to 2006 (CDC 2000, 2002, 2004, 2006) indicates 

35 no occurrence of the waterborne disease outbreaks in the State of Nebraska resulting from 

36 exposure to the thermophilic microbiological organisms Naegleria fowleri and Pseudomonas 

37 aeruginosa due to the operation of CNS-1. 

38 As part of its evaluation of cumulative impacts, the NRC staff also considered the effects of 

39 thermal discharges from other facilities on the Missouri River, located within one mile upstream 

40 of CNS-1, that are also producing thermal effluents. Such facilities could promote the growth of 

41 thermophilic microbiological organisms. The NRC staff did not find any such facilities. 

42 Potential cumulative effects of climate change on the Missouri River basin and local climate, 

43 whether or not from natural cycles or anthropogenic activities, could result in a variety of 
Environmental Impacts of Operation 

Draft NUREG-1437, Supplement 41 4-36 February 2010 

1 changes to the surface and ground water resources in the Missouri River basin. Nebraska is a 

2 part of the Great Plains Region. As projected in the “Global Climate Change Impacts in the 

3 United States” report by United States Global Change Research Program (USGCRP) (2009), 

4 the temperatures in southeastern Nebraska, where CNS-1 is located, are expected to rise 6 °F 

5 (14 °C) by 2080–2099 at minimum and maximum over 10 °F (12 °C), causing more frequent 

6 extreme weather events. Increases in average annual temperatures, higher probabilities of 

7 extreme heat events, and higher occurrences of extreme rainfall (intense rainfall or drought) 

8 could increase Missouri River temperatures and cause degradation of the water supply and its 

9 quality. Such conditions could support the proliferation of pathogenic organisms of concern and 

10 affect the burden of water-related diseases. The extent and the magnitude of the climate 

11 change on human health could be significant (Intergovernmental Panel on Climate Change 

12 (IPCC), 2009). 

13 The NRC staff concludes that the thermophilic microbiological organisms are not likely to 

14 present a public health hazard as a result of CNS-1 discharges to the Missouri River. The NRC 

15 staff concludes that the cumulative impacts on public health from thermophilic microbiological 

16 organisms from continued operation of CNS-1 during the license renewal period would be 

17 SMALL. 

18 The NRC staff determined that the CNS-1 transmission lines are operating within original design 

19 specifications and meet current NESC clearance standards; therefore, the CNS-1 transmission 

20 lines do not detectably affect the overall potential for electric shock from induced currents within 

21 the analysis area. With respect to the chronic effects of electromagnetic fields, although the 

22 GEIS finding of “not applicable” is appropriate to CNS-1, the transmission lines associated with 

23 CNS-1 are not likely to detectably contribute to the regional exposure to extremely low 

24 frequency electromagnetic fields. Therefore, the NRC staff has determined that the cumulative 

25 impacts of continued operation of the CNS-1 transmission lines would be SMALL. 

26 4.11.3 Cumulative Impacts on Aquatic Resources 

27 This section addresses the direct and indirect effects of license renewal when added to the 

28 aggregate effects of past, present, and reasonably foreseeable future actions (CEQ, 2005). The 

29 direct effects on aquatic resources from an additional 20 years of CNS-1 operation accrue 

30 primarily from impingement, entrainment, and heat shock to natural populations and the 

31 populations on which they depend through predator-prey, competitive, and other interactions. 

32 The cumulative impact is the total effect on the aquatic resources of all actions taken, no matter 

33 who has taken the actions (the second principle of cumulative effects analysis in CEQ, 1997). 

34 The geographic boundary for assessing cumulative aquatic impacts is somewhat variable and 

35 depends on the specific resource, but is generally the lower biological zone of the Missouri 

36 River, which extends from Gavins Point Dam to the confluence with the Mississippi River 

37 (Galat et al., 2005a and 2005b). 

38 The benchmark for assessing cumulative impacts on aquatic resources takes into account the 

39 pre-operational environment as recommended by the EPA (1999) for its review of NEPA 

40 documents: 

41 Designating existing environmental conditions as a benchmark may focus the 

42 environmental impact assessment too narrowly, overlooking cumulative impacts 

43 of past and present actions or limiting assessment to the proposed action and 

44 future actions. For example, if the current environmental condition were to serve 

45 as the condition for assessing the impacts of relicensing a dam, the analysis 
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February 2010 4-37 Draft NUREG-1437, Supplement 41 

1 would only identify the marginal environmental changes between the continued 

2 operation of the dam and the existing degraded state of the environment. In this 

3 hypothetical case, the affected environment has been seriously degraded for 

4 more than 50 years with accompanying declines in flows, reductions in fish 

5 stocks, habitat loss, and disruption of hydrologic functions. If the assessment 

6 took into account the full extent of continued impacts, the significance of the 

7 continued operation would more accurately express the state of the environment 

8 and thereby better predict the consequences of relicensing the dam. 

9 Section 2.2.5 presents an overview of the condition of the Missouri River ecosystem and the 

10 history and factors that led to its condition. At present, the Missouri River is a degraded 

11 ecosystem that the National Research Council (NRCC) (2002) has said may be close to or 

12 perhaps past the point of irreparable change. To determine and illustrate the environmental 

13 changes that affect resources in cumulative impact analysis, CEQ (1997) recommends a 

14 conceptual model. We present a simple conceptual model for the Missouri River ecosystem in 

15 Figure 2.2.5-1 that shows how some environmental factors affect aquatic resources. 

16 The NRCC (2002) identified the following man-induced changes in the Missouri River 

17 ecosystem that jeopardize its fundamental natural processes: “the loss of natural flood pulses; 

18 the loss of natural low flows; straightening of stream meanders and the elimination of cut-and-fill 

19 alluviation; losses of natural riparian vegetation; reductions in water temperature variation; 

20 introduction of nonnative species; and extensive bank stabilization and stream channelization.” 

21 These changes are due to activities like dam construction that alters flow and water temperature 

22 patterns, amplitude and frequency of natural peak flows used by some species as 

23 environmental cues for biological processes, and sediment transport and deposition. Land use 

24 changes; channelization; and construction of levees and dikes have altered almost three million 

25 acres of natural riverine and floodplain habitat. These changes, and more, influence primary 

26 productivity and the energy sources for aquatic communities, alter or eliminate natural habitat 

27 and habitat diversity required to support some species, and change invertebrate communities 

28 and food webs to fish. The NRCC (2002) found that “Of the 67 native fish species living along 

29 the mainstem, 51 are now listed as rare, uncommon, or decreasing across all or part of their 

30 ranges” and that one of these fish, the pallid sturgeon, is on the Federal Endangered Species 

31 List. 

32 In addition to these historic impacts, this section focuses on other facilities that withdraw 

33 Missouri River water and introduced species. CNS-1 directly affects Missouri River aquatic 

34 communities primarily through impingement, entrainment, and heat shock. Other facilities that 

35 withdraw water also impact aquatic communities through at least impingement and entrainment, 

36 and for some, also heat shock. The impact of introduction and stocking of native and introduced 

37 fish species is also somewhat similar to the impact of CNS-1, because the effect of a power 

38 plant that impinges and entrains aquatic organisms is somewhat similar to that of a large 

39 predator introduced into an aquatic system. 

40 The number of water consumptive and non-consumptive water intakes that withdraw water from 

41 the Missouri River is relatively large (Table 4-8). The cumulative stress from this large number 

42 of intakes, of which CNS-1 is one, spread across the length of the river depends on many 

43 factors that NRC staff cannot quantify, but which may be significant when added to all the other 

44 stresses on aquatic communities. 
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Draft NUREG-1437, Supplement 41 4-38 February 2010 

1 The States have stocked and released a number of native and introduced game fish into the 

2 Missouri River, primarily for sport fishing. Game fish tend to be predators, which may, through 

3 predation, affect aquatic communities in a manner somewhat similar to impingement and 

4 entrainment. For example, Nelson-Stastny (2004) compiled a list of selected introduced and 

5 native fish species stocked or released into the Missouri River in South Dakota in relation to 

6 their potential as predators of pallid sturgeon (Table 4-9). That author notes that: 

7 South Dakota made several stocking attempts with other fish species to try to 

8 utilize the newly created reservoir habitat in the South Dakota portion of the 

9 Missouri River. The fish species that were previously stocked, but for which 

10 stocking was eventually discontinued, include lake whitefish (Coregonus 

11 clupeaformis), sockeye salmon/kokanee (Oncorhyncus nerka), cutthroat trout 

12 (Oncorhyncus clarki), lake trout (Salvelinus namaycush), Bonneville cisco 

13 (Prosopium gemmiferu), muskellunge (Esox masquinongy), and tiger 

14 muskellunge (Esox lucius x masquinongy). Of these, only lake whitefish and tiger 

15 muskellunge are occasionally sampled either by anglers or in fish population 

16 surveys and these fish are believed to be from original stocking events (i.e., large 

17 adults). 

18 This example is from just one of the states in the Missouri River basin. As with water intakes, 

19 the cumulative stress from all these introductions spread across the length of the river depends 

20 on many factors, which NRC staff cannot quantify but which may be significant when added to 

21 all the other stresses on aquatic communities. 

22 While the level of impact due to direct and indirect impacts of CNS-1 on aquatic communities is 

23 SMALL, the cumulative impact when combined with all other sources has resulted in the 

24 Missouri River aquatic ecosystem being unstable and close to, if not past, the point of reparable 

25 change. This condition meets NRC’s definition of a LARGE level of impact. 
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February 2010 4-39 Draft NUREG-1437, Supplement 41 

1 Table 4-8. Intakes. Number of consumptive and non-consumptive water intakes that withdraw 

2 water from the Missouri River. 

Number of intakes by location 

 Intakes Total 

Reach Intakes 

Lower 

Boundary 

(RM) Power Municipal Industrial Irrigation Domestic Public 

Fort Peck Lake 1,771.60 1 5 101 2 109 

Fort Peck 1,547.10 5 (1) 4 283 (94) 162 (14) 1 455 (109) 

Lake 

Sakakawea 

1,389.90 1 10 (5) 6 (1) 44 (10) 228 (63) 11 300 (79) 

Garrison 1,317.40 6 3 6 77 28 3 123 

Lake Oahe 1,072.30 8 (3) 2 179 (12) 21 (6) 8 (2) 218 (23) 

Oahe 1,072.20 0 

Lake Sharpe 987.40 3 (2) 91 (71) 19 (4) 2 115 (77) 

Big Bend 987.30 0 

Lake Francis 

Case 

841.80 6 72 4 3 85 

Fort Randall 836.10 8 (4) 8 (4) 

Lewis and Clark 

Lake 

811.10 2 27 (5) 6 2 (2) 37 (7) 

Gavins Point 734.20 1 33 7 1 42 

Sioux City 648.00 2 2 1 42 (3) 2 49 (3) 

Omaha 597.20 3 2 1 8 2 5 21 

Nebraska City 497.40 2 22 1 25 

St. Joseph 374.00 3 4 2 9 

Kansas City 249.90 5 4 1 10 

Boonville 129.90 3 1 4 

Hermann 0.00 3 3 6 

Total 25 57 (11) 20 (1) 891 (199) 579 (87) 44 (4) 1,616 

(302) 

Above Gavins 

Point 

 7 38 (11) 18 (1) 786 (196) 569 (87) 32 (4) 

Below Gavins 

Point 

 18 19 2 105 (3) 10 12 

3 Numbers in parentheses refer to intakes located on reservation land. 

4 Source: USACE, 2004a, page 3-112 
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Draft NUREG-1437, Supplement 41 4-40 February 2010 

1 Table 4-9. Stastny 2004. Native and introduced fish species stocked in South Dakota into the 

2 Missouri River system that are to their potential as predators of pallid sturgeon. Species in this 

3 table were actively managed via stocking or other means in 2004 or had their status, whether 

4 native or nonnative, brought into question by others in litigation.

Species 

Name Common Name Origin Stocking Status 

Years Stocked in Missouri River 

in South Dakota 

Oncorhynchus mykiss rainbow trout I EFS 1951, 56, 57, 64, 68, 69, 1972-

2003 

Oncorhynchus 

tshawytscha 

Chinook salmon I EFS 1982-2000. 2003 

Salmo trutt brown trout I EFS 1964, 68, 79, 1981-2003 

Morone chrysops white bass I EPD 1960-62 

Coregonus artedi lake herring I EPD 1984, 88, 90-92 

Polyodon spathula paddlefish N NSA* 1974, 76-78, 1985-2003 

Osmerus mordax rainbow smelt I EPD** - 

Notropis hudsonius spottail shiner I EPD 1973-75, 78, 79 

Micropterus dolomieu smallmouth bass I EPD 1972, 74, 80, 83-92, 94-98 

Esox lucius northern pike PN, N NSA 1957, 58, 71, 82, 83, 85, 86, 88-97 

Perca flavescens yellow perch PN, N NSA - 

Sander vitreum walleye N NSA 1952, 53, 57, 58, 83-98, 2002 

5 Table adapted from Nelson-Stastny (2004, Table 1) 

6 *Paddlefish stocking in the last decade has only been in Lake Francis Case. An adult population exists in Lake 

7 Francis Case; however, natural reproduction has not been documented. 

8 ** Rainbow smelt in the South Dakota portion of the Missouri River originated from fish stocked in Lake Sakakawea in 

9 North Dakota. 

10 Origin as a native (N), introduced (I) or probable native (PN). 

11 Stocking status refers to one of the following: 

12 Established sport fishery – stocking required to maintain (EFS) 

13 Established population – stocking discontinued (EPD) 

14 Native – if stocked, additive to natural reproduction (NSA) 

15 4.11.4 Cumulative Impacts on Terrestrial Resources 

16 This section addresses past, present, and future actions that could result in adverse cumulative 

17 impacts to terrestrial resources, including wildlife populations, upland habitats, wetlands, 

18 riparian zones, invasive species, protected species, and land use. For purposes of this analysis, 

19 the geographic area considered in the evaluation includes the CNS-1 site, including the land on 

20 both the Nebraska and the Missouri sides of the Missouri River, the wetlands on and in the 

21 vicinity of the CNS-1 site, and the 145-mile long (233-kilometer) transmission line corridor 

22 identified in Section 2.1.5 of this report. 

23 Prior to construction of the CNS-1 facilities and before its conversion to cropland, the region 

24 surrounding the CNS-1 property in Nemaha County, Nebraska, and Atchison County, Missouri, 

25 was historically part of a dynamic Missouri River floodplain system, located within the Missouri 

26 alluvial plain ecoregion (U.S. Geological Survey (USGS), 2001). Historically, the Missouri River 

27 meandered across the width of this relatively flat, 6-mile (10-kilometer) wide alluvial floodplain 

28 along the border of eastern Nebraska and western Missouri. The CNS-1 facilities are located 

29 near the western edge of this floodplain and adjacent to the western bank of the Missouri River. 
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February 2010 4-41 Draft NUREG-1437, Supplement 41 

1 The vegetation within this floodplain and its vicinity was historically dominated by tallgrass 

2 prairie and wooded wetlands along the riparian corridors (NGPC, 2005). Before the completion 

3 in 1950 of the Federal levee system along the Missouri River, most of the Missouri River 

4 floodplain was subjected to frequent overbank flooding and much soil deposition occurred over 

5 the entire width of the floodplain (NPPD, 2008; USGS, 2001). Wooded wetlands dominate the 

6 239 acres of CNS-1 property on the Missouri side of the property, both today and prior to 

7 conversion of approximately 40 acres of the property to agriculture (NPPD, 2008). The Missouri 

8 CNS-1 property is also part of the Missouri alluvial plain ecoregion and much of the wooded 

9 wetland habitat historically flooded and continues to experience overbank flooding from the 

10 Missouri River (USGS, 2001). 

11 Historically, over 70 percent of the land encompassing the 145-mile long (233-kilometer) 

12 transmission line corridor was comprised primarily of prairie grasses of the tallgrass prairie 

13 ecoregion (NPPD, 2008; NGPC, 2005). The remaining 30 percent of the land traversed by the 

14 transmission line corridor was historically comprised of numerous narrow stream valleys with 

15 woody vegetation and shallow intermittent streams with small pockets of wetlands (NPPD, 

16 2008). The western half of the transmission line corridor traverses the Rainwater Basin Plains 

17 and historically contained the largest concentrations of natural wetlands found in Nebraska. 

18 Most of these wetlands have now been drained and converted to cropland and the historic 

19 prairie grass regions in the counties surrounding the transmission line corridor have likewise 

20 been converted to cropland (NGPC, 2005; USGS, 2001). Most of the noted stream valleys were 

21 too steep or too saturated to allow agriculture and still remain vegetated. 

22 Currently, over 97 percent of the land in Nemaha County, Nebraska, is used for agriculture. In 

23 the adjacent Richardson County and Otoe County in Nebraska, and Atchison County in 

24 Missouri, over 90 percent of the land on average is used for agriculture. Very little residential, 

25 commercial, or industrial development has occurred in the counties surrounding the CNS-1 site, 

26 and cumulative impacts from such types of development are considered minor. 

27 Current land use on the Nebraska CNS-1 property outside of the actual power plant facilities 

28 reflects the regional agricultural use. Approximately 900 acres (364 hectares) of the 1,121-acre 

29 (454 hectare) CNS-1 site is used for agriculture (NPPD, 2008). Much of the 90-acres (36 

30 hectares) of land where the CNS-1 facilities have been constructed was cropland prior to 

31 construction of the facility, so disturbance to wildlife habitat had occurred prior to construction of 

32 CNS-1. Construction on some of the CNS-1 facility led to the loss of riparian habitat along the 

33 shoreline, as well as the loss of some wetlands habitat, which may have impacted wildlife 

34 habitat and water quality. NPPD was recently required by the USACE to restore 55 acres (22 

35 hectares) of disturbed wetlands habitat onsite as mitigation for NPPD filling in other disturbed 

36 wetlands for construction of CNS-1 parking facilities. 

37 Surface water drainage patterns have changed on the Nebraska CNS-1 property as a result of 

38 construction of the Federal levee system and from construction of the CNS-1 facility. A dike and 

39 ditch system was created on the Nebraska side of the CNS-1 site during initial construction of 

40 the facilities to protect them from flooding events of the Missouri River (NPPD, 2008). Over 120 

41 acres (49 hectares) of the CNS-1 site on the Nebraska side contain wooded, scrub-shrub, and 

42 emergent wetlands, riparian habitat along the Missouri River, and several small intermittent 

43 streams (NPPD, 2008). Construction of the ditch, dike, and levee systems on the CNS-1 site 

44 have in some cases led to additional flooding on portions of the farm fields, forested areas, and 

45 these wetland areas. The intermittent streams and some surface water drains south into the 

46 adjacent USACE Langdon Bend Wetlands Restoration Project, which may benefit wetlands 

47 restoration on the Corps’ site (NDNR, 2009; USACE, 2004b). 
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Draft NUREG-1437, Supplement 41 4-42 February 2010 

1 Approximately 40 acres (16 hectares) of the 239-acre (97 hectare) CNS-1 property on the 

2 Missouri side are cropland, and the remaining acres are primarily wooded wetlands. Two 

3 transmission line corridors that are not in scope cut through this land and contain emergent 

4 vegetation. The Federal levee is located along the eastern border of this land, and reduces the 

5 threat of flooding of the farm fields beyond the CNS-1 property while retaining more water on 

6 the CNS-1 property. This CNS-1 property is still subject to occasional overbank flooding, as 

7 evidenced by water marks located several feet up on the trunks of trees. Thus, some flooding 

8 events on this land may be similar in degree of inundation to historic flooding events, helping to 

9 maintain this area as a bottomland hardwood, forested wetland. Based upon discussions with 

10 NPPD staff during the environmental site audit, NPPD is currently coordinating with Federal and 

11 State resource agencies to place this Missouri land into a conservation easement, which may 

12 lead to long-term protection of this land from any development as well as removal of the 40 

13 acres of cropland from agricultural production. A pair of bald eagles has been actively nesting 

14 on this property for the past several years (NPPD, 2008). 

15 Several exotic invasive plant species are located along the riverbank or in the vicinity of the 

16 CNS-1 site, and include purple loosestrife (Lythrum salicaria), reed canary grass (Phalaris 

17 arundinacea), and the common reed (Phragmites australis) (Natural Resources Conservation 

18 Services (NRCS), 2007; Nebraska Department of Agriculture (NDA), 2008). The NPPD does not 

19 manage invasive vegetative species on the CNS-1 site; therefore, a potential exists for these 

20 invasive species to increase in population on the CNS-1 site and compete with native vegetation 

21 for resources and degrade areas of terrestrial habitat. Invasive species may also be introduced 

22 on the associated transmission line ROW, with potentially similar impacts. 

23 The land traversed by the transmission line corridor and most of the land in the surrounding 

24 counties has been converted primarily from prairie grasses to cropland. There is currently less 

25 than two percent remaining of the historic prairie grass habitat in Nebraska (NGPC, 2005; 

26 USGS, 2001). Conversion from prairie grassland to cropland will affect wildlife species 

27 composition and behavior, and may have a cumulative adverse impact on nutrient discharges 

28 into the Missouri River and its tributaries. Farming occurs under the transmission lines and 

29 immediately adjacent to the transmission line poles, so little land is lost from agricultural 

30 production. Most of the narrow stream valleys now traversed by the transmission line corridor 

31 remain as vegetated riparian corridors annually maintained by NPPD, primarily as scrub-shrub 

32 wooded areas (NPPD, 2008). ROW maintenance of these riparian corridors has likely had some 

33 minor impacts in the past and is likely to have present and future impacts on these areas from 

34 their conversion from primarily forested riparian communities to scrub-shrub riparian 

35 communities; however, any future maintenance activities are estimated to be minor based on 

36 NPPD’s plan to conduct only necessary clearing to prevent obstruction of the lines. 

37 NPPD has consulted with the USFWS to address the potential risk of bird collisions with NPPD 

38 transmission line NPPD TL3502 which crosses the Platte River near the end of the CNS-1 

39 transmission line corridor, approximately 4 miles (6 kilometers) east of Grand Island, NE. The 

40 Federally-endangered whooping crane (Grus Americana) and interior least tern (Sterna 

41 antillarum athalassos), and the Federally-threatened piping plover (Charadrius melodius) use 

42 the Platte River and associated wetlands around Grand Island for different portions of their 

43 lifecycle (e.g., for migration, resting, feeding, and nesting) and risk collisions with the NPPD 

44 transmission line. The USFWS has indicated that collisions with transmission lines are the main 

45 cause of whooping crane mortality during their migrations (USFWS, 2009a); however, there are 

46 no data to indicate that transmission line NPPD TL3502 has caused any injury or mortality to 

47 whooping cranes, least terns, piping plovers, or to other species of Federally-protected 

48 migratory birds where the transmission line crosses the Platte River. On May 8, 2009, the NPPD 
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February 2010 4-43 Draft NUREG-1437, Supplement 41 

1 informed the USFWS that NPPD had agreed to mark that portion of the NPPD transmission line 

2 that crosses the Platte River with bird flight diverters to increase the visibility of the transmission 

3 line and reduce the risk of collisions (NPPD, 2009). The USFWS replied to NPPD on June 8, 

4 2009, informing them that NPPD had satisfactorily addressed the concerns of the USFWS 

5 regarding bird collisions (USFWS, 2009b). This voluntary mitigation measure by NPPD will help 

6 to reduce current and future potential impacts to whooping cranes, interior lest terns, piping 

7 plovers, and other migratory birds that use the Platte River and associated wetlands of the 

8 Rainwater Basin Wetland Management District (USFWS, 2009c). 

9 The Missouri River ecosystem has been dramatically transformed since the beginning of the 

10 20th century. Historically, the Missouri River was free-flowing with regular overbank flooding 

11 along its entire length, and the channel meandered across the entire floodplain. The 

12 construction of seven dams upriver from CNS-1, bank stabilization, channelization of the river 

13 for improved navigation by barge traffic, and a levee and dike system constructed along most of 

14 the entire length of the floodplain have led to significant changes to the terrestrial habitat of the 

15 ecosystem. There has also been a reduction of the amount and type of deciduous vegetation, 

16 grasslands, and wetlands present within the floodplain. Within the Missouri River itself, there 

17 has also been a reduction in the number of river islands (89 percent), a reduction in the surface 

18 area of these islands (98 percent), and a reduction in the number of sandbars (97 percent) 

19 along the river (NPPD, 2008). With the implementation of Federal aquatic and terrestrial habitat 

20 restoration projects along the entire Missouri River ecosystem and the adjacent USACE 

21 Langdon Bend Wetlands Restoration Project, restoration of Missouri River terrestrial habitat is 

22 beginning to improve ecological conditions from their current state (USACE, 2004b). 

23 Agriculture continues to be the overwhelming dominant land use in the region and with a 

24 declining human population in Nemaha County, additional impacts from new residential, 

25 commercial, or industrial development are not anticipated to increase terrestrial impacts. 

26 Continued runoff of nutrients from agricultural fields and bioaccumulation of pesticides or 

27 herbicides poses a threat to terrestrial and riparian habitats as well as to wildlife species; 

28 however, the Federal wetlands mitigation projects discussed above and in Section 2.2.6 will 

29 help to reduce impacts to both the aquatic and terrestrial environment. 

30 The NRC staff concludes that the minimal terrestrial impacts expected from the continued CNS31 1 operations, including the operation and maintenance of the 145-mile (233-kilometer) long 

32 transmission line corridor, would not contribute to the overall decline in the condition of 

33 terrestrial resources; however, the cumulative impacts on terrestrial resources resulting from all 

34 past, present, and reasonably foreseeable future actions, including non-CNS-1 activities, would 

35 be moderate. 

36 4.11.5 Cumulative Air Quality Impacts 

37 CNS-1 is located in Nemaha County, Nebraska, which belongs to the EPA Region 7. There are 

38 no counties designated by the EPA as nonattainment or maintenance counties for any of the 

39 criteria pollutants in the 50-mile (81-kilometer) vicinity of CNS-1. Douglas County, Nebraska, 

40 located approximately 72 miles (116 kilometers) from CNS-1, is the closest maintenance county 

41 for lead. 

42 As discussed in Air Quality Impacts Section 2.2.2.2, Nebraska Division of Air Quality of the 

43 NDEQ has primary responsibility for regulating air emission sources within the State of 

44 Nebraska, and, with the assistance from Lincoln-Lancaster County Health Department and 

45 Douglas County Health Department, NDEQ conducts ambient air monitoring in the State, 
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Draft NUREG-1437, Supplement 41 4-44 February 2010 

1 operating 28 sites throughout the state with the 34 monitors. The EPA and National 

2 Atmospheric Deposition Program also monitor air quality in Nebraska, which participates in the 

3 EPA’s AIRNow Network which continuously monitors some of the criteria pollutants and informs 

4 the public of the current environmental conditions. 

5 In April 2009, the EPA published the official U.S. inventory of the greenhouse gas (GHG) 

6 emissions that identifies and quantifies the primary anthropogenic sources and sinks of GHG. 

7 The EPA GHG inventory is an essential tool for addressing climate change and participating 

8 with the United Nations Framework Convention on Climate Change to compare the relative 

9 global contribution of different emission sources and GHGs to climate change. The EPA 

10 estimates that energy-related activities in the United States accounts for three-quarters of 

11 human-generated GHG emissions, mostly in the form of carbon dioxide emissions from burning 

12 fossil fuels. More than half of the energy-related emissions come from major stationary sources 

13 like power plants, and approximately one-third comes from transportation. Industrial processes 

14 (production of cement, steel, and aluminum), agriculture, forestry, other land use, and waste 

15 management are also important sources of greenhouse gas emissions in the United States 

16 (EPA, 2009). 

17 Potential cumulative effects of climate change in southeastern Nebraska, where CNS-1 is 

18 located, and local climate, whether or not from natural cycles or anthropogenic activities, could 

19 result in a variety of changes to the air quality of the area. Nebraska is a part of the Great Plains 

20 Region. As projected in the “Global Climate Change Impacts in the United States” report by 

21 USGCRP (2009), the temperatures in southeastern Nebraska are expected to rise 6 °F (14 °C) 

22 by 2080–2099 at minimum and maximum over 10 °F (12°C), causing more frequent extreme 

23 weather events. Increases in average annual temperatures, higher probabilities of extreme heat 

24 events, higher occurrences of extreme rainfall (intense rainfall or drought), and changes in the 

25 wind patterns could affect concentrations of the air pollutants and their long-range transport 

26 because their formation partially depends on the temperature and humidity, and is a result of the 

27 interactions between hourly changes in the physical and dynamic properties of the atmosphere, 

28 atmospheric circulation features, wind, topography, and energy use (IPCC, 2009). 

29 Nebraska is a participant of Western Governors Association (WGA) that encourages the 

30 participating regions to utilize its diverse resources for the production of affordable, sustainable, 

31 and environmentally responsible energy. Nebraska is also a part of WGA Western Regional Air 

32 Partnership which established a multi-state and tribal GHG registry and developed the GHG 

33 emissions inventories. 

34 As discussed in Nonradioactive Waste Management Section 2.1.3, NPPD is committed to the 

35 EPA's Reduce, Reuse, Recycle program at its major and minor facilities, with a growing Green 

36 Team, that focuses on pollution prevention, waste minimization, education and training of the 

37 personnel, and incorporates EPA recommendations on the national implementation of the 

38 climate change energy conservation techniques (EPA, 2009a). 

39 In the 2008 Integrated Resource Plan, NPPD outlined the environmental goals of the company 

40 with emphasis on lowering GHG emissions and obtaining 10 percent of the energy supply from 

41 renewable resources by 2020 (NPPD, 2008). 

42 CNS-1 is exempt from the NDEQ operating permit requirements and holds a Low Emitter Status 

43 from NDEQ, based on the CNS-1 actual quantities of emissions that meet criteria and do not 

44 exceed thresholds, defined in Chapter 5, Title 129 of Nebraska Administrative Code, for the 

45 emissions of particulate matter PM10, carbon monoxide volatile organic compounds, oxides of 
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February 2010 4-45 Draft NUREG-1437, Supplement 41 

1 nitrogen (NOx), SO2 or SO3, or any combination of the two (SOx), single Hazardous Air Pollutant 

2 or HAPs, and lead. As discussed in Air Quality Impacts Section 2.2.2.2, actual total emissions 

3 from all sources at CNS-1 for the period from 2004–2008 were 11.52 tons (10.45 MetricTons) 

4 per year, 10.73 tons (9.73 MetricTons) per year, 13.21 tons (11.98 MetricTons) per year, 11.43 

5 tons (10.37 MetricTons) per year and 9.85 tons (8.94 MetricTons) per year, respectively. 

6 Highest emissions for the period from 2004–2008 were reported in 2006: 0.16 tons (0.15 

7 MetricTons) per year of PM10, 2.41 tons (2.19 MetricTons) per year of CO, 0.22 tons (0.20 

8 MetricTons) per year of VOC, 9.0 tons (8.16 MetricTons) per year of NOx, 1.41 tons (1.28 

9 MetricTons) per year of SOx, and 0.01 tons (0.009 MetricTons) per year of single HAP (NPPD, 

10 2009).

11 NPPD stated in the environmental report (NPPD, 2008) and NRC staff confirmed that no 

12 refurbishment is planned at CNS-1 during the license renewal period. 

13 Based on all of the above, the staff concludes The Staff concludes that combined with the 

14 emissions from other past, present, and reasonably foreseeable future actions, cumulative 

15 hazardous and criteria air pollutants emissions on air quality from CNS-1 related actions would 

16 be SMALL. When considered with respect to an alternative of building a fossil-fuel powered 

17 plant, continuing the operation of the CNS-1 could constitute a net cumulative beneficial 

18 environmental impact in terms of reducing hazardous, criteria, and GHG air emissions; only the 

19 Combined Alternative (described in Chapter 6) would be equivalent to or would contribute less 

20 cumulative emissions than the option of license renewal. 

21 4.11.6 Cumulative Human Health Impacts 

22 NRC and the EPA developed radiological dose limits for protection of the public and workers to 

23 address the cumulative impact of acute and long-term exposure to radiation and radioactive 

24 material. These dose limits are codified in 10 CFR Part 20 and 40 CFR Part 190. This analysis 

25 includes the area within a 50-mile (80-kilometer) radius of the CNS-1 site. The REMP conducted 

26 by NPPD in the vicinity of the CNS-1 site measures the cumulative impact of radiation and 

27 radioactive materials from all sources. 

28 As discussed in Section 4.8.1 of this report, the staff reviewed the radiological environmental 

29 radiation monitoring results for the five-year period from 2003–2007 as part of the cumulative 

30 impacts assessment. Cumulative radiological impacts from all uranium fuel cycle facilities within 

31 a 50-mile (80 km) radius of the CNS-1 site, are limited by the dose limits codified in 10 CFR Part 

32 20 and 40 CFR Part 190. In Section 4.8 of this report, the NRC staff concluded that the impacts 

33 of radiation exposure to the public from the operation of CNS-1 during the renewal term would 

34 be SMALL. NRC and the EPA will regulate any future actions in the vicinity of the CNS-1 site 

35 that could contribute to cumulative radiological impacts; therefore, the NRC concludes that the 

36 cumulative impacts from continued operations of CNS-1 would be SMALL. 

37 4.11.7 Cumulative Socioeconomic Impacts 

38 As discussed in Section 4.4, continued operation of CNS-1 during the license renewal term 

39 would have no impact on socioeconomic conditions in the region beyond those already 

40 experienced. Since NPPD has no plans to hire additional workers during the license renewal 

41 term, overall expenditures and employment levels at CNS-1 would remain relatively constant 

42 with no additional demand for permanent housing and public services. In addition, since 

43 employment levels and tax payments would not change, there would be no population or tax 

44 revenue-related land use impacts. There would also be no disproportionately high and adverse 
Environmental Impacts of Operation 

Draft NUREG-1437, Supplement 41 4-46 February 2010 

1 health and environmental impacts on minority and low-income populations in the region. Based 

2 on this and other information presented in this chapter, there would be no cumulative 

3 socioeconomic impacts from the continued operation of CNS-1 during the license renewal term 

4 beyond what is currently being experienced. 

5 Any ground disturbing activities during the license renewal term, however, could result in the 

6 cumulative loss of historic and archaeological resources. Historic and archaeological resources 

7 are non-renewable; therefore, the loss of archaeological resources is cumulative. The continued 

8 operation of CNS-1 during the license renewal term has the potential to impact unknown historic 

9 and archaeological resources. 

10 As discussed in Section 4.9.6, continued operation of the CNS-1 during the license renewal 

11 term would have a SMALL impact on archaeological resources at the CNS-1 site. NPPD has no 

12 plans to alter the CNS-1 site for license renewal. Any future land disturbing activities would be 

13 carried out under corporate procedures. Should plans change, further consultation would be 

14 initiated by NPPD with the NRC and SHPO. Because impacts to historic and archaeological 

15 resources from the continued operation of CNS-1 would be SMALL, the cumulative 

16 environmental impacts to historic and archaeological resources would be SMALL. 

17 4.11.8 Summary of Cumulative Impacts 

18 We considered the potential impacts resulting from the operation of CNS-1 during the period of 

19 extended operation and other past, present, and future actions in the vicinity of CNS-1. The 

20 preliminary determination is that the potential cumulative impacts resulting from CNS-1 

21 operation during the period of extended operation would be SMALL to MODERATE. 
Environmental Impacts of Operation 

February 2010 4-47 Draft NUREG-1437, Supplement 41 

1 Table 4-10. Summary of Cumulative Impacts on Resources Areas 

Resource Area Impact Discussion 

Water Resources SMALL The total maximum pumping rate at CNS-1 of over 1,500 

gallons per minute (5,678 liters per minute) is less than one 

percent of the average flow in the river. Likewise, the 

influence of offsite pumping should have no measurable effect 

on ground water levels onsite. Because the cumulative effects 

of pumping ground water on river flow and vice versa are 

insignificant, the cumulative impact on water resources in the 

CNS-1 area is SMALL. 

Aquatic Resources LARGE While the level of impact due to direct and indirect impacts of 

CNS-1 on aquatic communities is SMALL, the cumulative 

impact when combined with all other sources has resulted in 

the Missouri River aquatic ecosystem being unstable and 

close to, if not past, the point of reparable change. This 

condition meets NRC’s definition of a LARGE level of impact. 

Terrestrial Resources MODERATE Agriculture continues to be the overwhelming dominant land 

use in the region, and with a declining human population in 

Nemaha County, additional impacts from new residential, 

commercial, or industrial development are not anticipated to 

increase terrestrial impacts. Continued runoff of nutrients from 

agricultural fields and bioaccumulation of pesticides or 

herbicides poses a threat to terrestrial and riparian habitats, 

as well as to wildlife species. However, the Federal wetlands 

mitigation projects discussed above and in Section 2.2.6 will 

help to reduce impacts to both the aquatic and terrestrial 

environment. The NRC staff concludes that the minimal 

terrestrial impacts expected from the continued CNS-1 

operations, including the operation and maintenance of the 

145-mile (233 km) long transmission line corridor, would not 

contribute to the overall decline in the condition of terrestrial 

resources. The cumulative impacts, however, on terrestrial 

resources resulting from all past, present, and reasonably 

foreseeable future actions, including non-CNS-1 activities, 

would be MODERATE. 

Air Quality SMALL NPPD is committed to the EPA's Reduce, Reuse, Recycle 

program at its major and minor facilities, with a growing Green 

Team, that focuses on pollution prevention, waste 

minimization, education and training of the personnel, and 

incorporates EPA recommendations on the national 

implementation of the climate change energy conservation 

techniques. CNS- 1 holds a Low Emitter Status from NDEQ, 

based on the CNS-1 actual quantities of emissions that meet 

criteria and do not exceed thresholds. The NRC staff 

concludes that the minimal air quality impacts expected from 

the continued CNS-1 operation would not destabilize the air 

quality in the vicinity of CNS-1; therefore, the NRC staff 

concludes that the cumulative impacts on the air quality from 

the continued operation of CNS-1 during the license renewal 

period would be SMALL 

Socioeconomics SMALL In Section 4.8 of this report, the NRC staff concluded that the 

impacts of radiation exposure to the public from the operation 

of CNS-1 during the renewal term would be SMALL. NRC and 

the EPA will regulate any future actions in the vicinity of the 

CNS-1 site that could contribute to cumulative radiological 

impacts; therefore, the NRC concludes that the cumulative 

impacts from continued operations of CNS-1 would be SMALL 
Environmental Impacts of Operation 

Draft NUREG-1437, Supplement 41 4-48 February 2010 

Resource Area Impact Discussion 

Human Health SMALL Cumulative radiological impacts from all uranium fuel cycle 

facilities within a 50-mile (80-kilometer) radius of the CNS-1 

site are limited by the dose limits codified in 10 CFR Part 20 

and 40 CFR Part 190. In Section 4.8 of this report, the staff 

concluded that the impacts of radiation exposure to the public 

from the operation of CNS-1 during the renewal term would 

be SMALL. NRC and Nebraska will regulate any future 

actions in the vicinity of the CNS-1 site that could contribute to 

cumulative radiological impacts; therefore, the NRC 

concludes that the cumulative impacts from continued 

operations of CNS-1 would be SMALL 

Archaeological Resources SMALL NPPD has no plans to alter the CNS-1 site for license 

renewal. Any future land disturbing activities would be carried 

out under corporate procedures. Archaeological surveys 

would be conducted in areas identified as archaeologically 

sensitive prior to any ground disturbing activities. Should 

plans change, further consultation would be initiated by NPPD 

with NRC, NSHS, and Missouri SHPO. Because impacts to 

historic and archaeological resources from the continued 

operation of CNS-1 would be SMALL, the cumulative 

environmental impacts to historic and archaeological 

resources would be SMALL. 

Electromagnetic Fields and 

Thermophilic Microbiological 

Organisms 

SMALL The NRC staff concludes that the thermophilic microbiological 

organisms are not likely to present a public health hazard as a 

result of CNS-1 discharges to the Missouri River. The staff 

concludes that the cumulative impacts on public health from 

thermophilic microbiological organisms from continued 

operation of CNS-1 during the license renewal period would 

be SMALL. The NRC staff determined that the CNS-1 

transmission lines are operating within original design 

specifications and meet current NESC clearance standards; 

therefore, the CNS-1 transmission lines do not detectably 

affect the overall potential for electric shock from induced 

currents within the analysis area. With respect to the chronic 

effects of EMFs, although the GEIS finding of “not applicable” 

is appropriate to CNS-1, the transmission lines associated 

with CNS-1 are not likely to detectably contribute to the 

regional exposure of ELF-EMFs; therefore, the NRC staff has 

determined that the cumulative impacts of the continued 

operation of the CNS-1 transmission lines would be SMALL. 

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17 Distribution of Federally-Listed, Threatened, Endangered, Proposed, and Candidate Species. 

18 USFWS, Columbia, Missouri. November 2008. Available URL: 

19 http://www.fws.gov/midwest/endangered/lists/missouri-cty.html (accessed April 17, 2009). 

20 USFWS (United States Fish and Wildlife Service). 2009a. Personal e-mail from Robert Harms, 

21 Fish and Wildlife Biologist, Grand Island Field Office, to R. Bulavinetz, Aquatic Ecologist, 

22 Division of License Renewal, Nuclear Regulatory Commission. Subject: Cooper Nuclear Plant. 

23 March 16, 2009. ADAMS No. ML092110590 

24 United States Fish and Wildlife Service (USFWS). 2009a. Personal e-mail from Robert Harms, 

25 Fish and Wildlife Biologist, Grand Island Field Office, to R. Bulavinetz, Aquatic Ecologist, 

26 Division of License Renewal, Nuclear Regulatory Commission. Subject: Cooper Nuclear Plant. 

27 March 16, 2009. ADAMS Accession No. ML092110590. 

28 United States Fish and Wildlife Service (USFWS). 2009b. Letter from June M. DeWeese, 

29 Nebraska Field Supervisor, U.S. Fish and Wildlife Service, Grand Island, to Joe L. Citta, Jr., 

30 Corporate Environmental Manager, NPPD. Subject: Cooper Nuclear Station. June 8, 2009. 

31 ADAMS Accession No. ML091830055. 

32 United States Fish and Wildlife Service (USFWS). 2009c. Rainwater Basin Wetland 

33 Management District. Available URL: http://www.fws.gov/Refuges/profiles/index.cfm?id=64530

34 (accessed April 29, 2009). 

35 U.S. Census Bureau (USCB). 2003. LandView 6 – Census 2000 Profile of General 

36 Demographic Characteristics DP-1 (100%) and Census Profile of Selected Economic 

37 Characteristics DP-3, Summary of Census Block Groups in a 50-mile radius around the CNS-1 

38 (40.361944 Lat., -95.641389 Long). December 2003. 

39 U.S. Geological Survey (USGS). 2001. Ecoregions of Nebraska and Kansas (color poster with 

40 map, descriptive text, summary tables, and photographs). Available URL: 

41 http://www.epa.gov/wed/pages/ecoregions/ksne_eco.htm (accessed April 29, 2009). 

42 World Health Organization (WHO).2007a. Extremely Low Frequency Fields Environmental 

43 Health Criteria Monograph No.238, World Health Organization, Geneva, Switzerland. 

44 http://www.who.int/pehemf/publications/elf_ehc/en/index.html (accessed August, 2008) 
February 2010 5-1 Draft NUREG-1437, Supplement 41 

1 5.0 ENVIRONMENTAL IMPACTS OF POSTULATED ACCIDENTS 

2 This chapter describes the environmental impacts from postulated accidents that might 

3 occur during the period of extended operation. The term “accident” as defined in the Generic 

4 Environmental Impact Statement (GEIS) (NRC, 1996) refers to any unintentional event 

5 outside the normal plant operational envelope that results in a release or the potential for 

6 release of radioactive materials into the environment. Two classes of postulated accidents 

7 are evaluated under the National Environmental Policy Act (NEPA) in the license renewal 

8 review: design-basis accidents (DBAs) and severe accidents. In the GEIS, the NRC staff 

9 categorized accidents as “design basis” when the plant was designed specifically to 

10 accommodate these accidents or as “severe” for those accidents involving multiple failures 

11 of equipment or function whose likelihood is generally lower than design-basis accidents but 

12 where consequences may be higher” (NRC, 1996). These issues are evaluated in Chapter 5 

13 of GEIS, “Environmental Impacts of Postulated Accidents.” 

14 5.1 DESIGN-BASIS ACCIDENTS 

15 As described in 10 CFR 50.34(b), in order to receive NRC approval for an operating license, 

16 an applicant for an initial operating license must submit a final safety analysis report (FSAR) 

17 as part of its application. The FSAR presents the design criteria and design information for 

18 the proposed reactor and comprehensive data on the proposed site. The FSAR also 

19 discusses various hypothetical accident situations and the safety features that are provided 

20 to prevent and mitigate accidents. The NRC staff reviews the application to determine 

21 whether or not the plant design meets the NRC’s regulations and requirements and 

22 includes, in part, the nuclear plant design and its anticipated response to an accident. 

23 The environmental impacts of postulated accidents were evaluated for the license renewal 

24 period in Chapter 5 of the GEIS. Section 5.5.1 states: 

25 All plants have had a previous evaluation of the environmental impacts of 

26 design-basis accidents. In addition, the licensee will be required to maintain 

27 acceptable design and performance criteria throughout the renewal period. 

28 Therefore, the calculated releases from design-basis accidents would not be 

29 expected to change. Since the consequences of these events are evaluated 

30 for the hypothetical maximally exposed individual at the time of licensing, 

31 changes in the plant environment will not affect these evaluations. Therefore, 

32 the staff concludes that the environmental impacts of design-basis accidents 

33 are of small significance for all plants. Because the environmental impacts of 

34 design basis accidents are of small significance and because additional 

35 measures to reduce such impacts would be costly, the staff concludes that no 

36 mitigation measures beyond those implemented during the current term 

37 license would be warranted. This is a Category 1 issue. 

38 No new and significant information related to DBAs was identified during the review of 

39 Nebraska Public Power District’s (NPPD’s) environmental report (ER), site audit, scoping 

40 process, or evaluation of other available information. Therefore, there are no impacts related 

41 to these issues beyond those discussed in the GEIS. 
Environmental Impacts of Postulated Accidents 

Draft NUREG-1437, Supplement 41 5-2 February 2010 

1 5.2 SEVERE ACCIDENTS 

2 Severe nuclear accidents are those that are more severe than DBAs because they could 

3 result in substantial damage to the reactor core, whether or not there are serious offsite 

4 consequences. In the GEIS, the staff assessed the impacts of severe accidents during the 

5 license renewal period, using the results of existing analyses and information from various 

6 sites to predict the environmental impacts of severe accidents for plants during the renewal 

7 period. 

8 Severe accidents initiated by external phenomena such as tornadoes, floods, earthquakes, 

9 fires, and sabotage have not traditionally been discussed in quantitative terms in the final 

10 environmental impact statements and were not specifically considered for the Cooper 

11 Nuclear Station, Unit 1 (CNS-1) site in the GEIS (NRC, 1996). The GEIS, however, did 

12 evaluate existing impact assessments performed by the NRC staff and by the industry at 44 

13 nuclear plants in the United States and segregated all sites into six general categories and 

14 then estimated that the risk consequences calculated in existing analyses bound the risks 

15 for all other plants within each category. The GEIS further concluded that the risk from 

16 beyond design-basis earthquakes at existing nuclear power plants is designated as SMALL. 

17 The Commission believes that NEPA does not require the NRC to consider the 

18 environmental consequences of hypothetical terrorist attacks on NRC-licensed 

19 facilities. However, the NRC staff's GEIS for license renewal contains a discretionary 

20 analysis of terrorist acts in connection with license renewal. The conclusion in the GEIS is 

21 that the core damage and radiological release from such acts would be no worse than the 

22 damage and release to be expected from internally initiated events. 

23 In the GEIS, the NRC staff concludes that the risk from sabotage and beyond design-basis 

24 earthquakes at existing nuclear power plants is designated as SMALL, and additionally, that 

25 the risks from other external events are adequately addressed by a generic consideration of 

26 internally initiated severe accidents (NRC, 1996). 

27 Based on information in the GEIS, the staff found that: 

28 The generic analysis...applies to all plants and that the probability-weighted 

29 consequences of atmospheric releases, fallout onto open bodies of water, 

30 releases to ground water, and societal and economic impacts of severe 

31 accidents are of small significance for all plants. However, not all plants have 

32 performed a site-specific analysis of measures that could mitigate severe 

33 accidents. Consequently, severe accidents are a Category 2 issue for plants 

34 that have not performed a site-specific consideration of severe accident 

35 mitigation and submitted that analysis for Commission review. 

36 The staff identified no new and significant information related to postulated accidents during 

37 the review of NPPD’s environmental report, the site audit, the scoping process, or evaluation 

38 of other available information. Therefore, there are no impacts related to postulated 

39 accidents beyond those discussed in the GEIS. In accordance with 10 CFR 

40 51.53(c)(3)(ii)(L), however, the NRC staff has reviewed severe accident mitigation 

41 alternatives (SAMAs) for CNS-1. Review results are discussed in Section 5.3. 
Environmental Impacts of Postulated Accidents 

February 2010 5-3 Draft NUREG-1437, Supplement 41 

1 5.3 SEVERE ACCIDENT MITIGATION ALTERNATIVES 

2 Regulations under Section 51.53(c)(3)(ii)(L) of 10 CFR requires an ER to contain an analysis 

3 of alternatives to mitigate severe accidents if the staff has not previously evaluated SAMAs 

4 for the applicant's plant in an environmental impact statement (EIS), related supplement, or 

5 in an environmental assessment. The Commission’s reconsideration of the issue of severe 

6 accident mitigation for license renewal is based on the Commission’s NEPA regulations that 

7 require a consideration of mitigation alternatives in its environmental impact statements 

8 (EISs) and supplements to EISs, as well as a previous court decision that required a review 

9 of sever mitigation alternatives at the operating license stage. 

10 5.3.1 Introduction 

11 This section presents a summary of the SAMA evaluation for CNS-1 conducted by NPPD 

12 Energy Company, LLC (NPPD) and the staff's review of that evaluation. The NRC staff 

13 performed its review with contract assistance from Pacific Northwest National Laboratory. 

14 Subsequent to the ER, NPPD discovered a problem with the process they used to 

15 numerically average the site-specific meteorological data. NPPD performed a sensitivity 

16 analysis of the population dose risk and offsite economic cost risk using corrected 

17 meteorological data, and found that the population dose and offsite economic cost values for 

18 each of the release categories would be slightly less than reported in the ER, and that the 

19 conclusions of the SAMA remain valid (NPPD, 2009b). The NRC staff’s review is available in 

20 Appendix F; the SAMA evaluation is available in NPPD’s ER and the supplement submitted 

21 in December 2009. 

22 The SAMA evaluation for CNS-1 was conducted with a four-step approach. In the first step, 

23 NPPD quantified the level of risk associated with potential reactor accidents using the plant 

24 specific probabilistic risk assessment (PRA) and other risk models. 

25 In the second step, NPPD examined the major risk contributors and identified possible ways 

26 (SAMAs) of reducing that risk. Common ways of reducing risk are changes to components, 

27 systems, procedures, and training. NPPD identified 33 potential SAMAs for CNS-1. NPPD 

28 performed an initial screening to determine if any SAMAs could be eliminated because they 

29 are not applicable to CNS-1 due to design differences, or have estimated implementation 

30 costs that would exceed the dollar-value associated with completely eliminating all severe 

31 accident risk at CNS-1. No SAMAs were eliminated based on this screening, leaving all 33 

32 for further evaluation. 

33 In the third step, NPPD estimated the benefits and the costs associated with each of the 

34 SAMAs. Estimates were made of how much each SAMA could reduce risk. Those estimates 

35 were developed in terms of dollars in accordance with NRC guidance for performing 

36 regulatory analyses (NRC, 1997). The cost of implementing the proposed SAMAs was also 

37 estimated. 

38 Finally, in the fourth step, the costs and benefits of each of the remaining SAMAs were 

39 compared to determine whether the SAMA was cost beneficial, meaning the benefits of the 

40 SAMA were greater than the cost (a positive cost benefit). NPPD concluded in its ER that 

41 several of the SAMAs evaluated are potentially cost-beneficial (NPPD, 2008). 

42 The potentially cost-beneficial SAMAs do not relate to adequately managing the effects of 

43 aging during the period of extended operation (e.g., none of the potentially cost-beneficial 
Environmental Impacts of Postulated Accidents 

Draft NUREG-1437, Supplement 41 5-4 February 2010 

1 SAMAs would reduce the frequency or risk associated with aging-related failures). 

2 Therefore, they need not be implemented as part of license renewal pursuant to 10 CFR 

3 Part 54. NPPD's SAMA analysis and the NRC staff’s review are discussed in more detail 

4 below. 

5 5.3.2 Estimate of Risk 

6 NPPD submitted an assessment of SAMAs for CNS-1 as part of the ER. This assessment 

7 was based on the most recent CNS-1 probabilistic safety assessment (PSA) available at 

8 that time, a plant-specific offsite consequence analysis performed using the MELCOR 

9 Accident Consequence Code System 2 (MACCS2) computer program, and insights from the 

10 CNS-1 Individual Plant Examination (IPE) (NPPD, 1993) and Individual Plant Examination of 

11 External Events (IPEEE) (NPPD, 1996). As mentioned above, NPPD discovered an error in 

12 the method used to average their wind data. NPPD performed a sensitivity analysis using 

13 the corrected meteorological data. Their analysis found that the error was conservative 

14 relative to the average population dose and economic cost, and that no SAMAs were 

15 inappropriately excluded from consideration in the LRA as a result of the error in wind 

16 direction. NPPD submitted their analysis and changes to the LRA in a letter dated 

17 December 7, 2009 (NPPD, 2009b). 

The CNS-1 core damage frequency (CDF) is approximately 9.3 x 10-6 18 per year for internal 

19 events as determined from the quantification of the Level 1 PSA model. When determined 

20 from the sum of the containment event tree sequences, or Level 2 PSA model, the release 

frequency is approximately 1.2 x 10-5 21 per year. The latter value was used as the baseline 

22 CDF in the SAMA evaluations. The CDF value is based on the risk assessment for 

23 internally-initiated events. NPPD did not include the contributions from external events within 

24 the CNS-1 risk estimates; however, it did account for the potential risk reduction benefits 

25 associated with external events by increasing the estimated benefits for internal events by a 

26 factor of 3. The breakdown of CDF by initiating event is provided in 1. 

27 Table 5-1. Cooper Nuclear Station, Unit 1, Core Damage Frequency for Internal Events 

Initiating Event CDF 

(per year) 

% Contribution to 

CDF 

Transients 3.0 × 10–6 32 

Loss of DC Power 2.1 × 10–6 22 

Loss of Coolant Accidents (LOCA) 1.4 × 10–6 15 

Loss of Feedwater 1.0 × 10–6 11 

Loss of Offsite Power 6.5 × 10–7 7 

Loss of Service Water 6.0 × 10–7 7 

Loss of AC Buses 2.6 × 10–7 3 

Internal Flood 2.6 × 10–7 3 

Interfacing System LOCA 5.1 × 10–8 <1 

Total CDF (Internal Events) 9.3 × 10–6 100 

28 As shown in this table, events initiated by transients, loss of DC power, LOCA, and loss of 

29 feedwater are the dominant contributors to the CDF. 

30 NPPD estimated the dose to the population within 50 miles (80 km) of the CNS-1 site to be 

31 approximately 0.021 person-sievert (person-Sv) (2.1 person-rem) per year. The breakdown 

32 of the total population dose by containment release mode is summarized in Table 5-2. 
Environmental Impacts of Postulated Accidents 

February 2010 5-5 Draft NUREG-1437, Supplement 41 

1 Containment failures within the early time frame (less than 3.7 hours following event 

2 initiation) dominate the population dose risk at CNS-1, with failures in the intermediate time 

3 frame (3.7 to 24 hours following event initiation) contributing most of the remaining 

4 population dose. 

5 Table 5-2. Breakdown of Population Dose by Containment Release Mode 

Containment Release Mode Population Dose 

(Person-Rem1 Per Year) % Contribution 

Early Containment Failure 1.67 78 

Intermediate Containment Failure 0.47 22 

Late Containment Failure <0.1 <1 

Intact Containment Negligible negligible 

Total 2.14 100 

1

One person-rem = 0.01 person-Sv 

6 The NRC staff has reviewed NPPD's data and evaluation methods and concludes that the 

7 quality of the risk analyses is adequate to support an assessment of the risk reduction 

8 potential for candidate SAMAs. Accordingly, the staff based its assessment of offsite risk on 

9 the CDFs and offsite doses reported by NPPD in their December 2009 letter (NPPD, 

10 2009b). 

11 5.3.3 Potential Plant Improvements 

12 Once the dominant contributors to plant risk were identified, NPPD searched for ways to 

13 reduce that risk. In identifying and evaluating potential SAMAs, NPPD considered insights 

14 from the plant-specific PSA, and SAMA analyses performed for other operating plants that 

15 have submitted license renewal applications. NPPD identified 244 potential risk-reducing 

16 improvements (SAMAs) to plant components, systems, procedures and training. 

17 NPPD removed all but 80 of the SAMAs from further consideration because they are not 

18 applicable at CNS-1 due to design differences, have already been implemented at CNS-1, 

19 or are similar in nature and could be combined with another SAMA candidate. A detailed 

20 cost-benefit analysis was performed for each of the remaining SAMAs. 

21 The staff concludes that NPPD used a systematic and comprehensive process for 

22 identifying potential plant improvements for CNS-1, and that the set of potential plant 

23 improvements identified by NPPD is reasonably comprehensive and, therefore, acceptable. 

24 5.3.4 Evaluation of Risk Reduction and Costs of Improvements 

25 NPPD evaluated the risk-reduction potential of the remaining 80 SAMAs. The majority of the 

26 SAMA evaluations were performed in a bounding fashion in that the SAMA was assumed to 

27 completely eliminate the risk associated with the proposed enhancement. 

28 NPPD estimated the costs of implementing the candidate SAMAs through the application of 

29 engineering judgment and use of other licensee’s estimates for similar improvements. The 

30 cost estimates conservatively did not include the cost of replacement power during extended 

31 outages required to implement the modifications, nor did they include maintenance and 

32 surveillance costs of the installed equipment. 
Environmental Impacts of Postulated Accidents 

Draft NUREG-1437, Supplement 41 5-6 February 2010 

1 The staff reviewed NPPD’s bases for calculating the risk reduction for the various plant 

2 improvements and concludes that the rationale and assumptions for estimating risk 

3 reduction are reasonable and generally conservative (i.e., the estimated risk reduction is 

4 higher than what would actually be realized). Accordingly, the staff based its estimates of 

5 averted risk for the various SAMAs on NPPD’s risk reduction estimates. 

6 The staff reviewed the bases for the applicant’s cost estimates. For certain improvements, 

7 the staff also compared the cost estimates to estimates developed elsewhere for similar 

8 improvements, including estimates developed as part of other licensee’s analyses of SAMAs 

9 for operating reactors and advanced light-water reactors. The staff found the cost estimates 

10 to be reasonable, and generally consistent with estimates provided in support of other 

11 plants’ analyses. 

12 The staff concludes that the risk reduction and the cost estimates provided by NPPD are 

13 sufficient and appropriate for use in the SAMA evaluation. 

14 5.3.5 Cost-Benefit Comparison 

15 The cost-benefit analysis performed by NPPD was based primarily on NUREG/BR-0184 

16 (NRC, 1997) and was executed consistent with this guidance. NUREG/BR-0058 has 

17 recently been revised to reflect the agency’s revised policy on discount rates. Revision 4 of 

18 NUREG/BR-0058 states that two sets of estimates should be developed – one at 3 percent 

19 and the other at 7 percent (NRC, 2004). NPPD provided both sets of estimates 

20 (NPPD, 2008). 

21 NPPD identified eight potentially cost-beneficial SAMAs in the baseline analysis contained in 

22 the ER. The potentially cost-beneficial SAMAs are: 

23 ● SAMA 25 – Develop procedures to allow bypass of the reactor core 

24 isolation cooling (RCIC) turbine exhaust pressure trip, extending the 

25 time available for RCIC operation. 

26 ● SAMA 30 – Revise procedures to allow manual alignment of the fire 

27 water system to the residual heat removal (RHR) heat exchangers, 

28 providing improved ability to cool the RHR heat exchangers in a loss of 

29 service water (SW). 

30 ● SAMA 33 – Provide for the ability to establish an emergency connection 

31 of existing or new water sources to feedwater and condensate systems, 

32 increasing availability of feedwater. 

33 ● SAMA 40 – Revise procedures to provide additional space cooling to 

34 the emergency diesel generator (EDG) room via the use of portable 

35 equipment, increasing availability of the EDG. 

36 ● SAMA 45 – Provide an alternate means of supplying the instrument air 

37 header, increasing availability of instrument air. 
Environmental Impacts of Postulated Accidents 

February 2010 5-7 Draft NUREG-1437, Supplement 41 

1 ● SAMA 68 – Revise procedures to allow the ability to cross-connect the 

2 circulating water pumps and the service water going to the turbine 

3 equipment cooling (TEC) heat exchangers, which allow continued use 

4 of the power conversion system after service water is lost. 

5 ● SAMA 78 – Improve training on alternate injection via the fire water 

6 system, increasing the availability of alternate injection. 

7 ● SAMA 79 – Revise procedures to allow use of the residual heat removal 

8 service water (RHRSW) system without a service water booster pump, 

9 increasing availability of the RHRSW system. 

10 NPPD performed additional analyses to evaluate the impact of parameter choices and 

11 uncertainties on the results of the SAMA assessment (NPPD, 2008). If the benefits are 

12 increased by an additional factor of 3 to account for uncertainties, three additional SAMA 

13 candidates were determined to be potentially cost-beneficial: 

14 ● SAMA 14 – Provide a portable generator to supply DC power to 

15 individual panels during a station blackout (SBO), increasing the time 

16 available for AC power recovery. 

17 ● SAMA 64 – Revise procedures to allow use of a fire pumper truck to 

18 pressurize the fire water system, increasing availability of the fire water 

19 system. 

20 ● SAMA 75 – Implement Generation Risk Assessment (trip and shutdown 

21 risk modeling) into plant activities, decreasing the probability of 

22 trips/shutdown. 

23 NPPD indicated that detailed engineering project cost-benefit analyses have been initiated 

24 for the 11 potentially cost-beneficial SAMAs (NPPD 2008, 2009). 

25 NRC staff reviewed NPPD’s re-analysis as submitted by NPPD and agrees that the error 

26 was conservative relative to the average population dose and offsite economic cost and that 

27 no SAMAs were inappropriately excluded from consideration in the LRA as a result of the 

28 error. 

29 Based on the staff’s review and the supplemental information provided by NPPD, the NRC 

30 staff concludes that, with the exception of the potentially cost-beneficial SAMAs discussed 

31 above, the costs of the SAMAs evaluated would be higher than the associated benefits. 

32 5.3.6 Conclusions 

33 The staff reviewed NPPD’s analysis and concluded that the methods used and the 

34 implementation of those methods were sound. The treatment of SAMA benefits and costs 

35 support the general conclusion that the SAMA evaluations performed by NPPD are 

36 reasonable and sufficient for the license renewal submittal. 

37 Based on its review of the SAMA analysis, the staff concurs with NPPD’s identification of 

38 areas in which risk can be further reduced in a cost-beneficial manner through the 

39 implementation of all, or a subset of potentially cost-beneficial SAMAs. Given the potential 
Environmental Impacts of Postulated Accidents 

Draft NUREG-1437, Supplement 41 5-8 February 2010 

1 for cost-beneficial risk reduction, the staff considers that further consideration of these 

2 SAMAs by NPPD is warranted. However, none of the potentially cost-beneficial SAMAs 

3 relate to adequately managing the effects of aging during the period of extended operation 

4 e.g., none of the potentially cost-beneficial SAMAs would reduce the frequency or risk 

5 associated with aging-related failures). Therefore, they need not be implemented as part of 

6 the license renewal pursuant to 10 CFR Part 54. 

7 5.4 REFERENCES 

8 10 CFR Part 50. Code of Federal Regulations, Title 10, Energy, Part 50, “Domestic 

9 Licensing of Production and Utilization Facilities.” 

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

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

12 10 CFR Part 54. Code of Federal Regulations, Title 10, Energy, Part 54, “Requirements for 

13 Renewal of Operating Licenses for Nuclear Power Plants.” 

14 10 CFR Part 100. Code of Federal Regulations, Title 10, Energy, Part 100, “Reactor Site 

15 Criteria.” 

16 Nebraska Public Power District (NPPD). 1993. “Generic Letter 88-20, Individual Plant 

17 Examination for Severe Accident Vulnerabilities – 10 CFR 50.54(f), IPE Report Submittal, 

18 Cooper Nuclear Station, Docket No. 50-298, DPR-46,” March 1993. ADAMS Accession Nos. 

19 ML073600192 (Volume 1) and ML073600193 (Volume 2). 

20 Nebraska Public Power District (NPPD). 1996. “Individual Plant Examination for External 

21 Events Report – 10 CFR 50.54(f), Cooper Nuclear Station, NRC Docket No. 50-298, License 

22 No. DPR-46,” October 1996. ADAMS Accession No. ML073580487. 

23 Nebraska Public Power District (NPPD).2008. Cooper Nuclear Station --- License Renewal 

24 Application, Appendix E: Applicant’s Environmental Report, Operating License Renewal 

25 Stage. Columbus, Nebraska, September 24, 2008 ADAMS Accession Nos.ML083030246 

26 (main report) and ML083030252 (attachments). 

27 Nebraska Public Power District (NPPD).2009. Letter from Stewart B. Minahan, NPPD to 

28 NRC Document Control Desk. Subject: Response to Request for Additional Information for 

29 License Renewal Application – Severe Accident Mitigation Alternatives, Cooper Nuclear 

30 Station, Docket No. 50-298, DPR-46. July 1, 2009. ADAMS Accession No. ML0918803193. 

31 Nebraska Public Power District (NPPD). 2009b. Letter from Stewart B. Minahan, NPPD to 

32 NRC Document Control Desk. Subject: SAMA Meteorological Anomaly Related to the 

33 Cooper Nuclear Station License Renewal Application, Cooper Nuclear Station, Docket No. 

34 50-298, DPR-46. December 7, 2009. ADAMS Accession No. ML093490997 

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

36 Statement for License Renewal of Nuclear Plants. NUREG-1437, Vols. 1 and 2, 

37 Washington, D.C. ADAMS Accession Nos. ML040690705 and ML040690738 

38 U.S. Nuclear Regulatory Commission (NRC). 1997. Regulatory Analysis Technical 

39 Evaluation Handbook. NUREG/BR-0184, Washington, D.C. 

40 U.S. Nuclear Regulatory Commission (NRC). 2004. Regulatory Analysis Guidelines of the 

41 U.S. Nuclear Regulatory Commission. NUREG/BR-0058, Rev. 4, Washington, D.C.
February 2010 6-1 Draft NUREG-1437, Supplement 41 

1 6.0 ENVIRONMENTAL IMPACTS OF THE URANIUM FUEL CYCLE, 

2 AND SOLID WASTE MANAGEMENT, AND GREENHOUSE GASEOUS 

3 EMISSIONS 

4 6.1 THE URANIUM FUEL CYCLE 

5 This section addresses issues related to the uranium fuel cycle and solid waste management 

6 during the period of extended operation. The uranium cycle includes uranium mining and 

7 milling, the production of uranium hexafluoride, isotopic enrichment, fuel fabrication, 

8 reprocessing of irradiated fuel, transportation of radioactive materials, and management of low9 level wastes and high-level wastes related to uranium fuel cycle activities. The Generic 

10 Environmental Impact Statement (GEIS) (NRC 1996, 1999) details the potential generic impacts 

11 of the radiological and nonradiological environmental impacts of the uranium fuel cycle including 

12 transportation of nuclear fuel and wastes. The GEIS is based, in part, on the generic impacts 

13 provided in Table S-3, “Table of Uranium Fuel Cycle Environmental Data,” in Title 10 of the 

14 Code of Federal Regulations (CFR), Section 51.51(a), and in Table S-4, “Environmental Impact 

15 of Transportation of Fuel and Waste to and from One Light-Water-Cooled Nuclear Power 

16 Reactor,” in 10 CFR 51.52(b). The GEIS also addresses the impacts from radon-222 and 

17 technetium-99. 

18 For these Category 1 issues, the GEIS concludes that the impacts are designated as SMALL, 

19 except for the collective offsite radiological impacts from the fuel cycle and from high-level waste 

20 and spent fuel disposal, where no significance level was assigned to these two impacts. For the 

21 collective offsite radiological impacts, the Commission concludes that these impacts are 

22 acceptable in that these impacts would not be sufficiently large to require the NEPA conclusion, 

23 for any plant, that the option of extended operation under 10 CFR Part 54 should be eliminated. 

24 The staff of the U.S. Nuclear Regulatory Commission (NRC) did not identify any new and 

25 significant information related to the uranium fuel cycle during the review of Nebraska Public 

26 Power District’s (NPPD) environmental report (ER) (NPPD, 2008), the site audit, and the 

27 scoping process. Therefore, there are no impacts related to these issues beyond those 

28 discussed in the GEIS. 

29 Nine generic issues are related to the fuel cycle and solid waste management. These are shown 

30 in Table 6-1. There are no site-specific issues. 
Environmental Impacts of the Uranium Fuel Cycle 

Draft NUREG-1437, Supplement 41 6-2 February 2010 

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

Issues GEIS Section Category 

Offsite radiological impacts (individual effects from other than the 

disposal of spent fuel and high-level waste) 

6.1, 6.2.1, 6.2.2.1, 

6.2.2.3, 6.2.3, 6.2.4, 

6.6 

1 

Offsite radiological impacts (collective effects) 6.1, 6.2.2.1, 6.2.3, 

6.2.4, 6.6 

1 

Offsite radiological impacts (spent fuel and high-level waste 

disposal) 

6.1, 6.2.2.1, 6.2.3, 

6.2.4, 6.6 

1 

Nonradiological impacts of the uranium fuel cycle 6.1, 6.2.2.6, 6.2.2.7, 

6.2.2.8, 6.2.2.9, 6.2.3, 

6.2.4, 6.6 

1 

Low-level waste storage and disposal 6.1, 6.2.2.2, 6.4.2, 

6.4.3, 6.4.3.1, 6.4.3.2, 

6.4.3.3, 6.4.4, 6.4.4.1, 

6.4.4.2, 6.4.4.3, 

6.4.4.4, 6.4.4.5, 

6.4.4.5.1, 6.4.4.5.2, 

6.4.4.5.3, 6.4.4.5.4, 

6.4.4.6, 6.6 

1 

Mixed waste storage and disposal 6.4.5.1, 6.4.5.2, 

6.4.5.3, 6.4.5.4, 

6.4.5.5, 6.4.5.6, 

6.4.5.6.1, 6.4.5.6.2, 

6.4.5.6.3, 6.4.5.6.4, 

6.6 

1 

Onsite spent fuel 6.1, 6.4.6, 6.4.6.1, 

6.4.6.2, 6.4.6.3, 

6.4.6.4, 6.4.6.5, 

6.4.6.6, 6.4.6.7, 6.6 

1 

Nonradiological waste 6.1, 6.5, 6.5.1, 6.5.2, 

6.5.3, 6.6 

1 

Transportation 6.1, 6.3.1, 6.3.2.3, 

6.3.3, 6.3.4, 6.6, 

Addendum 1 

1 

2 6.2 GREENHOUSE GAS EMISSIONS 

3 This section provides a discussion of potential impacts from greenhouse gases (GHGs) emitted 

4 from the nuclear fuel cycle. The GEIS does not directly address these emissions, and its 

5 discussion is limited to an inference that substantial carbon dioxide (CO2) emissions may occur 

6 if coal- or oil-fired alternatives to license renewal are implemented. 

7 6.2.1 Existing Studies 

8 Since the development of the GEIS, the relative volumes of GHGs emitted by nuclear and other 

9 electricity generating methods have been widely studied. However, estimates and projections of 
Environmental Impacts of the Uranium Fuel Cycle 

February 2010 6-3 Draft NUREG-1437, Supplement 41 

1 the carbon footprint of the nuclear power lifecycle vary depending on the type of study 

2 conducted. Additionally, considerable debate also exists among researchers regarding the 

3 relative impacts of nuclear and other forms of electricity generation on GHG emissions. Existing 

4 studies on GHG emissions from nuclear power plants generally take two different forms: 

5 (1) Qualitative discussions of the potential to use nuclear power to reduce GHG emissions 

6 and mitigate global warming; and 

7 (2) Technical analyses and quantitative estimates of the actual amount of GHGs generated 

8 by the nuclear fuel cycle or entire nuclear power plant life cycle and comparisons to the 

9 operational or life cycle emissions from other energy generation alternatives. 

10 6.2.1.1 Qualitative Studies 

11 The qualitative studies consist primarily of broad, large-scale public policy or investment 

12 evaluations of whether an expansion of nuclear power is likely to be a technically, economically, 

13 and/or politically feasible means of achieving global GHG reductions. Studies identified by the 

14 NRC staff during the subsequent literature search include: 

15 ● Evaluations to determine whether investments in nuclear power in 

16 developing countries should be accepted as a flexibility mechanism to 

17 assist industrialized nations in achieving their GHG reduction goals under 

18 the Kyoto Protocols (Schneider, 2000; IAEA, 2000; NEA, 2002; 

19 NIRS/WISE, 2005). Ultimately, the parties to the Kyoto Protocol did not 

20 approve nuclear power as a component under the Clean Development 

21 Mechanism (CDM) due to safety and waste disposal concerns (NEA, 2002). 

22 ● Analyses developed to assist governments, including the United States, in 

23 making long-term investment and public policy decisions in nuclear power 

24 (Keepin, 1988; Hagen et al., 2001; MIT, 2003). 

25 Although the qualitative studies sometimes reference and critique the existing quantitative 

26 estimates of GHGs produced by the nuclear fuel cycle or life cycle, their conclusions generally 

27 rely heavily on discussions of other aspects of nuclear policy decisions and investment such as 

28 safety, cost, waste generation, and political acceptability. Therefore, these studies are typically 

29 not directly applicable to an evaluation of GHG emissions associated with the proposed license 

30 renewal for a given nuclear power plant. 

31 6.2.1.2 Quantitative 

32 A large number of technical studies, including calculations and estimates of the amount of 

33 GHGs emitted by nuclear and other power generation options, are available in the literature and 

34 were useful to the NRC staff’s efforts in addressing relative GHG emission levels. Examples of 

35 these studies include – but are not limited to – Mortimer (1990), Andseta et al. (1998), Spadaro 

36 (2000), Storm van Leeuwen and Smith (2005), Fritsche (2006), Parliamentary Office of Science 

37 and Technology (POST) (2006), Atomic Energy Authority (AEA) (2006), Weisser (2006), 

38 Fthenakis and Kim (2007), and Dones (2007). 
Environmental Impacts of the Uranium Fuel Cycle 

Draft NUREG-1437, Supplement 41 6-4 February 2010 

1 Comparing these studies and others like them is difficult because the assumptions and 

2 components of the lifecycles the authors evaluate vary widely. Examples of areas in which 

3 differing assumptions make comparing the studies difficult include: 

4 ● Energy sources that may be used to mine uranium deposits in the future; 

5 ● Reprocessing or disposal of spent nuclear fuel; 

6 ● Current and potential future processes to enrich uranium and the energy 

7 sources that will power them; 

8 ● Estimated grades and quantities of recoverable uranium resources; 

9 ● Estimated grades and quantities of recoverable fossil fuel resources; 

10 ● Estimated GHG emissions other than CO2, including the conversion to CO2

11 equivalents per unit of electric energy produced; 

12 ● Performance of future fossil fuel power systems; 

13 ● Projected capacity factors for alternatives means of generation; and 

14 ● Current and potential future reactor technologies. 

15 In addition, studies may vary with respect to whether all or parts of a power plant’s lifecycle are 

16 analyzed, i.e., a full lifecycle analysis will typically address plant construction, operations, 

17 resource extraction (for fuel and construction materials), and decommissioning, whereas, a 

18 partial lifecycle analysis primarily focus on operational differences. 

19 In the case of license renewal a GHG analysis for that portion of the plant’s lifecycle (operation 

20 for an additional 20 years) would not involve GHG emissions associated with construction 

21 because construction activities have already been completed at the time of relicensing. In 

22 addition, the proposed action of license renewal would also not involve additional GHG 

23 emissions associated with facility decommissioning, because that decommissioning must occur 

24 whether the facility is relicensed or not. However, in some of the aforementioned studies, the 

25 specific contribution of GHG emissions from construction, decommissioning, or other portions of 

26 a plant’s lifecycle cannot be clearly separated from one another. In such cases, an analysis of 

27 GHG emissions would overestimate the GHG emissions attributed to a specific portion of a 

28 plant’s lifecycle. Nonetheless, these studies provide some meaningful information with respect 

29 to the relative magnitude of the emissions among nuclear power plants and other forms of 

30 electric generation, as discussed in the following sections. 

31 In Tables 6-2, 6-3, and 6-4 the NRC staff presents the results of the aforementioned quantitative 

32 studies to provide a weight-of-evidence evaluation of the relative GHG emissions that may 

33 result from the proposed license renewal as compared to the potential alternative use of coal34 fired, natural gas-fired, and renewable generation. Most studies from Mortimer (1990) onward 

35 suggest that uranium ore grades and uranium enrichment processes are leading determinants 

36 in the ultimate GHG emissions attributable to nuclear power generation. These studies indicate 

37 that the relatively lower order of magnitude of GHG emissions from nuclear power when 

38 compared to fossil-fueled alternatives (especially natural gas) could potentially disappear if 
Environmental Impacts of the Uranium Fuel Cycle 

February 2010 6-5 Draft NUREG-1437, Supplement 41 

1 available uranium ore grades drop sufficiently while enrichment processes continued to rely on 

2 the same technologies. 

3 6.2.1.3 Summary of Nuclear Greenhouse Gas Emissions Compared to Coal 

4 Considering that coal fuels the largest share of electricity generation in the United States and 

5 that its burning results in the largest emissions of GHGs for any of the likely alternatives to 

6 nuclear power generation, including Cooper Nuclear Station, Unit 1 (CNS-1), most of the 

7 available quantitative studies focused on comparisons of the relative GHG emissions of nuclear 

8 to coal-fired generation. The quantitative estimates of the GHG emissions associated with the 

9 nuclear fuel cycle (and, in some cases, the nuclear lifecycle), as compared to an equivalent 

10 coal-fired plant, are presented in Table 6-2. The following chart does not include all existing 

11 studies, but provides an illustrative range of estimates developed by various sources. 

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

Source GHG Emission Results 

Nuclear—230,000 tons CO2 

Coal—5,912,000 tons CO2

Mortimer (1990) 

Note: Future GHG emissions from nuclear to increase because of declining ore 

grade. 

Andseta et al. (1998) Nuclear energy produces 1.4 percent of the GHG emissions compared to coal. 

Note: Future reprocessing and use of nuclear-generated electrical power in the 

mining and enrichment steps are likely to change the projections of earlier 

authors, such as Mortimer (1990). 

Spadaro (2000) Nuclear—2.5 to 5.7 g Ceq/kWh 

Coal—264 to 357 g Ceq/kWh 

Storm van Leeuwen 

and Smith (2005) 

Authors did not evaluate nuclear versus coal. 

Fritsche (2006) (Values Nuclear—33 g Ceq/kWh 

estimated from graph 

in Figure 4) Coal—950 g Ceq/kWh 

Nuclear—5 g Ceq/kWh 

Coal—>1000 g Ceq/kWh 

POST (2006) (Nuclear 

calculations from AEA, 

2006) Note: Decrease of uranium ore grade to 0.03 percent would raise nuclear to 6.8 g 

Ceq /kWh. Future improved technology and carbon capture and storage could 

reduce coal-fired GHG emissions by 90 percent. 

Weisser (2006) Nuclear—2.8 to 24 g Ceq/kWh 

(Compilation of results 

from other studies) Coal—950 to 1250 g Ceq/kWh 

Fthenakis and Kim 

(2007) 

Authors did not evaluate nuclear versus coal. 

Dones (2007) Author did not evaluate nuclear versus coal. 

13 6.2.1.4 Summary of Nuclear Greenhouse Gas Emissions Compared to Natural Gas 

14 The quantitative estimates of the GHG emissions associated with the nuclear fuel cycle (and, in 

15 some cases, the nuclear lifecycle), as compared to an equivalent natural gas-fired plant, are 

16 presented in Table 6-3. The following chart does not include all existing studies, but provides an 

17 illustrative range of estimates developed by various sources. 
Environmental Impacts of the Uranium Fuel Cycle 

Draft NUREG-1437, Supplement 41 6-6 February 2010 

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

Source GHG Emission Results 

Mortimer (1990) Author did not evaluate nuclear versus natural gas. 

Andseta (1998) Author did not evaluate nuclear versus natural gas. 

Spadaro (2000) Nuclear—2.5 to 5.7 g Ceq/kWh 

Natural Gas—120 to 188 g Ceq/kWh 

Nuclear fuel cycle produces 20 to 33 percent of the GHG emissions compared to 

natural gas (at high ore grades). 

Storm van Leeuwen 

and Smith (2005) 

Note: Future nuclear GHG emissions to increase because of declining ore grade. 

Fritsche (2006) (Values Nuclear—33 g Ceq/kWh 

estimated from graph 

in Figure 4) Cogeneration Combined Cycle Natural Gas—150 g Ceq/kWh 

Nuclear—5 g Ceq/kWh 

Natural Gas—500 g Ceq/kWh 

POST (2006) (Nuclear 

calculations from AEA, 

2006) Note: Decrease of uranium ore grade to 0.03 percent would raise nuclear to 

6.8 g Ceq/kWh. Future improved technology and carbon capture and storage could 

reduce natural gas GHG emissions by 90 percent. 

Weisser (2006) Nuclear—2.8 to 24 g Ceq/kWh 

(Compilation of results 

from other studies) Natural Gas—440 to 780 g Ceq/kWh 

Fthenakis and Kim 

(2007) 

Authors did not evaluate nuclear versus natural gas. 

Dones (2007) Author critiqued methods and assumptions of Storm van Leeuwen and Smith 

(2005), and concluded that the nuclear fuel cycle produces 15 to 27 percent of the 

GHG emissions of natural gas. 

2 6.2.1.5 Summary of Nuclear Greenhouse Gas Emissions Compared to Renewable Energy 

3 Sources 

4 The quantitative estimates of the GHG emissions associated with the nuclear fuel cycle, as 

5 compared to equivalent renewable energy sources, are presented in Table 6-4. Calculation of 

6 GHG emissions associated with these sources is more difficult than the calculations for nuclear 

7 energy and fossil fuels because of the large variation in efficiencies due to their different 

8 sources and locations. For example, the efficiency of solar and wind energy is highly dependent 

9 on the location in which the power generation facility is installed. Similarly, the range of GHG 

10 emissions estimates for hydropower varies greatly depending on the type of dam or reservoir 

11 involved (if used at all). Therefore, the GHG emissions estimates for these energy sources have 

12 a greater range of variability than the estimates for nuclear and fossil fuel sources. As noted in 

13 Section 6.2.1.2, the following chart does not include all existing studies, but provides an 

14 illustrative range of estimates developed by various sources. 
Environmental Impacts of the Uranium Fuel Cycle 

February 2010 6-7 Draft NUREG-1437, Supplement 41 

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

Source GHG Emission Results 

Nuclear—230,000 tons CO2 

Hydropower—78,000 tons CO2

Wind power—54,000 tons CO2

Tidal power—52,500 tons CO2

Mortimer (1990) 

Note: Future GHG emissions from nuclear to increase because of declining ore 

grade. 

Andseta (1998) Author did not evaluate nuclear versus renewable energy sources. 

Nuclear—2.5 to 5.7 g Ceq/kWh 

Solar PV—27.3 to 76.4 g Ceq/kWh 

Hydroelectric—1.1 to 64.6 g Ceq/kWh 

Biomass—8.4 to 16.6 g Ceq/kWh 

Spadaro (2000) 

Wind—2.5 to 13.1 g Ceq/kWh 

Storm van Leeuwen 

and Smith (2005) 

Author did not evaluate nuclear versus renewable energy sources. 

Nuclear—33 g Ceq/kWh 

Solar PV—125 g Ceq/kWh 

Hydroelectric—50 g Ceq/kWh 

Fritsche (2006) (Values 

estimated from graph 

in Figure 4) 

Wind—20 g Ceq/kWh 

Nuclear—5 g Ceq/kWh 

Biomass—25 to 93 g Ceq/kWh 

Solar PV—35 to 58 g Ceq/kWh 

Wave/Tidal—25 to 50 g Ceq/kWh 

Hydroelectric—5 to 30 g Ceq/kWh 

Wind—4.64 to 5.25 g Ceq/kWh 

POST (2006) (Nuclear 

calculations from AEA, 

2006) 

Note: Decrease of uranium ore grade to 0.03 percent would raise nuclear to 

6.8 g Ceq/kWh. 

Nuclear—2.8 to 24 g Ceq/kWh 

Solar PV—43 to 73 g Ceq/kWh 

Hydroelectric—1 to 34 g Ceq/kWh 

Biomass—35 to 99 g Ceq/kWh 

Weisser (2006) 

(Compilation of results 

from other studies) 

Wind—8 to 30 g Ceq/kWh 

Fthenakis and Kim Nuclear—16 to 55 g Ceq/kWh 

(2007) Solar PV—17 to 49 g Ceq/kWh 

Dones (2007) Author did not evaluate nuclear versus renewable energy sources. 

2 6.2.2 Conclusions: Relative GHG Emissions 

3 The sampling of data presented in Tables 6-2, 6-3, and 6-4 above demonstrates the challenges 

4 of any attempt to determine the specific amount of GHG emission attributable to nuclear energy 

5 production sources, as different assumptions and calculation methodology will yield differing 

6 results. The differences and complexities in these assumptions and analyses will further 

7 increase when they are used to project future GHG emissions. Nevertheless, several 

8 conclusions can be drawn from the information presented. 
Environmental Impacts of the Uranium Fuel Cycle 

Draft NUREG-1437, Supplement 41 6-8 February 2010 

1 First, the various studies indicate a general consensus that nuclear power currently produces 

2 fewer GHG emissions than fossil-fuel-based electrical generation, e.g., the GHG emissions from 

3 a complete nuclear fuel cycle currently range from 2.5 to 55 g Ceq/kWh, as compared to the use 

4 of coal plants (264 to 1250 g Ceq/kWh) and natural gas plants (120 to 780 g Ceq/kWh). The 

5 studies also provide estimates of GHG emissions from five renewable energy sources based on 

6 current technology. These estimates included solar-photovoltaic (17 to 125 g Ceq/kWh), 

7 hydroelectric (1 to 64.6 g Ceq/kWh), biomass (8.4 to 99 g Ceq/kWh), wind (2.5 to 30 g Ceq/kWh), 

8 and tidal (25 to 50 g Ceq/kWh). The range of these estimates is wide, but the general conclusion 

9 is that current GHG emissions from the nuclear fuel cycle are of the same order of magnitude as 

10 from these renewable energy sources. 

11 Second, the studies indicate no consensus on future relative GHG emissions from nuclear 

12 power and other sources of electricity. There is substantial disagreement among the various 

13 authors regarding the GHG emissions associated with declining uranium ore concentrations, 

14 future uranium enrichment methods, and other factors, including changes in technology. Similar 

15 disagreement exists regarding future GHG emissions associated with coal and natural gas for 

16 electricity generation. Even the most conservative studies conclude that the nuclear fuel cycle 

17 currently produces fewer GHG emissions than fossil-fuel-based sources, and is expected to 

18 continue to do so in the near future. The primary difference between the authors is the projected 

19 cross-over date (the time at which GHG emissions from the nuclear fuel cycle exceed those of 

20 fossil-fuel-based sources) or whether cross-over will actually occur. 

21 Considering the current estimates and future uncertainties, it appears that GHG emissions 

22 associated with the proposed CNS-1 relicensing action are likely to be lower than those 

23 associated with fossil-fuel-based energy sources. The NRC staff bases this conclusion on the 

24 following rationale: 

25 (1) As shown in Tables 6-2 and 6-3, the current estimates of GHG emissions from the 

26 nuclear fuel cycle are far below those for fossil-fuel-based energy sources; 

27 (2) CNS-1 license renewal will involve continued GHG emissions due to uranium mining, 

28 processing, and enrichment, but will not result in increased GHG emissions associated 

29 with plant construction or decommissioning (as the plant will have to be decommissioned 

30 at some point whether the license is renewed or not); and 

31 (3) Few studies predict that nuclear fuel cycle emissions will exceed those of fossil fuels 

32 within a timeframe that includes the CNS-1 periods of extended operation. Several 

33 studies suggest that future extraction and enrichment methods, the potential for higher 

34 grade resource discovery, and technology improvements could extend this timeframe. 

35 With respect to comparison of GHG emissions among the proposed CNS-1 license renewal 

36 action and renewable energy sources, it appears likely that there will be future technology 

37 improvements and changes in the type of energy used for mining, processing, and constructing 

38 facilities of all types. Currently, the GHG emissions associated with the nuclear fuel cycle and 

39 renewable energy sources are within the same order of magnitude. Because nuclear fuel 

40 production is the most significant contributor to possible future increases in GHG emissions 

41 from nuclear power, and because most renewable energy sources lack a fuel component, it is 

42 likely that GHG emissions from renewable energy sources would be lower than those 

43 associated with CNS-1 at some point during the period of extended operation. 
Environmental Impacts of the Uranium Fuel Cycle 

February 2010 6-9 Draft NUREG-1437, Supplement 41 

1 The NRC staff also provides an additional discussion about the contribution of GHG to 

2 cumulative air quality impacts in Section 4.11.5 of this SEIS, 

3 6.3 REFERENCES 

4 10 CFR Part 51. Code of Federal Regulations, Title 10, Energy, Part 51, “Environmental 

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

6 10 CFR Part 54. Code of Federal Regulations, Title 10, Energy, Part 54, “Requirements for 

7 Renewal of Operating Licenses for Nuclear Power Plants.” 

8 10 CFR Part 63. Code of Federal Regulations, Title 10, Energy, Part 63, “Disposal of High-Level 

9 Radioactive Wastes in a Geologic Repository at Yucca Mountain, Nevada.” 

10 40 CFR Part 191. Code of Federal Regulations, Title 40, Protection of Environment, Part 191, 

11 “Environmental Radiation Protection Standards for Management and Disposal of Spent Nuclear 

12 Fuel, High-Level and Transuranic Radioactive Waste.” 

13 AEA Technology (AEA). 2006. “Carbon Footprint of the Nuclear Fuel Cycle, Briefing Note.” 

14 Prepared for British Energy. March 2006. 

15 Andseta, S., M.J. Thompson, J.P. Jarrell, and D.R. Pendergast. 1998. “CANDU Reactors and 

16 Greenhouse Gas Emissions.” Canadian Nuclear Association, 11th Pacific Basin Nuclear 

17 Conference, Banff, Alberta, Canada. May 1998. 

18 Dones, R. 2007. “Critical Note on the Estimation by Storm Van Leeuwen J.W., and Smith P. of 

19 the Energy Uses and Corresponding CO2 Emissions for the Complete Nuclear Energy Chain.” 

20 Paul Sherer Institute. April 2007. 

21 Fritsche, U.R. 2006. “Comparison of Greenhouse-Gas Emissions and Abatement Cost of 

22 Nuclear and Alternative Energy Options from a Life-Cycle Perspective.” Oko-Institut, Darmstadt 

23 Office. January 2006. 

24 Fthenakis, V.M. and H.C. Kim. 2007. Greenhouse-gas emissions from solar-electric and nuclear 

25 power: A life cycle study. Energy Policy, Volume 35, Number 4. 

26 International Atomic Energy Agency (IAEA). 2000. “Nuclear Power for Greenhouse Gas 

27 Mitigation under the Kyoto Protocol: The Clean Development Mechanism (CDM).” November 

28 2000. 

29 Mortimer, N. 1990. “World Warms to Nuclear Power.” SCRAM Safe Energy Journal. December 

30 1989 and January 1990. Available URL: 

31 http://www.no2nuclearpower.org.uk/articles/mortimer_se74.php (accessed February 29, 2007). 

32 Nebraska Public Power District (NPPD). 2008. Cooper Nuclear Station License Renewal 

33 Application. Environmental Report. 

34 Organization for Economic Co-Operation and Development, Nuclear Energy Agency (NEA). 

35 2002. Nuclear Energy and the Kyoto Protocol. 

36 Parliamentary Office of Science and Technology (POST). 2006. “Carbon Footprint of Electricity 

37 Generation.” Postnote, Number 268. October 2006. 

38 Schneider, M. 2000. Climate Change and Nuclear Power. World Wildlife Fund for Nature. April 

39 2000. 

40 Spadaro, J.V., L. Langlois and B. Hamilton. 2000. “Greenhouse Gas Emissions of Electricity 

41 Generation Chains: Assessing the Difference.” IAEA Bulletin 42/2/2000, Vienna, Austria. 
Environmental Impacts of the Uranium Fuel Cycle 

Draft NUREG-1437, Supplement 41 6-10 February 2010 

1 Storm van Leeuwen, J.W. and P. Smith 2005. Nuclear Power—The Energy Balance. August 

2 2005. 

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

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

5 1996. ADAMS Accession Nos. ML040690705 and ML040690738. 

6 U.S. Nuclear Regulatory Commission (NRC). 1999. Generic Environmental Impact Statement 

7 for License Renewal of Nuclear Plants, Main Report, “Section 6.3 – Transportation, Table 9.1, 

8 Summary of Findings on NEPA Issues for License Renewal of Nuclear Power Plants, Final 

9 Report.” NUREG-1437, Volume 1, Addendum 1, Washington, D.C. 

10 Weisser, D. 2006. “A Guide to Life-Cycle Greenhouse Gas (GHG) Emissions from Electric 

11 Supply Technologies.” Available URL: 

12 http://www.iaea.org/OurWork/ST/NE/Pess/assets/GHG_manuscript_pre13 print_versionDanielWeisser.pdf (accessed May 19, 2009)
February 2010 7-1 Draft NUREG-1437, Supplement 41 

1 7.0 ENVIRONMENTAL IMPACTS OF DECOMMISSIONING 

2 Environmental impacts from the activities associated with the decommissioning of any reactor 

3 before or at the end of an initial or renewed license are evaluated in the Generic Environmental 

4 Impact Statement on Decommissioning of Nuclear Facilities: Supplement 1, Regarding the 

5 Decommissioning of Nuclear Power Reactors, NUREG-0586, Supplement 1 (NRC, 2002). The 

6 staff's evaluation of the environmental impacts of decommissioning presented in NUREG-0586, 

7 Supplement 1, identifies a range of impacts for each environmental issue. 

8 The incremental environmental impacts associated with decommissioning activities resulting 

9 from continued plant operation during the renewal term are discussed in the Generic 

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

11 Volumes 1 and 2 (NRC 1996; 1999). 

12 7.1 DECOMMISSIONING

13 Category 1 issues in Table B-1 of Title 10 of the Code of Federal Regulations (CFR) Part 51, 

14 Subpart A, Appendix B that are applicable to Cooper Nuclear Station, Unit 1 (CNS-1) 

15 decommissioning following the renewal term are listed in Table 7-1. 

16 Table 7-1. Category 1 Issues Applicable to the Decommissioning of CNS-1 Following the 

17 Renewal Term

ISSUE GEIS Section

Radiation doses 7.3.1 

Waste management 7.3.2 

Air quality 7.3.3 

Water quality 7.3.4 

Ecological resources 7.3.5 

Socioeconomic impacts 7.3.7 

18 

19 A brief description of the staff’s review and the conclusions, as stated in Table B-1, 10 CFR Part 

20 51, for each of the issues follows: 

21 ● Radiation doses. Based on information in the GEIS, the Commission found that: 

22 Doses to the public will be well below applicable regulatory standards regardless 

23 of which decommissioning method is used. Occupational doses would increase 

24 no more than 1 man-rem caused by buildup of long-lived radionuclides during the 

25 license renewal term. 

26 ● Waste management. Based on information in the GEIS, the Commission found that: 

27 Decommissioning at the end of a 20-year license renewal period would generate 

28 no more solid wastes than at the end of the current license term. No increase in 

29 the quantities of Class C or greater than Class C wastes would be expected. 

30 ● Air quality. Based on information in the GEIS, the Commission found that: 
Environmental Impacts of Decommissioning 

Draft NUREG-1437, Supplement 41 7-2 February 2010 

1 Air quality impacts of decommissioning are expected to be negligible either at the 

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

3 ● Water quality. Based on information in the GEIS, the Commission found that: 

4 The potential for significant water quality impacts from erosion or spills is no 

5 greater whether decommissioning occurs after a 20-year license renewal period 

6 or after the original 40-year operation period, and measures are readily available 

7 to avoid such impacts. 

8 ● Ecological resources. Based on information in the GEIS, the Commission found that: 

9 Decommissioning after either the initial operating period or after a 20-year 

10 license renewal period is not expected to have any direct ecological impacts. 

11 ● Socioeconomic Impacts. Based on information in the GEIS, the Commission found that: 

12 Decommissioning would have some short-term socioeconomic impacts. The 

13 impacts would not be increased by delaying decommissioning until the end of a 

14 20-year relicense period, but they might be decreased by population and 

15 economic growth. 

16 The NRC staff has not identified any new and significant information during the review of the 

17 Nebraska Public Power District (NPPD) environmental report (ER), the site audit, or the scoping 

18 process; therefore, there are no impacts related to these issues beyond those discussed in the 

19 GEIS (NRC 1996, 1999). For the issues listed in Table 7-1 above, the GEIS concluded that the 

20 impacts are SMALL. 

21 7.2 REFERENCES 

22 10 CFR Part 51. Code of Federal Regulations, Title 10, Energy, Part 51, “Environmental 

23 Protection Regulations for Domestic Licensing and Related Regulatory Functions 

24 Nebraska Public Power District (NPPD). 2008. Cooper Nuclear Station, Applicant’s 

25 Environmental Report, License Renewal Operating Stage. ADAMS Accession No. 

26 ML08303020246.

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

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

29 ADAMS Accession No. ML040690705 and ML040690738. 

30 U.S. Nuclear Regulatory Commission (NRC). 1999. Generic Environmental Impact Statement 

31 for License Renewal of Nuclear Plants, Main Report, “Section 6.3, Transportation, Table 9.1, 

32 Summary of Findings on NEPA Issues for License Renewal of Nuclear Power Plants, Final 

33 Report.” NUREG-1437, Volume 1, Addendum 1, Washington, D.C. 

34 U.S. Nuclear Regulatory Commission (NRC). 2002. Generic Environmental Impact Statement 

35 on Decommissioning of Nuclear Facilities: Supplement 1, “Regarding the Decommissioning of 

36 Nuclear Power Reactors.” NUREG-0586, Supplement 1, Volumes 1 and 2, Washington, D.C. 
February 2010 8-1 Draft NUREG-1437, Supplement 41 

1 8.0 ENVIRONMENTAL IMPACTS OF ALTERNATIVES 

2 The National Environmental Policy Act (NEPA) mandates that each environmental impact 

3 statement (EIS) consider alternatives to any proposed major Federal action. U.S. Nuclear 

4 Regulatory Commission (NRC) regulations (Title 10 of the Code of Federal Regulations (CFR) 

5 Section 51.71(d)) implementing NEPA for license renewal require that a supplemental 

6 environmental impact statement (SEIS) do the following: 

7 Consider and weigh the environmental effects of the proposed action; the 

8 environmental impacts of alternatives to the proposed action; and alternatives 

9 available for reducing or avoiding adverse environmental effects and consideration 

10 of the economic, technical, and other benefits and costs of the proposed action. 

11 In this case, the proposed Federal action is issuing a renewed license for Cooper Nuclear 

12 Station, Unit 1 (CNS-1), which will allow the plant to operate for 20 years beyond its current 

13 license expiration date. In this chapter, the NRC staff examines potential environmental impacts 

14 of alternatives to issuing a renewed operating license for CNS-1 as well as alternatives that may 

15 reduce or avoid adverse environmental impacts from license renewal, including when and 

16 where these alternatives are applicable. 

17 While the Generic Environmental Impact Statement (GEIS) for License Renewal of Nuclear 

18 Plants, NUREG-1437 (NRC 1996, 1999), reached generic conclusions regarding many 

19 environmental issues associated with license renewal, it did not determine which alternatives 

20 are reasonable or reach conclusions about site-specific environmental impact levels. As such, 

21 the NRC staff must evaluate environmental impacts of alternatives on a 

22 site-specific basis. 

23 Alternatives to the proposed action of issuing a renewed CNS-1 operating license must meet 

24 the purpose and need for issuing a renewed license; they must “provide an option that allows for 

25 power generation capability beyond the term of a current nuclear power plant operating license 

26 to meet future system generating needs, as such needs may be determined by State, utility, 

27 and, where authorized, Federal (other than NRC) decision makers (NRC, 1996).” 

28 The NRC staff ultimately makes no decision as to which alternative (or the proposed action) to 

29 implement, since that decision falls to utility, or State officials. Comparing the environmental 

30 effects of these alternatives will assist the NRC in deciding whether or not the adverse 

31 environmental impacts of license renewal are so great that preserving the option of license 

32 renewal for energy planning decisionmakers would be unreasonable. If the NRC acts to issue a 

33 renewed license, all of the alternatives, including the proposed action, will be available to 

34 energy-planning decision makers. If NRC decides not to renew the license (or takes no action at 

35 all), then energy-planning decision makers may no longer elect to continue operating CNS-1 

36 and will have to resort to another alternative—which may or may not be one of the alternatives 

37 the NRC staff considers in this section—to meet their energy needs. 

38 In evaluating alternatives to license renewal, the NRC staff first selects energy technologies or 

39 options currently in commercial operation as well as some technologies not currently in 

40 commercial operation but likely to be commercially available by the time the current CNS-1 

41 operating license expires. 
Environmental Impacts of Alternatives 

Draft NUREG-1437, Supplement 41 8-2 February 2010 

Energy Outlook: 

Each year the Energy Information 

Administration (EIA), part of the U.S. 

Department of Energy (DOE), issues its 

updated Annual Energy Outlook (AEO). 

AEO, 2009, indicates that natural gas, coal, 

and renewables are likely to fuel most new 

electrical capacity through 2030, with some 

growth in nuclear capacity (EIA, 2009a), 

though all projections are subject to future 

developments in fuel price or electricity 

demand. 

 “Natural-gas-fired plants account for 

53 percent of capacity additions in the 

reference case, as compared with 

22 percent for renewables, 18 percent for 

coal-fired plants, and 5 percent for 

nuclear. Capacity expansion decisions 

consider capital, operating, and 

transmission costs. Typically, coal-fired, 

nuclear, and renewable plants are 

capital-intensive, whereas operating (fuel) 

expenditures account for most of the costs 

associated with natural-gas-fired 

capacity.” (EIA, 2009c) 

1 Second, the NRC staff screens the alternatives to remove those that cannot meet future system 

2 needs. Then, the staff screens the remaining options to remove those whose costs or benefits 

3 do not justify inclusion in the range of reasonable alternatives. Any alternatives remaining, then, 

4 constitute alternatives to the proposed action that the staff evaluates in-depth throughout this 

5 section. At the end of the section, the staff will briefly address each alternative removed during 

6 screening. 

7 The NRC staff initially considers 19 discrete alternatives to the proposed action. 

8 Once the staff identifies the in-depth alternatives, the staff refers to generic environmental 

9 impact evaluations in the GEIS. The GEIS provides overviews of some energy technologies 

10 available at the time of its publishing in 1996, though it does not reach any conclusions 

11 regarding which alternatives are most appropriate, nor does it precisely categorize impacts for 

12 each site. Since 1996, many energy technologies have evolved significantly in capability and 

13 cost, while regulatory structures have changed to either promote or impede development of 

14 particular alternatives. 

15 As a result, our analyses include updated information from sources like the Energy Information 

16 Administration (EIA), other organizations within the Department of Energy (DOE), the 

17 Environmental Protection Agency (EPA), industry sources and publications, and information 

18 submitted by the applicant (Nebraska Public Power District (NPPD)) in the environmental report 

19 (ER). 

20 For each in-depth analysis, the staff 

21 analyzes environmental impacts across 

22 seven impact categories: (1) air quality, 

23 (2) ground water use and quality, (3) 

24 surface water use and quality, (4) 

25 ecology, (5) human health, (6) 

26 socioeconomics, and (7) waste 

27 management. As in earlier chapters of 

28 this draft SEIS, the staff uses NRC’s 

29 three-level standard of significance—

30 SMALL, MODERATE, or LARGE—to 

31 indicate the intensity of environmental 

32 effects for each alternative that is 

33 evaluated in depth. By placing the 

34 detailed alternative analyses in this 

35 order, the NRC staff does not mean to 

36 imply that one alternative would have the 

37 least impact, or that an energy-planning 

38 decision maker would be most likely to 

39 implement one or another alternative. 

40 Sections 8.1 through 8.3 contain 

41 analyses of environmental impacts of 

42 alternatives to license renewal. These 

43 include a supercritical coal-fired plant in 

44 Section 8.1, a natural gas-fired 

45 combined-cycle power plant in 8.2, and a 

46 combination of alternatives in 8.3, that 
Environmental Impacts of Alternatives 

February 2010 8-3 Draft NUREG-1437, Supplement 41 

1 includes some natural gas-fired capacity, energy conservation, and a wind power component. In 

2 Section 8.4, the NRC staff explains why it dismissed many other alternatives from in-depth 

3 consideration. Finally, in Section 8.5, the staff considers the environmental effects that may 

4 occur if NRC takes no action and does not issue a renewed license for CNS-1. 

5 8.1 SUPERCRITICAL COAL-FIRED GENERATION 

6 Coal-fired generation accounts for a greater share of U.S. electrical power generation than any 

7 other fuel (EIA, 2009a). Furthermore, the EIA projects that coal-fired power plants will account 

8 for the greatest share of capacity additions through 2030—more than natural gas, nuclear or 

9 renewable generation options. While coal-fired power plants are widely used and likely to 

10 remain widely used, the staff acknowledges that future additions to coal capacity may be 

11 affected by perceived or actual efforts to limit greenhouse gas (GHG) emissions. For now, the 

12 staff considers a coal-fired alternative to be a feasible, commercially available option for 

13 providing electrical generating capacity beyond CNS-1’s current license expiration. 

14 Supercritical technologies are increasingly common in new coal-fired plants. Supercritical 

15 facilities operate at higher temperatures and pressures than most existing coal-fired plants. At 

16 the critical point, there is no change of state when pressure is increased or if heat is added. For 

17 states above the critical point the steam is supercritical. Operating at higher temperatures and 

18 pressures allows the supercritical coal-fired alternative to operate at a higher thermal efficiency 

19 than subcritical coal-fired power plants. While supercritical facilities are more expensive to 

20 construct, they consume less fuel for a given output, reducing environmental impacts. Based on 

21 technology forecasts from EIA (EIA, 2009), the NRC staff expects that a new, supercritical coal22 fired plant that begins operation in 2014 would operate at a heat rate of 9,069 British thermal 

units/kilowatt hours (Btu/kWh), or approximately 38 percent thermally efficient (EIA, 2009).3 23 

24 In a supercritical coal-fired power plant, burning coal heats pressurized water. As the 

25 supercritical steam/water mixture moves through plant pipes to a turbine generator, the 

26 pressure drops and the mixture flashes to steam. The heated steam expands across the turbine 

27 stages, which then spin and turn the generator to produce electricity. After passing through the 

28 turbine, any remaining steam is condensed back to water in the plant’s condenser. 

29 In most modern U.S. coal facilities, condenser cooling water circulates through cooling towers or 

30 a cooling pond system (either of which are closed-cycle cooling systems). Older plants often 

31 withdraw cooling water directly from existing rivers or lakes and discharge heated water directly 

32 to the same body of water (called open-cycle cooling). Though the NRC staff notes that a new 

33 facility could hypothetically continue to use the existing CNS-1 intake structure with a once34 through cooling system as long as CNS-1 could continue to receive sufficient water to maintain 

35 cooling for those systems necessary for a shutdown plant and provided that no modifications 

36 would be necessary to the intake structure and associated pumps. In order to provide cooling 

37 water for the new facility, the NRC staff has chosen to evaluate a coal-fired alternative using 

38 closed-cycle cooling because it will result in lower impacts—primarily to aquatic ecology—over 

39 the life of the alternative. Construction impacts may, however, be slightly greater, and 

40 operational impacts to aesthetics may also be slightly more noticeable, depending on whether 

41 or not the replacement facility uses natural- or mechanical-draft cooling towers. 

 

3

 Thermal efficiency is a measure of the efficiency of converting a fuel to energy and useful work. Thermal efficiency 

of a nuclear plant is roughly 32 percent. 
Environmental Impacts of Alternatives 

Draft NUREG-1437, Supplement 41 8-4 February 2010 

1 The plant would withdraw makeup water from and discharge blowdown (water containing 

2 concentrated dissolved solids and biocides) back to the Missouri River. Cooling towers could be 

3 either natural draft (tall towers powered only by the difference in density between heated, humid 

4 air, and surrounding cooler and usually drier air) or mechanical draft (shorter towers powered by 

5 mechanical fans). For this analysis, the NRC staff assumed that a new supercritical coal-fired 

6 power plant would use mechanical draft towers for its closed-cycle cooling system. 

7 In order to replace the 816 net MWe that CNS-1 currently supplies, the coal-fired alternative 

8 would ideally produce roughly the same amount (NPPD, 2008). Onsite electricity usage includes 

9 scrubbers, cooling towers, coal-handling equipment, lights, communication, and other onsite 

10 needs. A supercritical coal-fired power plant equivalent in capacity to CNS-1 would require less 

11 cooling water than CNS-1 because of the switch from open-cycle to closed-cycle cooling and 

12 because the plant operates at a higher thermal efficiency. 

13 This 816 net MWe power plant would consume 3.14 million tons (2.84 million metric tons (MT)) 

14 of coal annually assuming an average heat content of 8,570 British thermal unit/pound (BTU/lb) 

15 (EIA, 2006). EIA reported that most coal consumed in Nebraska originates in Wyoming. Given 

16 current coal mining operations in Wyoming, the coal used in this alternative would likely be 

17 mined in surface mines, then mechanically processed and washed, before being transported—

18 likely by rail—to the power plant site. Limestone for scrubbers would also likely arrive by rail. 

19 This coal-fired alternative would then produce roughly 153,000 tons (138,800 MT) of ash, and 

20 roughly 49,500 tons (45,000 MT) scrubber sludge. As noted above, much of the coal ash and 

21 scrubber sludge (about 38,300 tons (34,800 MT)) could be recycled. 

22 Environmental impacts from the coal-fired alternative will be greatest during construction. Site 

23 crews will clear the plant site of vegetation, prepare the site surface, and begin excavation 

24 before other crews begin actual construction on the plant and any associated infrastructure, 

25 including electricity transmission infrastructure connecting the plant to existing transmission 

26 lines.

27 8.1.1 Air Quality 

28 Air quality impacts from coal-fired generation can be substantial because it emits a significant 

29 quantity of sulfur oxides (SOx), nitrogen oxides (NOx), particulates, carbon monoxide (CO), and 

30 hazardous air pollutants (HAPs) such as mercury; however, many of these pollutants can be 

31 effectively controlled by various technologies. 

32 CNS-1 is located in Nemaha County, Nebraska. There are no areas designated by the EPA as 

33 nonattainment or maintenance for any of the criteria pollutants in the 50-mile (81 kilometer) 

34 vicinity of CNS-1. (EPA has defined six "criteria pollutants" as indicators of air quality, and has 

35 established for each of them a maximum concentration above which adverse effects on human 

36 health may occur). A new coal-fired generating plant would qualify as a new major-emitting 

37 industrial facility and would be subject to Prevention of Significant Deterioration of Air Quality 

38 Review under requirements of the Clean Air Act (CAA) (42 U.S.C. §7401 et seq.), adopted by 

39 Nebraska Department of Environmental Quality (NDEQ) in Title 129 of Nebraska Air Quality 

40 Regulations (NAQR) (EPA, 2008a). A new coal-fired generating plant would need to comply

41 with the new source performance standards for coal-fired plants set forth in 40 CFR 60 Subpart 

42 Da. The standards establish limits for particulate matter (40 CFR 60.42Da), sulfur dioxide (SO2) 

43 (40 CFR 60.43Da), and NOx (40 CFR 60.44Da). Regulations issued by NDEQ adopt the EPA's 

44 CAA rules, with modifications, to limit power plant emissions of SOx, NOx, particulate matter, 

45 and HAPs, among other matters. The new coal-fired generating plant would qualify as a Class I 
Environmental Impacts of Alternatives 

February 2010 8-5 Draft NUREG-1437, Supplement 41 

1 major source as identified in Chapter 2 of Title 129 of the Nebraska Administrative Code and 

2 would be required to obtain Class I major source permits from NDEQ, (the EPA may also elect 

3 to review this aspect prior to issuance of the permits (NDEQ, 2003)). 

4 Section 169A of the CAA (42 U.S.C. § 7491) calls for EPA to establish rules to remedy any 

5 existing visibility impairment and prevent any future impairment in mandatory Class I federal 

6 areas resulting from manmade air pollution. There are no mandatory Class I Federal areas in 

7 the State of Nebraska and the closest mandatory Class I Federal area is Hercules-Glades 

8 Wilderness Area, which is located 295 miles southeast from the CNS-1 in the State of Missouri. 

9 However, the State of Nebraska is among nine states (Nebraska, Kansas, Oklahoma, Texas, 

10 Minnesota, Iowa, Missouri, Arkansas, and Louisiana) that are members of the Central Regional 

11 Air Planning Association (CENRAP), along with tribes, Federal agencies, and other interested 

12 parties that identify regional haze and visibility issues and develop strategies to address them. 

13 The visibility protection regulatory requirements, contained in 40 CFR Part 51, Subpart P, 

14 include the review of the new sources that would be constructed in the attainment or 

15 unclassified areas and may affect visibility in any Federal Class I area (40 CFR § 51.307). 

16 The emissions from the coal-fired alternative at the CNS-1 site, projected by the NRC staff 

17 based on published EIA data, EPA emission factors and based on performance characteristics 

18 for this alternative and likely emission controls, would be: 

19 ● Sulfur oxides (SOx) – 923 tons (838 metric tones) per year 

20 ● Nitrogen oxides (NOx) – 784 tons (711 metric tones) per year 

21 ● Total suspended particles (TSP) – 80 tons (72 metric tones) per year 

22 ● Particulate matter (PM) PM10 – 18 tons (17 metric tones) per year 

23 ● Particulate matter (PM) PM2.5 – 77 tons (69 metric tones) per year 

24 ● Carbon monoxide (CO) – 784 tons (711 metric tones) per year 

25 8.1.1.1 Sulfur Oxides 

26 The coal-fired alternative at the CNS-1 site would likely use wet, limestone-based scrubbers to 

27 remove SOx. The EPA indicates that this technology can remove more than 95 percent of SOx

28 from flue gases. The staff projects total SOx emissions would be 923 tons (838 MT) per year. 

29 SOx emissions from a new coal-fired power plant would be subject to the part of the 

30 requirements of the CAA (42 U.S.C. §§7651 et seq.). These regulations were enacted to reduce 

31 emissions of SO2 and NOx, the two principal precursors of acid rain, by restricting emissions of 

32 these pollutants from power plants. Title IV caps aggregate annual power plant SO2 emissions 

33 and imposes controls on SO2 emissions through a system of marketable allowances. The EPA 

34 issues one allowance for each ton of SO2 that a unit is allowed to emit. New units do not receive 

35 allowances, but are required to have allowances to cover their SO2 emissions. Owners of new 

36 units must therefore purchase allowances from owners of other power plants or reduce SO2

37 emissions at other power plants they own. Allowances can be banked for use in future years. 

38 Thus, provided a new coal-fired power plant is able to purchase sufficient allowances to 

39 operate, it would not add to net regional SO2 emissions, although it might do so locally. 
Environmental Impacts of Alternatives 

Draft NUREG-1437, Supplement 41 8-6 February 2010 

1 8.1.1.2 Nitrogen Oxides 

2 A coal-fired alternative at the CNS-1 site would most likely employ various available NOx -

3 control technologies, which can be grouped into two main categories: combustion modifications 

4 and post-combustion processes. Combustion modifications include low- NOx burners, overfire 

5 air, reburning, flue gas recirculation, and operational modifications. Post-combustion processes 

6 include selective catalytic reduction, selective noncatalytic reduction, and hybrid processes. 

7 Effective combination of the combustion modifications and post-combustion processes allows 

8 reducing NOx emissions by up to 95 percent (EPA, 1998). NPPD indicated in its ER that it would 

9 use a combination of low- NOx burners, overfire air, and selective noncatalytic reduction 

10 technologies in order to reduce NOx emissions from this alternative. Assuming the use of such 

11 technologies at the CNS-1 site, NOx emissions after scrubbing are estimated to be in the range 

12 of 783.77 tons (711.04 MT) annually. 

13 Section 407 of the CAA establishes technology-based emission limitations for NOx emissions. A 

14 new coal-fired power plant would be subject to the new source performance standards for such 

15 plants as indicated in 40 CFR 60.44Da(1). This regulation, limits the discharge of any gases that 

16 contain NOx to 200 nanograms (ng) of NOx per joule (J) of gross energy output (equivalent to 

17 1.6 pounds per megawatt hours (lb/MWh), based on a 30-day rolling average. Based on the 

18 projected emissions and proposed emissions controls, the coal-fired alternative would meet this 

19 regulation.

20 8.1.1.3 Particulates 

21 The new coal-fired power plant would use fabric filters to remove particulates from flue gases. 

22 NPPD indicates that fabric filters would remove 99.9 percent of particulate matter (NPPD, 

23 2008). The EPA notes that filters are capable of removing in excess of 99 percent of particulate 

24 matter, and that SO2scrubbers further reduce particulate matter emissions (EPA, 2008); 

25 therefore, the NRC staff believes the NPPD removal factor is appropriate. Based on this, the 

26 new supercritical coal-fired plant would emit 79.68 tons (72.29 MT) per year of TSP and 

27 approximately 18.33 tons (16.63 MT) per year of particulate matter having an aerodynamic 

28 diameter less than, or equal to, 10 microns (PM10) annually. In addition, coal burning would 

29 also result in approximately 76.50 tons per year (69.40 MT) of particulate emissions with an 

30 aerodynamic diameter of 2.5 microns or less (PM2.5) and coal-handling equipment would 

31 introduce fugitive dust emissions when fuel is being transferred to onsite storage and then 

32 reclaimed from storage for use in the plant. During the construction of a coal-fired plant, onsite 

33 activities would also generate fugitive dust. Vehicles and motorized equipment would create 

34 exhaust emissions during the construction process. These impacts would be intermittent and 

35 short-lived; however, to minimize dust generation, construction crews could use applicable dust36 control measures. 

37 8.1.1.4 Carbon Monoxide 

38 Based upon EPA emission factors (EPA, 1998), NRC staff estimates that total CO emissions 

39 would be approximately 783.77 tons (711.04 MT) per year. 

40 8.1.1.5 Carbon Dioxide 

41 A coal-fired plant would also have unregulated carbon dioxide (CO2) emissions during 

42 operations, as well as during mining, processing, and transportation. The coal-fired plant would 

43 emit between 5,516,000 tons (5,004,000 MT) and 5,715,000 tons (5,184,600 MT) of CO2 per 

44 year from coal combustion, depending on the type and quality of the coal burned. 
Environmental Impacts of Alternatives 

February 2010 8-7 Draft NUREG-1437, Supplement 41 

1 8.1.1.6 Summary of Air Quality 

2 While the GElS analysis mentions global warming from unregulated CO2 emissions and acid 

3 rain from SOx and NOx emissions as potential impacts, it does not quantify emissions from coal4 fired power plants; however, the GElS analysis does imply that air impacts would be substantial 

5 (NRC, 1996). The above analysis shows that emissions of air pollutants, including SOx, NOx, 

6 CO, and particulates, exceed those produced by the existing nuclear power plant, as well as 

7 those of the other alternatives considered in this section. Operational emissions of CO2 are also 

8 much greater under the coal-fired alternative than under other alternatives, as reviewed by the 

9 staff in Section 6.2. Adverse human health effects such as cancer and emphysema have also 

10 been associated with air emissions from coal combustion, and are discussed further in Section 

11 8.1.5. 

12 The NRC analysis for a coal-fired alternative at an alternative site indicates that impacts from 

13 the coal-fired alternative would have clearly noticeable effects, but given existing regulatory 

14 regimens, permit requirements, and emissions controls, the coal-fired alternative would not 

15 destabilize air quality. Therefore, the appropriate characterization of air impacts from coal-fired 

16 plant located at CNS-1 site is MODERATE. 

17 8.1.2 Ground Water Use and Quality 

18 If the onsite coal-fired alternative continued to use ground water for drinking water and service 

19 water, the need for ground water at the plant would be minor. Total usage would likely be less 

20 than CNS-1 because fewer workers would be onsite, and the coal-fired unit would have fewer 

21 auxiliary systems requiring service water. No effect on ground water quality would likely be 

22 apparent. 

23 Construction of a coal-fired plant could have a localized effect on ground water due to 

24 temporary dewatering and run-off control measures. Because of the temporary nature of 

25 construction and the likelihood of reduced ground water usage during operation, the impact of 

26 the coal-fired alternative would be designated as SMALL. 

27 8.1.3 Surface Water Use and Quality 

28 Because the alternative would draw water from the Missouri River, most of the approximately 

29 12,000 gallons per minute (gpm) needed for maximum withdrawal would be taken from the river 

30 with an average consumptive loss of about 15 million gallons per day (mgd). Since the 

31 consumptive loss is less than 0.1 percent of the average annual flow of the Missouri River, the 

32 NRC staff concludes the impact of surface water use would be designated as SMALL. A new 

33 coal-fired plant would be required to obtain a National Pollutant Discharge and Elimination 

34 System (NPDES) permit from the NDEQ for regulation of industrial discharges such as 

35 wastewater and storm water. Assuming the plant operates within the limits of this permit, the 

36 impact from any cooling tower blowdown, site runoff, and other effluent discharges on surface 

37 water quality would be designated as SMALL. 

38 8.1.4 Aquatic and Terrestrial Ecology 

39 8.1.4.1 Aquatic Ecology 

40 In Section 8.1, the NRC notes that it may be possible for a coal-fired alternative to rely on the 

41 existing CNS-1 cooling water intake and open cycle cooling, but in order to reduce potential 

42 impacts to aquatic organisms, the NRC staff has determined that the coal-fired alternative would 
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Draft NUREG-1437, Supplement 41 8-8 February 2010 

1 use closed-cycle cooling. The number of fish and other aquatic organisms affected by 

2 impingement, entrainment, and thermal impacts will be less than those associated with license 

3 renewal because water consumption from, and heat rejected to, the Missouri River would be 

4 substantially lower than the current CNS-1 as closed cycle cooling requires less water and has 

5 less aquatic effects than once-through cooling. Some temporary impacts to aquatic organisms 

6 might occur as a result of construction or effluent discharges to the river. These activities would 

7 be monitored by the NDEQ under the project’s NPDES permit. Although the number of affected 

8 organisms would be substantially less than for license renewal, the level of impact for continued 

9 CNS-1 operation is already small, and so NRC expects that the levels of impact for 

10 impingement, entrainment, and thermal effects would also be designated as SMALL. 

11 8.1.4.2 Terrestrial Ecology 

12 Coal-mining operation will also affect terrestrial ecology in offsite coal mining areas, although 

13 some of the land is most likely already disturbed by mining operations. Onsite and offsite land 

14 disturbances form the basis for impacts to terrestrial ecology.

15 Onsite impacts to terrestrial ecology will be minor because most of the site has been previously 

16 disturbed and is currently used for agricultural activities, aside from the 234 acres (95 ha) of 

17 woodland on the Missouri side of the river. The impact could change if additional railways or 

18 roads are constructed through less disturbed areas. It is likely that the coal-fired alternative 

19 would continue to use the existing transmission system and right-of-ways (ROWs). The 

20 construction of mechanical draft cooling towers for the closed-cycle cooling system may also 

21 result in additional land disturbances. These construction activities may fragment (in the case of 

22 roads or railways) or destroy habitats and could include a loss of onsite farmland and possibly 

23 wetlands. Construction could also affect current drainage patterns of water into and out of the 

24 wetlands on the CNS-1 site. These land disturbances could affect food supply and habitat of 

25 native wildlife and migratory waterfowl, and changes to the drainage patterns of the wetlands 

26 could affect the wetlands vegetation. However, these impacts are not likely to be significant. 

27 Cooling tower operation could produce some deposition of dissolved solids on surrounding 

28 vegetation and soil from cooling tower drift, even though the GEIS indicates that the impact of 

29 cooling towers on agricultural crops is of small significance and most of the land surrounding the 

30 CNS-1 site is farmland. 

31 Any onsite or offsite waste disposal by land filling will also affect terrestrial ecology at least 

32 through the period when the disposal area is reclaimed. Deposition of acid rain resulting from 

33 NOx or SOx emissions, and the deposition of other pollutants, can also affect terrestrial ecology. 

34 Given the emission regulations discussed in Section 8.1.1, air deposition impacts may be 

35 noticeable but are not likely to be destabilizing. Because of the potential habitat disturbances 

36 and potential pollutant deposition, impacts to terrestrial resources from a coal-fired alternative 

37 would be designated as MODERATE and would occur mostly during construction. 

38 8.1.5 Human Health 

39 Coal-fired power plants introduce worker risks from coal and limestone mining, from coal and 

40 limestone transportation, from plant operations, and from disposal of coal combustion and 

41 scrubber wastes. In addition, there are public risks from inhalation of stack emissions (as 

42 addressed in Section 8.1.1) and the secondary effects of eating foods grown in areas subject to 

43 deposition from plant stacks. 

44 Human health risks of coal-fired power plants are described, in general, in Table 8-2 of the 

45 GEIS (NRC, 1996). Cancer and emphysema as a result of the inhalation of toxins and 
Environmental Impacts of Alternatives 

February 2010 8-9 Draft NUREG-1437, Supplement 41 

1 particulates are identified as potential health risks to occupational workers and members of the 

2 public (NRC, 1996). The human health risks of coal-fired power plants, both to occupational 

3 workers and to members of the public, are greater than those of the current CNS-1 due to 

4 exposures to chemicals such as mercury; SOx; NOx; radioactive elements such as uranium and 

5 thorium contained in coal and coal ash; and polycyclic aromatic hydrocarbon (PAH) compounds, 

6 including benzo(a)pyrene. 

7 Regulations restricting emissions—enforced by the EPA or State agencies—have acted to 

8 significantly reduce potential health effects but do not entirely eliminate them. These agencies 

9 also impose site-specific emission limits as needed to protect human health. Even if the coal10 fired alternative were located in a nonattainment area, emission controls and trading or offset 

11 mechanisms could prevent further regional degradation; however, local effects could be visible. 

12 Many of the byproducts of coal combustion responsible for health effects are largely controlled, 

13 captured, or converted in modern power plants (as described in Section 8.1.1), although some 

14 level of health effects may remain. 

15 Aside from emission impacts, the coal-fired alternative introduces the risk of coal pile fires and 

16 for those plants that use coal combustion liquid and sludge waste impoundments, the release of 

17 the waste due to a failure of the impoundment. Although there have been several instances of 

18 this occurring in recent years, these types of events are still relatively rare. 

19 Overall, despite the range of potential threats to human health, extensive health-based 

20 regulations exist to mitigate the risks to workers and the public. As a result, the NRC staff 

21 expects human health impacts to be characterized as SMALL. 

22 8.1.6 Socioeconomics 

23 8.1.6.1 Land Use 

24 The GEIS generically evaluates the impacts of nuclear power plant operations on land use both 

25 on and off each power plant site. The analysis of land use impacts focuses on the amount of 

26 land area that would be affected by the construction and operation of a new supercritical coal27 fired power plant on the CNS-1 site. 

28 Based on previous experience and operating coal-fired plants of similar size, the NRC staff 

29 estimates that an 816-MWe plant would require approximately 170 acres (69 ha) of land. 

30 Additional onsite land may be needed to support a rail spur and yard, as well as approximately 

31 140 acres (57 ha) of land area for waste disposal. 

32 Offsite land use impacts would occur from coal mining, in addition to land use impacts from the 

33 construction and operation of the new power plant. Scaling from GEIS estimates, approximately 

34 18,260 acres (7,390 ha) of land could be affected by mining coal and waste disposal to support 

35 the coal-fired alternative during its operational life (NRC, 1996); however, most of the land in 

36 existing coal-mining areas has already experienced some level of disturbance. The elimination 

37 of the need for uranium mining to supply fuel for the CNS-1 would partially offset this offsite land 

38 use impact. Scaling from GEIS estimates, approximately 816 acres (330 ha) of land used for 

39 uranium mining and processing would no longer be needed. 

40 Based on this information, land use impacts could range from MODERATE to LARGE. Some 

41 portion of this impact could be mitigated by constructing the rail spur in existing ROWs. 
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Draft NUREG-1437, Supplement 41 8-10 February 2010 

1 8.1.6.2 Socioeconomics 

2 Socioeconomic impacts are defined in terms of changes to the demographic and economic 

3 characteristics and social conditions of a region. For example, the number of jobs created by the 

4 construction and operation of a new coal-fired power could affect regional employment, income, 

5 and expenditures. Job creation is characterized by two types: (1) construction-related jobs, and 

6 (2) operation-related jobs in support of power plant operations, which have the greater potential 

7 for permanent, long-term socioeconomic impacts. Workforce requirements of power plant 

8 construction and operation for the coal-fired alternative were determined in order to measure 

9 their possible effects on current socioeconomic conditions. 

10 Based on GEIS estimates, NPPD projected a peak construction workforce of 979 to 

11 2,040 workers would be required to construct the coal-fired alternative at the CNS-1 

12 (NPPD, 2008). During the construction period, the communities surrounding the plant site would 

13 experience increased demand for rental housing and public services. The relative economic 

14 contributions of these relocating workers to local business and tax revenues would vary over 

15 time. 

16 After construction, local communities may be temporarily affected by the loss of construction 

17 jobs and associated loss in demand for business services. In addition, the rental housing market 

18 could experience increased vacancies and decreased prices. As noted in the GEIS, the 

19 socioeconomic impacts at a rural construction site could be larger than at an urban site, 

20 because the workforce would need to relocate closer to the construction site. Although the CNS21 1 site is a rural site, it is located near the city of Omaha, Nebraska (75 miles), meaning that 

22 these effects may be somewhat lessened if workers commute to the site instead of relocating 

23 closer. Construction impacts could range from MODERATE to LARGE. 

24 NPPD estimated an operational workforce of 163 to 204 workers for the 816-MWe CNS-1 based 

25 on GEIS estimates (NPPD, 2008). The NPPD estimate appears reasonable and is consistent 

26 with trends calling for decreased workforces at power facilities. Even at a rural site like CNS-1, 

27 impacts are unlikely to be large. Operations impacts would likely be in the range of SMALL to 

28 MODERATE. 

29 8.1.6.3 Transportation 

30 During construction, approximately 2,000 workers would be commuting to the site. In addition to 

31 commuting workers, trucks would transport construction materials and equipment to the 

32 worksite increasing the amount of traffic on local roads. The increase in vehicular traffic would 

33 peak during shift changes resulting in temporary levels of service impacts and delays at 

34 intersections. Trains or barges could also be used to deliver large components to the CNS-1 

35 site, which could require the construction of a rail spur or a dock, as well as possible dredging in 

36 the Missouri River, if barge delivery is chosen. Transportation impacts are likely to be in the 

37 range of MODERATE to LARGE during construction. 

38 Transportation impacts would be greatly reduced after construction, but would not disappear 

39 during plant operations. The maximum number of plant operating personnel commuting to the 

40 CNS-1 would be approximately 200 workers. Frequent deliveries of coal and limestone by rail (if 

41 rail delivery is used) would add to the overall transportation impact. Onsite coal storage would 

42 make it possible to receive several trains per day. Limestone delivered by rail could also add 

43 additional traffic (though considerably less traffic than that generated by coal deliveries). 

44 The coal-fired alternative would likely create SMALL to MODERATE transportation impacts. 
Environmental Impacts of Alternatives 

February 2010 8-11 Draft NUREG-1437, Supplement 41 

1 8.1.6.4 Aesthetics 

2 The aesthetics impact analysis focuses on the degree of contrast between the coal-fired 

3 alternative and the surrounding landscape and the visibility of the coal plant. 

4 The coal-fired alternative would be up to 200 feet (61 m) tall with an exhaust stack up to 500 

5 feet (152 m) and may be visible offsite in daylight hours. The coal-fired plant, however, would be 

6 shorter than the current CNS-1 reactor building, which stands at 290 feet (88 m), with a release 

7 point at 325 feet (99 m). The assumed mechanical draft towers would generate condensate 

8 plumes, but these would be shorter than the plumes from the natural-draft tower alternative. 

9 Noise and light from plant operations, as well as lighting on plant structures, may be detectable 

10 offsite. 

11 Impacts could be moderated because the higher elevation ridges along the river valley may 

12 make it difficult to see or hear the plant outside of the river valley. Overall, aesthetic impacts 

13 associated with the coal-fired alternative would likely be designated as SMALL to MODERATE. 

14 8.1.6.5 Historic and Archaeological Resources 

15 Cultural resources are the indications of human occupation and use of the landscape as defined 

16 and protected by a series of Federal laws, regulations, and guidelines. Prehistoric resources are 

17 physical remains of human activities that predate written records; they generally consist of 

18 artifacts that may alone or collectively yield information about the past. Historic resources 

19 consist of physical remains that postdate the emergence of written records; in the United States, 

20 they are architectural structures or districts, archaeological objects, and archaeological features 

21 dating from 1492 and later. Ordinarily, sites less than 50 years old are not considered historic, 

22 but exceptions can be made for such properties if they are of particular importance, such as 

23 structures associated with the development of nuclear power or Cold War themes. American 

24 Indian resources are sites, areas, and materials important to American Indians for religious or 

25 heritage reasons. Such resources may include geographic features, plants, animals, 

26 cemeteries, battlefields, trails, and environmental features. The cultural resource analysis 

27 encompassed the power plant site and adjacent areas that could potentially be disturbed by the 

28 construction and operation of alternative power plants. 

29 The potential for historic and archaeological resources can vary greatly depending on the 

30 location of the proposed site. To consider a project's effects on historic and archaeological 

31 resources, any proposed areas will need to be surveyed to identify and record historic and 

32 archaeological resources, identify cultural resources (e.g., traditional cultural properties), and 

33 develop possible mitigation measures to address any adverse effects from ground disturbing 

34 activities. Studies will be needed for all areas of potential disturbance at the proposed plant site 

35 and along associated corridors where new construction will occur (e.g., roads, transmission 

36 corridors, rail lines, or other ROWs). In most cases, project proponents should avoid areas with 

37 the greatest sensitivity. 

38 CNS-1 is situated in an area where historic and archaeological resources could be located 

39 several feet beneath the ground surface. As noted in Section 4.9.6, NPPD conducted a Phase 

40 1A survey of the CNS-1 site in 2007 and 2008. NPPD has also developed a Cultural Resources 

41 Protection Plan which calls for surveys to be conducted by a qualified archaeologist in areas 

42 deemed sensitive prior to work commencing. The plan also includes an inadvertent discovery 

43 (stop work) provision to ensure that proper notification is taken to protect these resources 

44 should they be discovered. Since NPPD conducted a survey and has established a protection 

45 plan, the impact for a coal-fired alternative at the CNS-1 site would be designated as SMALL. 
Environmental Impacts of Alternatives 

Draft NUREG-1437, Supplement 41 8-12 February 2010 

1 8.1.6.6 Environmental Justice 

2 The environmental justice impact analysis evaluates the potential for disproportionately high and 

3 adverse human health and environmental effects on minority and low-income populations that 

4 could result from the construction and operation of a new coal-fired power plant. Adverse health 

5 effects are measured in terms of the risk and rate of fatal or nonfatal adverse impacts on human 

6 health. Disproportionately high and adverse human health effects occur when the risk or rate of 

7 exposure to an environmental hazard for a minority or low-income population is significant and 

8 exceeds the risk or exposure rate for the general population or for another appropriate 

9 comparison group. The minority and low-income populations are subsets of the general public 

10 residing around the site, and all are exposed to the same hazards generated from various 

11 power plant operations. 

12 Minority and low-income populations could be affected by the construction and operation of a 

13 new coal-fired power plant. For example, increased demand for rental housing during 

14 construction could disproportionately affect low-income populations. Nevertheless, impacts on 

15 minority and low-income populations from the construction and operation of a coal-fired power 

16 plant alternative could range from SMALL to MODERATE. 

17 8.1.7 Waste Management 

18 Coal combustion generates several waste streams including ash (a dry solid) and sludge (a 

19 semi-solid by-product of emission control system operation). The NRC staff estimates that an 

20 816-MWe power plant would generate annually a total of 326,000 tons (296,000 MT) of dry solid 

21 ash and scrubber sludge. Much of this waste would be recycled. Disposal of the remaining 

22 waste from the 20-year operation of this alternative would require approximately 141 acres (57 

23 ha). Disposal of the remaining waste could noticeably affect land use and ground water quality, 

24 but with a proper siting in accordance with the Title 132, Chapter 4 standards of the Nebraska 

25 Administrative Code (NAC), implementation of the monitoring and management practices, it 

26 would not destabilize resources. After closure of the waste site and revegetation, the land could 

27 be available for other uses. 

28 The impacts from waste generated during operation of this coal-fired alternative would be 

29 designated as MODERATE; the impacts would be clearly visible but would not destabilize 

30 important resources. 

31 Impacts from waste generated during the construction stage would be short-lived. The amount 

32 of the construction waste is small compared to the amount of waste generated during the 

33 operational stage, and most could be recycled. Overall, the impacts from waste generated 

34 during the construction stage would be designated as SMALL. 

35 The NRC staff, therefore, concludes that waste management impacts from construction and 

36 operation of this alternative would be MODERATE. 

37 Table 8-1 provides a summary of the environmental impacts of the supercritical coal-fired 

38 alternative compared to continued operation of CNS-1. 
Environmental Impacts of Alternatives 

February 2010 8-13 Draft NUREG-1437, Supplement 41 

1 Table 8-1. Summary of Environmental Impacts of the Supercritical Coal-Fired Alternative 

2 Compared to Continued Operation of CNS-1 

Supercritical Coal-Fired 

Generation Continued CNS-1 Operation 

Air quality MODERATE SMALL 

Ground water SMALL SMALL 

Surface water SMALL SMALL 

Aquatic and terrestrial resources SMALL to MODERATE SMALL 

Human health SMALL SMALL 

Socioeconomics SMALL to LARGE SMALL 

Waste management MODERATE SMALL 

3 8.2 NATURAL GAS-FIRED COMBINED-CYCLE GENERATION

4 In this section, the environmental impacts of natural gas-fired combined-cycle generation are 

5 evaluated at the CNS-1 site.

6 Natural gas fueled 22 percent of electric generation in the United States in 2007 (the most 

7 recent year for which data are available), accounting for the second greatest share of electrical 

8 power after coal (EIA, 2009a). Like coal-fired power plants, natural gas-fired plants may be 

9 affected by perceived or actual action to limit GHG emissions, although they produce markedly 

10 fewer GHGs per unit of electrical output than coal-fired plants. Natural gas-fired power plants 

11 are feasible, commercially available options for providing electrical generating capacity beyond 

12 CNS-1’s current license expiration. 

13 Combined-cycle power plants differ significantly from coal-fired and existing nuclear power 

14 plants. Combined-cycle power plants derive the majority of their electrical output from a 

15 gas-turbine cycle, and then generate additional power—without burning any additional fuel—

16 through a second, steam-turbine cycle. The first, gas turbine stage (similar to a large jet engine) 

17 burns natural gas which turns a driveshaft that powers an electric generator. The exhaust gas 

18 from the gas turbine is still hot enough, however, to boil water to steam. Ducts carry the hot 

19 exhaust to a heat recovery steam generator, which produces steam to drive a steam turbine and 

20 produce additional electrical power. The combined-cycle approach is significantly more efficient 

21 than any one cycle on its own; thermal efficiency can exceed 60 percent. Since the natural gas22 fired alternative derives much of its power from a gas turbine cycle, and because it wastes less 

23 heat than either the coal-fired alternative or the existing CNS-1, it requires significantly less 

24 cooling water and smaller cooling towers than the coal-fired alternative discussed in Section 8.1. 

25 In order to replace the 816-MWe that CNS-1 currently supplies, the NRC staff selected a gas26 fired alternative that uses two General Electric S107H combined-cycle generating units. While 

27 any number of commercially available combined-cycle units could be installed in a variety of 

28 combinations to replace the power currently produced by CNS-1, the S107H is a highly efficient 

29 model that will help to minimize environmental impacts. Other manufacturers, like Siemens, 

30 offer similarly high efficiency models. This gas-fired alternative produces a net 400 MWe per 

31 unit. Two units produce a total of 800 MWe, or nearly the same net output as the existing CNS32 1. 

33 The combined-cycle alternative operates at a heat rate of 5,690 British thermal units per kilowatt 

34 hours (BTU/kWh), or nearly 60 percent thermal efficiency (GE, 2007). As noted above, this gas-
Environmental Impacts of Alternatives 

Draft NUREG-1437, Supplement 41 8-14 February 2010 

1 fired alternative would require much less cooling water than CNS-1, because it operates at a 

2 higher thermal efficiency and because it requires much less water for steam cycle condenser 

3 cooling. Cooling towers for this alternative would likely be mechanical draft-type towers 

4 approximately 65 feet (20 m) high. 

5 In addition to cooling towers, other visible structures onsite include the turbine buildings and 

6 heat recovery steam generators (HRSGs) (which may be enclosed in a single building), two 

7 exhaust stacks, an electrical switchyard, and, possibly, equipment associated with a natural gas 

8 pipeline, like a compressor station. Based on GEIS estimates, NPPD indicated that this 800-

9 MWe plant would require approximately 90 acres (36 ha). 

This 800-MWe power plant would consume 34 billion ft3

 (964 million m3 10 ) of natural gas annually 

assuming an average heat content of 1,029 BTU/ft3 11 (EIA, 2009b). Natural gas would be 

12 extracted from the ground through wells, then treated to remove impurities (like hydrogen 

13 sulfide), and blended to meet pipeline gas standards, before being piped through the interstate 

14 pipeline system to the power plant site. This gas-fired alternative would produce relatively little 

15 waste, primarily in the form of spent catalysts used for emissions controls. 

16 Environmental impacts from the gas-fired alternative will be greatest during construction. Site 

17 crews will clear vegetation from the site, prepare the site surface, and begin excavation before 

18 other crews begin actual construction on the plant and any associated infrastructure, including a 

19 pipeline spur to serve the plant and electricity transmission infrastructure connecting the plant to 

20 existing transmission lines. Constructing the gas-fired alternative on NPPD property would allow 

21 the gas-fired alternative to make use of CNS-1’s existing transmission system. 

22 8.2.1.1 Air Quality 

23 Nemaha County, Nebraska is in EPA Region 7. All counties in the State of Nebraska are in 

24 attainment for all criteria pollutants, except Douglas County, which is a maintenance county for 

25 lead. A new gas-fired generating plant developed at the CNS-1 site would qualify as a new 

26 major-emitting industrial facility and require a New Source Review (NSR)/Prevention of 

27 Significant Deterioration of Air Quality review under CAA, adopted by Nebraska Department of 

28 Environmental Quality (NDEQ) in Title 129 of NAC (EPA, 2008). The natural gas-fired plant 

29 would need to comply with the standards of performance for electric utility steam generating 

30 units set forth in 40 CFR Part 60 Subpart Da. 

31 Subpart P of 40 CFR Part 51 contains the visibility protection regulatory requirements, including 

32 the review of the new sources that would be constructed in the attainment or unclassified areas 

33 and may affect visibility in any Federal Class I area. If a gas-fired alternative was located close 

34 to a mandatory Class I area, additional air pollution control requirements would imply. There are 

35 no mandatory Class I Federal areas in the State of Nebraska and the closest mandatory Class I 

36 Federal area is Hercules-Glades Wilderness Area, which is located 295 miles southeast from 

37 the CNS-1 in the State of Missouri. 

38 The staff projects the following emissions for a gas-fired alternative based on data published by 

39 the EIA, EPA, and on performance characteristics for this alternative and its emissions controls:

40 ● Sulfur oxides (SOx) – 60 tons (54 MT) per year 

41 ● Nitrogen oxides (NOx) – 192 tons (177 MT) per year 
Environmental Impacts of Alternatives 

February 2010 8-15 Draft NUREG-1437, Supplement 41 

1 ● Carbon monoxide (CO) – 40 tons (36 MT) per year 

2 ● Total suspended particles (TSP) – 34 tons (30 MT) per year 

3 ● Particulate matter (PM) PM10 – 34 tons (30 MT) per year 

4 ● Carbon dioxide (CO2) – 2,050,000 tons (1,860,000 MT) per year 

5 A new natural gas-fired plant would have to comply with Title IV of the CAA (42 U.S.C. §7651) 

6 reduction requirements for SO2 and NOx, which are main precursors of acid rain and the major 

7 cause of reduced visibility. Title IV establishes maximum SO2 and NOx emission rates from the 

8 existing plants and a system of the SO2 emission allowances that can be used, sold, or saved 

9 for future use by the new plants. 

10 8.2.1.2 Sulfur and Nitrogen Oxides 

11 As stated above, the new natural gas-fired alternative would produce 60.02 tons (54.45 MT) per 

12 year of SOx and 192.42 tons (176.56 MT) per year of NOx based on the use of the dry low NOx

13 combustion technology and use of the selective catalytic reduction (SCR) in order to 

14 significantly reduce NOx emissions. 

15 The new plant would be subjected to the continuous monitoring requirements of SOx, NOx, and 

16 CO2 specified in 40 CFR Part 75. The natural gas-fired plant would emit approximately 2.1 

17 million tons (approximately 1.9 million MT) per year of unregulated CO2 emissions. Currently, 

18 there is no required reporting of GHG emissions in Nebraska. 

19 8.2.1.3 Particulates 

20 The new natural gas-fired alternative would produce 33.54 tons (30.43 MT) per year of TSP, all 

21 of which would be emitted as PM10. 

22 8.2.1.4 Hazardous Air Pollutants 

23 The EPA issued in December 2000 regulatory findings (EPA, 2000a) on emissions of HAPs 

24 from electric utility steam-generating units, which identified that natural gas-fired plants emit 

25 HAPs such as arsenic, formaldehyde, and nickel, and stated that: 

26 Also in the utility RTC (Report to Congress), the EPA indicated that the impacts 

27 due to HAP emissions from natural gas-fired electric utility steam generating 

28 units were negligible based on the results of the study. The Administrator finds 

29 that regulation of HAP emissions from natural gas-fired electric utility steam 

30 generating units is not appropriate or necessary. 

31 The new natural gas-fired alternative would produce 33.25 tons (30.16 MT) per 

32 year of the TSP as PM10 emissions 

33 8.2.1.5 Construction Impacts 

34 Activities associated with the construction of the new natural gas-fired plant onsite or offsite 

35 CNS-1 would cause some additional, temporary air effects as a result of equipment emissions 

36 and fugitive dust from operation of the earth-moving and material handling equipment. 

37 Emissions from workers’ vehicles and motorized construction equipment exhaust would be 

38 temporary. The construction crews would employ dust-control practices in order to control and 

39 reduce fugitive dust. The NRC staff concludes that the impact of vehicle exhaust emissions and 
Environmental Impacts of Alternatives 

Draft NUREG-1437, Supplement 41 8-16 February 2010 

1 fugitive dust from operation of the earth-moving and material handling equipment would be 

2 SMALL. 

3 The overall air-quality impacts of a new natural gas-fired plant located at the CNS-1 site would 

4 be designated as SMALL to MODERATE. 

5 8.2.2 Ground Water Use and Quality 

6 The use of ground water for a natural gas-fired combined-cycle plant would likely be limited to 

7 supply wells for drinking water and possibly filtered service water. Total usage would likely be 

8 much less than CNS-1 because fewer workers would be onsite and because the gas-fired 

9 alternative would have fewer auxiliary systems requiring service water. 

10 No effects on ground water quality would be apparent except during the construction phase due 

11 to temporary dewatering and run-off control measures. Because of the temporary nature of 

12 construction and the likelihood of reduced ground water usage during operation, the impact of 

13 the coal-fired alternative would be designated as SMALL. 

14 8.2.3 Surface Water Use and Quality 

15 Maximum withdrawals of surface water from the Missouri River would be much less for a gasfired plant than the 668,000 gpm (2 m3 16 /s)) maximum currently used by CNS-1; however, by 

17 switching from the open-cycle cooling system currently used by CNS-1 to a closed-cycle cooling 

18 system used by the proposed alternative, consumptive water losses will increase. Since the 

19 consumptive loss will remain less than 0.1 percent of the average annual flow of the Missouri 

20 River, the NRC staff concludes the impact of surface water use would be designated as SMALL. 

21 A new gas-fired plant would be required to obtain an NPDES permit from the NDEQ for 

22 regulation of industrial wastewater, stormwater, and other discharges. Assuming the plant 

23 operates within the limits of this permit, the impact from any possible runoff cooling tower 

24 blowdown, stormwater discharge, and effluent discharges on surface water quality would be 

25 designated as SMALL. 

26 8.2.4 Aquatic and Terrestrial Ecology 

27 8.2.4.1 Aquatic Ecology 

28 Compared to the existing CNS-1 plant, aquatic ecology actually benefits from the onsite gas29 fired alternative, as the combined-cycle plant with cooling towers rejects significantly less heat 

30 to the environment, thus requiring less water. The number of fish and other aquatic organisms 

31 affected by impingement, entrainment, and thermal impacts will be less than those associated 

32 with license renewal because water consumption and heat rejected to the Missouri River are 

33 substantially lower. Some temporary impacts to aquatic organisms might occur due to any 

34 construction or effluent discharge to the river, but NRC assumes that the appropriate agencies 

35 would be monitoring and regulating such activities. Although the number of affected organisms 

36 would be substantially less than for license renewal, the NRC level of impact for license renewal 

37 is already small, and so NRC expects that the levels of impact for impingement, entrainment, 

38 and thermal effects would also be designated as SMALL. 
Environmental Impacts of Alternatives 

February 2010 8-17 Draft NUREG-1437, Supplement 41 

1 8.2.4.2 Terrestrial Ecology 

2 Constructing the natural gas alternative will require 90 acres (36 ha) of land. These land 

3 disturbances form the basis for impacts to terrestrial ecology. 

4 Impacts to terrestrial ecology will be minor because the selected site has been previously 

5 disturbed and is mostly used for agricultural activities. (Gas extraction and collection will also 

6 affect terrestrial ecology in offsite gas fields, although, much of this land is likely already 

7 disturbed by gas extraction, and the incremental effects of this alternative on gas field terrestrial 

8 ecology are difficult to gauge.) 

9 Construction of the two natural gas units and mechanical draft cooling towers could result in the 

10 loss of farmland and possible changes to drainage patterns of water into and out of the wetlands 

11 on the CNS-1 site, which could affect food supply and habitat of native wildlife. Land 

12 disturbance could also affect wetland vegetation, but these effects are not expected to be 

13 significant. Operation of the cooling towers would produce a visible plume and cause some 

14 deposition of dissolved solids on surrounding vegetation (including some wetlands) and soil 

15 from cooling tower drift; however, the GEIS indicates that the impact of cooling towers on 

16 agricultural crops is of small significance, and most of the land surrounding the cooling towers is 

17 farmland. 

18 Construction of the 40-mile gas pipeline could lead to a conversion of forested lands used by 

19 terrestrial wildlife to a mowed right-of-way (ROW) as well as the possible loss of cropland from 

20 agricultural production, which could impact wildlife that use the croplands as a food source 

21 (NPPD, 2008). Siting of the pipeline may occur partially in wetlands, which could impact wildlife 

22 that utilize wetlands habitat. Pipeline construction may fragment surrounding habitat and may 

23 increase edge habitat, which may have adverse impacts on forest interior dwelling species, 

24 including migratory songbirds. Threatened and endangered species may also be affected by 

25 construction of the gas pipeline. Impacts from construction of the pipeline are expected to be 

26 MODERATE. 

27 Based on this information, impacts to terrestrial resources could range from SMALL to 

28 MODERATE. 

29 8.2.5 Human Health 

30 Like the coal-fired alternative discussed above, a gas-fired plant would emit criteria air 

31 pollutants, but generally in smaller quantities (except NOx, which requires additional controls to 

32 reduce emissions). Human health effects of gas-fired generation are generally low, although in 

33 Table 8-2 of the GEIS (NRC, 1996), the NRC staff identified cancer and emphysema as 

34 potential health risks from gas-fired plants. NOx emissions contribute to ozone formation, which 

35 in turn contributes to human health risks. Emission controls on this gas-fired alternative maintain 

36 NOx emissions well below air quality standards established for the purposes of protecting 

37 human health, and emissions trading or offset requirements mean that overall NOx in the region 

38 will not increase. Health risks to workers may also result from handling spent catalysts that may 

39 contain heavy metals. 

40 Overall, human health risks to occupational workers and to members of the public from 

41 gas-fired power plant emissions sited at CNS-1 would be less than the risks described for a 

42 coal-fired alternative and therefore, would likely be designated as SMALL. 
Environmental Impacts of Alternatives 

Draft NUREG-1437, Supplement 41 8-18 February 2010 

1 8.2.6 Socioeconomics 

2 8.2.6.1 Land Use 

3 As discussed in Section 8.1.6, the GEIS generically evaluates the impacts of nuclear power 

4 plant operations on land use, both on and off each power plant site. The analysis of land use 

5 impacts focuses on the amount of land area that would be affected by the construction and 

6 operation of a two-unit natural gas-fired combined-cycle power plant at the CNS-1 site. 

7 Based on GEIS estimates, NPPD indicated that approximately 90 acres (36 ha) of land would 

8 be needed to support a natural gas-fired alternative to replace CNS-1 (NPPD, 2008). This 

9 amount of land use would include other plant structures and associated infrastructure, and is 

10 unlikely to exceed 90 acres (36 ha), excluding land for natural gas wells and collection stations. 

11 Land use impacts from construction would be designated as SMALL. 

12 In addition to onsite land requirements, land would be required offsite for natural gas wells and 

13 collection stations. Scaling from GEIS estimates, approximately 2,988 acres (1,209 ha) would 

14 be required for wells, collection stations, and pipelines to bring the gas to the plant. Most of this 

15 land requirement would occur on land where gas extraction already occurs. In addition, some 

16 natural gas could come from outside the United States and be delivered as liquefied gas. 

17 The elimination of uranium fuel for the CNS-1 could partially offset offsite land requirements. 

18 Scaling from GEIS estimates, the NRC staff estimated that approximately 816 acres (330 ha) 

19 would not be needed for mining and processing uranium during the operating life of the plant. 

20 Overall land use impacts from a gas-fired power plant would be in the range of SMALL to 

21 MODERATE. 

22 8.2.6.2 Socioeconomics 

23 Socioeconomic impacts are defined in terms of changes to the demographic and economic 

24 characteristics and social conditions of a region. For example, the number of jobs created by the 

25 construction and operation of a new natural gas-fired power plant could affect regional 

26 employment, income, and expenditures. Two types of jobs are created by this alternative: (1) 

27 construction-related jobs, which are transient, short in duration, and less likely to have a long28 term socioeconomic impact; and (2) operation-related jobs in support of power plant operations, 

29 which have the greater potential for permanent, long-term socioeconomic impacts. Workforce 

30 requirements of power plant construction and operations for the natural gas-fired power plant 

31 alternative were determined in order to measure their possible effect on current socioeconomic 

32 conditions. 

33 The socioeconomic impacts from constructing and operating a gas-fired plant would have little 

34 noticeable effect. Compared to the coal-fired alternative, the small size of the construction and 

35 operations workforce would have little or no socioeconomic impact. As discussed in Section 

36 8.1.6.2, the socioeconomic impact of operations of the coal-fired alternative would likely be in 

37 the range of SMALL to MODERATE. 

38 Based on GEIS estimates, NPPD projected a maximum construction workforce of 979 (NPPD, 

39 2008). During construction of a gas-fired plant, the communities surrounding the power plant 

40 site would experience increased demand for rental housing and public services. The relative 

41 economic effect of construction workers on local economy and tax base would vary over time. 
Environmental Impacts of Alternatives 

February 2010 8-19 Draft NUREG-1437, Supplement 41 

1 After construction, local communities may be temporarily affected by the loss of construction 

2 jobs and associated loss in demand for business services, and the rental housing market could 

3 experience increased vacancies and decreased prices. As noted in the GEIS, the 

4 socioeconomic impacts at a rural construction site could be larger than at an urban site, 

5 because the workforce may have to move to be closer to the construction site. The impact of 

6 construction on socioeconomic conditions could range from SMALL to MODERATE. 

7 Based on GEIS estimates, NPPD estimated a power plant operations workforce of 

8 approximately 125 (NPPD, 2008). The NPPD estimate appears reasonable and is consistent 

9 with trends toward lowering labor costs by reducing the size of power plant operations 

10 workforces. The small number of operations workers could have a noticeable effect on 

11 socioeconomic conditions in the region, however, socioeconomic impacts associated with the 

12 operation of a gas-fired power plant at the CNS-1 site would be designated as SMALL. 

13 8.2.6.3 Transportation 

14 Transportation impacts associated with construction and operation of a two-unit gas-fired power 

15 plant would consist of commuting workers and truck deliveries of construction materials to the 

16 CNS-1 site. During construction, up to 1,000 workers would be commuting to the site. In 

17 addition to commuting workers, trucks would transport construction materials and equipment to 

18 the worksite increasing the amount of traffic on local roads. The increase in vehicular traffic 

19 would peak during shift changes resulting in temporary levels of service impacts and delays at 

20 intersections. Pipeline construction and modification to existing natural gas pipeline systems 

21 could also have an impact. 

22 During plant operations, transportation impacts would almost disappear. According to NPPD, 

23 approximately 125 workers would be needed to operate the gas-fired power plant. Since fuel is 

24 transported by pipeline, most transportation infrastructure would experience little increased use 

25 from plant operations. 

26 The transportation infrastructure would experience little to no increased use from plant 

27 operations. Overall, the gas-fired alternative would have a SMALL impact on transportation 

28 conditions in the region around the CNS-1. 

29 8.2.6.4 Aesthetics 

30 The aesthetics impact analysis focuses on the degree of contrast between the natural 

31 gas-fired alternative and the surrounding landscape and the visibility of the gas-fired plant. 

32 The two gas-fired units could be approximately 100 feet (30 m) tall, with two exhaust stacks up 

33 to 175 feet (53 m) tall. Some structures may require aircraft warning lights. Aesthetic impacts 

34 may be mitigated as higher elevations and vegetation along the river valley could make it 

35 difficult to see or hear the plant outside of the river valley. Power plant infrastructure would 

36 generally be smaller and less noticeable than the CNS-1, which has a reactor building height of 

37 290 feet (88 m). Mechanical draft cooling towers would generate condensate plumes and 

38 operational noise. Noise during power plant operations would be limited to industrial processes 

39 and communications. Pipelines delivering natural gas fuel could be audible offsite near 

40 compressors. 

41 In general, aesthetic changes would be limited to the immediate vicinity of the CNS-1. Impacts 

42 would likely be designated as SMALL to MODERATE. 
Environmental Impacts of Alternatives 

Draft NUREG-1437, Supplement 41 8-20 February 2010 

1 8.2.6.5 Historic and Archaeological Resources 

2 The same considerations as discussed in Section 8.1.6.4 for impact of the coal-fired alternative 

3 on historic and archaeological resources apply to the gas-fired alternative. 

4 The impact for a gas-fired alternative at the CNS-1 site would be SMALL. 

5 8.2.6.6 Environmental Justice 

6 The environmental justice impact analysis evaluates the potential for disproportionately high and 

7 adverse human health and environmental effects on minority and low-income populations that 

8 could result from the construction and operation of a new natural gas-fired power plant. Adverse 

9 health effects are measured in terms of the risk and rate of fatal or nonfatal adverse impacts on 

10 human health. Disproportionately high and adverse human health effects occur when the risk or 

11 rate of exposure to an environmental hazard for a minority or low-income population is 

12 significant and exceeds the risk or exposure rate for the general population or for another 

13 appropriate comparison group. The minority and 

14 low-income populations are subsets of the general public residing around the site, and all are 

15 exposed to the same hazards generated from various power plant operations. 

16 Minority and low-income populations could be affected by the construction and operation of a 

17 new natural gas-fired power plant. Some of these effects have been identified in resource areas 

18 discussed in this section. For example, increased demand for rental housing during construction 

19 could disproportionately affect low-income populations. Nevertheless, impacts on minority and 

20 low-income populations from the construction and operation of a natural gas-fired power plant 

21 alternative could range from SMALL to MODERATE. 

22 8.2.7 Waste Management 

23 During the construction stage of the natural gas-fired combined-cycle generation alternative, 

24 land clearing and other construction activities would generate waste that can be recycled, 

25 disposed onsite or shipped to the offsite waste disposal facility. Because the alternative would 

26 be constructed on the previously disturbed CNS-1 site, the amounts of wastes produced during 

27 land clearing would be reduced. 

28 During operational stage, spent SCR catalysts, which are used to control NOx emissions from 

29 the natural gas-fired plants, would make up the majority of the waste generated by this 

30 alternative. 

31 The NRC staff concluded in the GEIS (NRC, 1996), that natural gas-fired plant would generate 

32 minimal waste and the waste impacts would be SMALL for a natural gas-fired alternative 

33 located at CNS-1 site or offsite. 

34 Table 8-2 provides a summary of the environmental impacts of the natural gas-fired alternative 

35 compared to continued operation of CNS-1. 
Environmental Impacts of Alternatives 

February 2010 8-21 Draft NUREG-1437, Supplement 41 

1 Table 8-2. Summary of Environmental Impacts of the Natural Gas-Fired Combined-Cycle 

2 Generation Alternative Compared to Continued Operation of CNS-1 

Natural Gas Combined-Cycle 

Generation Continued CNS-1 Operation 

Air quality SMALL to MODERATE SMALL 

Ground water SMALL SMALL 

Surface water SMALL SMALL 

Aquatic and terrestrial resources SMALL to MODERATE SMALL 

Human health SMALL SMALL 

Socioeconomics SMALL to MODERATE SMALL 

Waste management SMALL SMALL 

3 8.3 COMBINATION ALTERNATIVE 

4 In this section, the environmental impacts of a combination of alternatives are evaluated. This 

5 combination will include a portion of the combined-cycle gas-fired capacity identified in Section 

6 8.2, an energy conservation capacity component, and a wind power component. This alternative 

7 requires new construction of a single gas-fired unit installed at the CNS-1 site and the 

8 construction of roughly 250 wind turbines at an offsite location, or several different offsite 

9 locations. 

10 In this alternative, a portion of CNS-1’s output—250 MWe—would be replaced by conservation. 

11 Inclusion of this conservation component of the alternative is based on Nebraska’s energy 

12 efficiency goals for the year 2012. Wind turbines constructed offsite will account for roughly 150 

13 MWe of capacity and 400 MWe will come from one GE S107H combined-cycle power plant. The 

14 only major construction anticipated is at the current CNS-1 site where the combined-cycle gas15 fired power plant would be constructed and the wind turbine construction at an offsite location 

16 (including the right of way for new transmission lines). No major construction should be 

17 necessary for the conservation portion. 

18 The appearance of the gas-fired facility would be similar to that of the full gas-fired alternative 

19 considered in Section 8.2, though only one unit would be constructed. The NRC staff estimates 

20 that it would require about 50 percent of the space necessary for the alternative considered in 

21 Section 8.2, and that all construction effects—as well as operational aesthetic, fuel-cycle, air 

22 quality, socioeconomic, land use, environmental justice, and water consumption effects—will 

23 scale accordingly. 

24 8.3.1 Air Quality 

25 Nemaha County, Nebraska, where CNS-1 is located, is in EPA Region 7. All counties in the 

26 State of Nebraska are in attainment for all criteria pollutants. Douglas County is a maintenance 

27 county for lead. NDEQ is responsible for managing and monitoring air quality in the State of 

28 Nebraska. 

29 This alternative is a combination of one 400-MWe natural gas-fired combined-cycle generating 

30 unit, constructed onsite, 250 MWe equivalent of conservation and demand-side management, 

31 and 500 MWe of wind capacity constructed offsite, possibly at several different locations. 
Environmental Impacts of Alternatives 

Draft NUREG-1437, Supplement 41 8-22 February 2010 

1 A new gas-fired generating plant on the CNS-1 site would qualify as a new major-emitting 

2 industrial facility and require an NSR under CAA. Nebraska air quality regulations require s that 

3 a permit must be obtained before construction of the new major-emitting industrial facility which 

4 will be issued only if the new plant includes pollution control measures that reflect the best 

5 available control technology (BACT). The natural gas-fired plant must comply with the standards 

6 of performance for electric utility steam generating units set forth in 40 CFR Part 60 Subpart Da. 

7 Subpart P of 40 CFR Part 51 contains the visibility protection regulatory requirements, including 

8 the review of the new sources that would be constructed in the attainment or unclassified areas 

9 and may affect visibility in any Federal Class I area (40 CFR §51.307). If a gas-fired unit were 

10 located close to a mandatory Class I area, additional air pollution control requirements would 

11 imply. There are no mandatory Class I Federal areas in the State of Nebraska. The closest is 

12 Hercules-Glades Wilderness Area, which is located 295 miles southeast of CNS-1 in the State 

13 of Missouri. 

14 According to published EIA data, the EPA emission factors, performance characteristics for this 

15 alternative and implemented emission controls, emissions from the one natural gas-fired unit 

16 with a capacity of 400 MWe built at CNS-1 site would be: 

17 ● Sulfur oxides (SOx) – 30 tons (27 MT) per year 

18 ● Nitrogen oxides (NOx) (with SCR) – 96 tons (87 MT) per year 

19 ● Carbon monoxide (CO) – 20 tons (18 MT) per year 

20 ● Total suspended particles (TSP) – 17 tons (15 MT) per year 

21 ● Particulate matter (PM) PM10 – 17 tons (15 MT) per year 

22 ● Carbon dioxide (CO2) – 1,030,000 tons (964,000 MT) per year 

23 The natural gas-fired component of this alternative would emit 17 tons (15. MT) per year of 

24 particulate matter having an aerodynamic diameter less than, or equal to, 10 μm (PM10). 

25 In December 2000, the EPA issued regulatory findings (EPA, 2000) on emissions of hazardous 

26 air pollutants from electric utility steam-generating units. The findings show that natural gas-fired 

27 plants emit HAPs such as arsenic, formaldehyde, and nickel, and state that: 

28 Also in the utility RTC (Report to Congress, the impacts due to HAP emissions 

29 from natural gas-fired electric utility steam generating units were negligible based 

30 on the results of the study. The Administrator finds that regulation of HAP 

31 emissions from natural gas-fired electric utility steam generating units is not 

32 appropriate or necessary. 

33 The new natural gas-fired alternative would produce 16.77 tons (15.21 MT) per year of TSP, all 

34 of which would be emitted as PM10 emissions. 

35 The natural gas-fired plant would have to comply with CAA reduction requirements for SO2 and 

36 NOx (42 U.S.C. §7401 et seq.), which are the main precursors of acid rain and major causes of 

37 reduced visibility. Title IV establishes maximum SO2 and NOx emission rates from the existing 
Environmental Impacts of Alternatives 

February 2010 8-23 Draft NUREG-1437, Supplement 41 

1 plants and a system of the SO2 emission allowances that can be used, sold, or saved for future 

2 use by the new plants. 

3 As stated above, the new natural gas-fired unit would produce 30.01 tons (27.23 MT) per year 

4 of SOx and 96.21 tons (87.28 MT) per year of NOx based on the use of the dry low NOx

5 combustion technology and use of the SCR in order to significantly reduce NOx emissions. 

6 The natural gas-fired component of this alternative would be subjected to the continuous 

7 monitoring requirements of SO2, NOx, and CO2 specified in 40 CFR Part 75. The natural gas8 fired plant would emit approximately 1.0 million tons (approximately 0.9 million MT) per year of 

9 unregulated CO2 emissions. In response to the Consolidated Appropriations Act of 2008, the 

10 EPA has proposed a rule that requires mandatory reporting of GHG emissions from large 

11 sources (applicable to the presented alternative) in the United States that would allow collection 

12 of accurate and comprehensive emissions data to inform future policy decisions. EPA proposes 

13 that suppliers of fossil fuels or industrial GHGs, manufacturers of vehicles and engines, and 

14 facilities that emit 25,000 MT or more per year of GHG emissions submit annual reports to the 

15 EPA. The gases covered by the proposed rule are CO2, CH4, N2O, HFC, PFC, SF6 and other 

16 fluorinated gases including NF3 and HFE. NPPD states in the “Statement on Addressing the 

17 Challenge of Global Climate Change” that it is voluntarily engaged in lowering the GHG 

18 emissions (NPPD, 2008). In the “2008 Integrated Resource Plan,” NPPD outlines the 

19 environmental goals of the company with emphasis on lowering GHG emissions and obtaining 

20 10 percent of the energy supply from renewable resources by 2020, wind being primarily the 

21 source of power (NPPD, 2008). 

22 There would be no operating emissions from the wind or conservation components of the 

23 combination alternative. 

24 Activities associated with the construction of the new natural gas-fired plant onsite at CNS-1 and 

25 wind turbines offsite would cause some additional air effects as a result of equipment emissions 

26 and fugitive dust from operation of the earth-moving and material handling equipment. Vehicles 

27 of workers and construction motorized equipment exhaust emissions would be temporary. The 

28 construction crews would employ dust-control practices in order to control and reduce fugitive 

29 dust, which would be temporary in nature. The NRC staff concludes that the impact of vehicle 

30 exhaust emissions and fugitive dust from operation of earth-moving and material handling 

31 equipment would be designated as SMALL. Implementation of the conservation portion of this 

32 alternative would have no noticeable effects on air quality, though some weatherization 

33 programs may cause existing indoor air quality problems to become worse. 

34 The overall air-quality impacts of the combination alternative consisting of a natural gas-fired 

35 plant located at CNS-1 site, energy conservation, and an offsite wind component would be in 

36 the range of SMALL to MODERATE. 

37 8.3.2 Ground Water Use and Quality 

38 If the onsite gas-fired plant continued to use ground water for drinking water and service water, 

39 the total usage would likely be much less than CNS-1 uses, because fewer workers are onsite 

40 and because the gas-fired unit would have fewer auxiliary systems requiring service water. The 

41 current average withdrawal rate is 250 gpm, and pumping tests indicate this rate would not 

42 cause an effect on nearby supply wells. A reduction in this withdrawal rate means that impacts 

43 of the combination alternative would remain SMALL. 
Environmental Impacts of Alternatives 

Draft NUREG-1437, Supplement 41 8-24 February 2010 

1 8.3.3 Surface Water Use and Quality 

2 Using a combined alternative with conservation as a major component will reduce the amount of 

3 surface water consumed for cooling purposes from the already low consumption of the wholly 

4 gas-fired alternative considered in Section 8.2. The maximum consumptive use would be 

5 reduced to a fraction of the surface water withdrawn by the open-cycle cooling system currently 

6 in use by CNS-1. This represents less than 0.001 percent of the average annual flow rate in the 

7 Missouri River. The impact of this withdrawal would be SMALL. 

8 8.3.4 Aquatic and Terrestrial Ecology 

9 8.3.4.1 Aquatic Ecology 

10 In order to minimize impacts, NRC assumes that the cooling system for this gas-fired plant 

11 would involve closed-cycle cooling. The wind and conservation components would have no 

12 associated impingement, entrainment, and thermal impacts. The number of fish and other 

13 aquatic resource organisms affected by impingement, entrainment, and other impacts will be 

14 less than those associated with license renewal because water consumption and heat injected 

15 to the Missouri River would be substantially lower. Some temporary impacts to aquatic 

16 organisms might occur due to any construction that might occur or due to any effluent 

17 discharges to the river, but these activities would be monitored by the NDEQ under the project’s 

18 NPDES permit. Although the number of affected organisms would be substantially less than for 

19 license renewal, the NRC level of impact for license renewal is already designated as SMALL, 

20 and so NRC expects that the impact for impingement, entrainment, and thermal effects would 

21 also be SMALL. 

22 8.3.4.2 Terrestrial Ecology 

23 A combination alternative of a single natural gas-fired unit, a system using wind energy, and 

24 energy conservation would make use of existing disturbed land and possibly some farmland at 

25 the CNS-1 site for the natural gas unit and the mechanical draft cooling tower. This alternative 

26 would also require land offsite for the gas pipeline and would require additional land offsite to 

27 accommodate the number of turbines necessary in a wind farm to offset the power generated by 

28 CNS-1. 

29 This alternative would use a portion of the existing plant site land, switchyard, and transmission 

30 line system for construction of the gas-fired unit. Approximately 45 ac (18 ha) of land would be 

31 required on the CNS-1 site to support a 400 MWe natural gas plant. 

32 Impacts to terrestrial ecology from onsite construction of a single gas-fired unit with one 

33 mechanical draft cooling tower would be less than the impacts described for the two-unit gas34 fired alternative. The impacts to farmland onsite would be approximately one-half of the impacts 

35 of the two-unit natural gas plant alternative. The drainage patterns of the wetland areas onsite 

36 may also be impacted, though again to a lesser degree than the two-unit gas alternative. These 

37 onsite impacts are expected to be minor. Impacts to terrestrial ecology from offsite construction 

38 of the 40-mile (64-km) long gas pipeline for a single gas-fired unit would be the same as for the 

39 two gas-fired unit alternative previously discussed (NPPD, 2008). 

40 Based upon data in the GEIS, the wind farm component of the combination alternative 

41 producing 500 MWe of electricity would require approximately 32,000 acres (12,950 ha) spread 

42 over several offsite locations, with approximately 125 acres (51 ha) in actual use. The remainder 
Environmental Impacts of Alternatives 

February 2010 8-25 Draft NUREG-1437, Supplement 41 

1 of the land would remain in agriculture. Additional land may be needed for construction of 

2 transmission line corridors to connect to existing transmission line corridors. 

3 Impacts to terrestrial ecology from construction of the wind farm portion of the combination 

4 alternative and any needed transmission lines could include loss of terrestrial habitat, an 

5 increase in habitat fragmentation and a corresponding increase in edge habitat, and may impact 

6 threatened and endangered species. The GEIS notes that habitat fragmentation may lead to a 

7 decline in migrant bird populations. Bird mortality would increase from construction of the wind 

8 farm, although proper site selection for the wind farm could help to reduce bird strikes. The 

9 GEIS noted that wind farms typically do not cause significant adverse impacts to bird 

10 populations, although thousands of acres of wildlife habitat or agricultural land could be 

11 impacted, and disruptions could occur to wildlife migratory routes (NRC, 1996). 

12 Based on this information, impacts to terrestrial resources could range from MODERATE to 

13 LARGE. 

14 8.3.5 Human Health 

15 The human health risks from a combination of alternatives include the effects already discussed 

16 in Section 8.2.5 for the combined cycle gas-fired plant. The GEIS (NRC, 1996) notes that the 

17 environmental impacts of conservation and a demand-side management alternative are likely to 

18 be centered on indoor air quality. This is due to increased weatherization of the home in the 

19 form of extra insulation and reduced air turnover rates from the reduction in air leaks; however, 

20 the actual impact from the conservation alternative is highly site specific and not yet well21 established. For wind capacity, the GEIS notes that, except for a potential small number of 

22 occupational injuries, human health would not be affected by routine operations. 

23 The human health risks from the combination of alternatives, although uncertain, are considered 

24 to be SMALL to MODERATE given that the construction and operation of the facilities are 

25 expected to comply with health-based Federal and State safety and emission standards. 

26 8.3.6 Socioeconomics 

27 8.3.6.1 Land Use 

28 The GEIS generically evaluates the impacts of nuclear power plant operations on land use both 

29 on and off each power plant site. The analysis of land use impacts for combination alternative 

30 focuses on the amount of land area that would be affected by the construction and operation of 

31 a single natural gas-fired unit power plant at the CNS-1 site and at an offsite wind energy 

32 generating facility, and demand-side energy conservation. 

33 Based on GEIS estimates, approximately 45 acres (18 ha) would be needed to support the 

34 single natural gas-fired unit portion of the combination alternative. Land use impacts from 

35 construction of the natural gas-fired power plant at CNS-1 would be designated as SMALL. 

36 In addition to onsite land requirements, land would be required offsite for natural gas wells and 

37 collection stations. Scaling from GEIS estimates, the natural gas-fired power plant at the CNS-1 

38 could require 1,469 acres (594 ha) for wells, collection stations, and pipelines to bring the gas to 

39 the facility. Most of this land requirement would occur on land where gas extraction already 

40 occurs. In addition, some natural gas could come from outside of the United States and be 

41 delivered as liquefied gas. 
Environmental Impacts of Alternatives 

Draft NUREG-1437, Supplement 41 8-26 February 2010 

1 The wind farm component of the combination alternative producing 500 MWe of electricity 

2 would require approximately a 32,000-acre (12,950-ha) spread over several locations with 

3 approximately 125 acres (51 ha) in actual use. 

4 Land use impacts of an energy efficiency alternative would be designated as SMALL. Quickly 

5 replacing and disposing old inefficient equipment could generate waste material and increase 

6 the size of landfills; however, given the time for program development and implementation, the 

7 cost of replacements, and the average life of equipment, the replacement process would 

8 probably be gradual. Older equipment would simply be replaced by more efficient equipment 

9 (especially in the case of frequently replaced items, such as light bulbs). In addition, many items 

10 (such as home appliances and industrial equipment) have recycling value and would probably 

11 not be disposed of in landfills. 

12 The elimination of uranium fuel for CNS-1 could partially offset offsite land requirements. 

13 Scaling from GEIS estimates, approximately 816 acres (330 ha) would not be needed for mining 

14 and processing uranium during the operating life of the plant. Overall land use impacts from the 

15 combination alternative would range from SMALL to MODERATE. 

16 8.3.6.2 Socioeconomics 

17 As previously discussed, socioeconomic impacts are defined in terms of changes to the 

18 demographic and economic characteristics and social conditions of a region. For example, the 

19 number of jobs created by the construction and operation of a new single natural 

20 gas-fired power plant at CNS-1 and the wind farm could affect regional employment, income, 

21 and expenditures. Job creation is characterized by two types: (1) construction-related jobs, 

22 which are transient, short in duration, and less likely to have a long-term socioeconomic impact; 

23 and (2) operation-related jobs in support of power generating operations, which have a greater 

24 potential for permanent, long-term socioeconomic impacts. The NRC staff conducted 

25 evaluations of construction and operations workforce requirements in order to measure their 

26 effect on current socioeconomic conditions. 

27 Based on GEIS projections and a workforce of 1,200 for a 1,000-MWe plant, a single 400 MWe 

28 unit at CNS-1 requires a peak estimated construction workforce of 490. Additional estimated 

29 construction workforce requirements for this combination alternative include 300 construction 

30 workers for the wind farm. The number of additional workers would cause a short-term increase 

31 in the demand for services and temporary (rental) housing in the region around the construction 

32 site. 

33 After construction and depending on the size of the community, some local communities may be 

34 temporarily affected by the loss of the construction jobs and associated loss in demand for 

35 business services. The rental housing market could also experience increased vacancies and 

36 decreased prices. The impact of construction on socioeconomic conditions would be designated 

37 as SMALL. 

38 Following construction, a single-unit gas-fired power plant at CNS-1 could provide up to 63 jobs, 

39 based on NPPD estimates, or up to 64 jobs, based on GEIS estimates. Additional estimated 

40 operations workforce requirements for this combination alternative include 50 operations 

41 workers for the wind farm. Given the small numbers of operations workers at these facilities, 

42 socioeconomic impacts associated with the operation of the natural gas-fired power plant at 

43 CNS-1 and the wind farm would be designated as SMALL. 
Environmental Impacts of Alternatives 

February 2010 8-27 Draft NUREG-1437, Supplement 41 

1 Socioeconomic effects of an energy efficiency program would be SMALL. As noted in the GEIS, 

2 the program would require additional workers. Lower-income families could benefit from 

3 weatherization and insulation programs. This effect would be greater than the effect for the 

4 general population because low-income households experience home energy burdens more 

5 than four times larger than the average household (OMB, 2007). 

6 8.3.6.3 Transportation 

7 Transportation impacts would be SMALL because the number of employees commuting to the 

8 CNS-1 site, where the gas-fired portion is located, would be small. Any transportation effects 

9 from the energy efficiency alternative would be widely distributed across the state, and would 

10 not be noticeable. 

11 Construction and operation of a natural gas-fired power plant and wind farm would increase the 

12 number of vehicles on the roads in the vicinity of these facilities. During construction, cars and 

13 trucks would deliver workers, materials, and equipment to the worksites. The increase in 

14 vehicular traffic would peak during shift changes resulting in temporary levels of service impacts 

15 and delays at intersections. Pipeline construction and modification to existing natural gas 

16 pipeline systems could also have an impact. Highway delivery of large wind farm components 

17 may also cause impacts to traffic. 

18 During plant operations, transportation impacts would almost disappear. Given the small 

19 numbers of operations workers at these facilities, levels of service impacts on local roads from 

20 the operation of the natural gas-fired power plant at CNS-1 and at the wind farm, would be 

21 SMALL. Transportation impacts at the wind farm site would also depend on current road 

22 capacities and average daily traffic volumes. 

23 8.3.6.4 Aesthetics 

24 The aesthetics impact analysis focuses on the degree of contrast between the surrounding 

25 landscape and the visibility of the power plant. 

26 A single natural gas-fired unit located at CNS-1 would be approximately 100 feet (30 m) tall with 

27 an exhaust stack of at least 175 feet (53 m) tall, which is less noticeable than the current CNS-1 

28 reactor building at 290 feet (88 m). The impact would be moderated as higher elevations and 

29 vegetation along the river valley could make it difficult to see or hear the power plant outside of 

30 the river valley. Power plant infrastructure would generally be smaller and less noticeable than 

31 the CNS-1 containment and turbine buildings. Mechanical draft cooling towers (if used) would 

32 generate condensate plumes and operational noise, which during power plant operations would 

33 be limited to noise from industrial processes and communications. In addition to power plant 

34 structures, construction of natural gas pipelines would have a short-term impact. Noise from the 

35 pipelines could be audible offsite near compressors. 

36 Impacts from energy efficiency programs would be SMALL. Some noise impacts could occur in 

37 instances of energy efficiency upgrades to major building systems, although this impact would 

38 be intermittent and short-lived. 

39 In general, aesthetic changes would be limited to the immediate vicinity of the CNS-1 site and 

40 the wind farm facilities. The wind farm would have the greatest aesthetic effect. Compared to a 

41 fossil-fueled power plant unit on 46 to 1,400 acres, the 250 wind turbines at over 300 feet (100 

42 m) tall and spread across multiple sites covering 32,000 acres (13,000 ha) may, in some 

43 locations, dominate the view and be a major focus of viewer attention. The overall impact, 
Environmental Impacts of Alternatives 

Draft NUREG-1437, Supplement 41 8-28 February 2010 

1 however, would depend on the sensitivity of the people living around the area of the site; 

2 therefore, overall aesthetic impacts from the construction and operation of this combination 

3 alternative would be SMALL to MODERATE. 

4 8.3.6.5 Historic and Archaeological Resources 

5 Cultural resources are the indications of human occupation and use of the landscape as defined 

6 and protected by a series of Federal laws, regulations, and guidelines. Prehistoric resources are 

7 physical remains of human activities that predate written records; they generally consist of 

8 artifacts that may alone or collectively yield information about the past. Historic resources 

9 consist of physical remains that postdate the emergence of written records; in the United States, 

10 they are architectural structures or districts, archaeological objects, and archaeological features 

11 dating from 1492 and later. Ordinarily, sites less than 50 years old are not considered historic, 

12 but exceptions can be made for such properties if they are of particular importance, such as 

13 structures associated with the development of nuclear power or Cold War themes. American 

14 Indian resources are sites, areas, and materials important to American Indians for religious or 

15 heritage reasons. Such resources may include geographic features, plants, animals, burial 

16 grounds, battlefields, trails, and environmental features. The cultural resource analysis 

17 encompassed the power plant site and adjacent areas that could potentially be disturbed by the 

18 construction and operation of alternative power plants. 

19 The potential for historic and archaeological resources can vary greatly depending on the 

20 location of the proposed site. To consider a project's effects on historic and archaeological 

21 resources, any proposed areas will need to be surveyed to identify and record historic and 

22 archaeological resources, identify cultural resources (e.g., traditional cultural properties), and 

23 develop possible mitigation measures to address any adverse effects from ground disturbing 

24 activities. Studies will be needed for all areas of potential disturbance at the proposed plant site 

25 and along associated corridors where new construction will occur (e.g., roads, transmission 

26 corridors, rail lines, or other ROWs). In most cases, project proponents should avoid areas with 

27 the greatest sensitivity. 

28 The impact for a single-unit natural gas-fired alternative at the CNS-1 site would be SMALL. As 

29 noted in Section 4.9.6, NPPD conducted a Phase 1A survey of the CNS-1 site in 2007 and 

30 2008. NPPD has also developed a Cultural Resources Protection Plan which calls for surveys to 

31 be conducted by a qualified archaeologist in areas deemed sensitive prior to work commencing. 

32 The plan also includes an inadvertent discovery (stop work) provision to ensure that proper 

33 notification is taken to protect these resources should they be discovered. Depending on the 

34 resource richness of an alternative site or sites ultimately chosen for the wind farm alternative, 

35 impacts could range from SMALL to MODERATE. 

36 Impacts to historic and archaeological resources from implementing the energy efficiency 

37 programs would be SMALL. A conservation alternative would not affect land use or historical or 

38 cultural resources onsite or elsewhere in the state.

39 8.3.6.6 Environmental Justice 

40 The environmental justice impact analysis evaluates the potential for disproportionately high and 

41 adverse human health and environmental effects on minority and low-income populations that 

42 could result from the construction and operation of a new natural gas-fired power plant and wind 

43 farm. Adverse health effects are measured in terms of the risk and rate of fatal or nonfatal 

44 adverse impacts on human health. Disproportionately high and adverse human health effects 

45 occur when the risk or rate of exposure to an environmental hazard for a minority or low-income 
Environmental Impacts of Alternatives 

February 2010 8-29 Draft NUREG-1437, Supplement 41 

1 population is significant and exceeds the risk or exposure rate for the general population or for 

2 another appropriate comparison group. The minority and low-income populations are subsets of 

3 the general public residing around the site, and all are exposed to the same hazards generated 

4 from various power plant operations. 

5 Minority and low-income populations could be affected by the construction and operation of a 

6 new natural gas-fired power plant and wind farm. Some of these effects have been identified in 

7 resource areas discussed in this section. For example, increased demand for rental housing 

8 during construction could disproportionately affect low-income populations. 

9 Weatherization programs could target low-income residents as a cost-effective energy efficiency 

10 option since low-income populations tend to spend a larger proportion of their incomes paying 

11 utility bills (according to the Office of Management and Budget (OMB), low income populations 

12 experience energy burdens more than four times as large as those of average households 

13 (OMB, 2007)). Impacts to minority and low-income populations from energy efficiency programs 

14 would be SMALL, depending on program design and enrollment. 

15 Impacts on minority and low-income populations under the combination alternative could range 

16 from SMALL to MODERATE, due to the small number of workers needed to construct and 

17 operate the natural gas-fired power plant and wind farm. 

18 8.3.7 Waste Management 

19 During the construction stage of this combination of alternative, land clearing and other 

20 construction activities would generate wastes that can be recycled, disposed onsite or shipped 

21 to the offsite waste disposal facility. During the operational stage, spent SCR catalysts, which 

22 are used to control NOx emissions from the natural gas-fired plants, would make up the majority 

23 of the waste generated by this alternative. 

24 There will be an increase in wastes generated during installation or implementation of 

25 conservation measures, such as appropriate disposal of old appliances, installation of control 

26 devices and building modifications. New and existing recycling programs would help to minimize 

27 the amount of generated waste. 

28 The NRC staff concludes that overall waste impacts from the combination of the natural gas29 fired unit constructed onsite, wind capacity, and conservation are SMALL. 

30 Table 8-3 provides a summary of the environmental impacts of the combined alternative 

31 compared to continued operation of CNS-1. 
Environmental Impacts of Alternatives 

Draft NUREG-1437, Supplement 41 8-30 February 2010 

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

2 to Continued Operation of CNS 1

Combination Alternative Continued CNS-1 Operation 

Air quality SMALL to MODERATE SMALL 

Ground water SMALL SMALL 

Surface water SMALL SMALL 

Aquatic and terrestrial resources SMALL to LARGE SMALL 

Human health SMALL to MODERATE SMALL 

Socioeconomics SMALL to MODERATE SMALL 

Waste management SMALL SMALL 

3 8.4 ALTERNATIVES CONSIDERED BUT DISMISSED 

4 In this section, the NRC staff presents the alternatives it initially considered for analysis as 

5 alternatives to license renewal of CNS-1, but later dismissed due to technical, resource 

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

7 likely to continue to exist when the existing CNS-1 license expires. Under each of the following 

8 technology headings, the NRC staff indicates why it dismissed each alternative from further 

9 consideration. Offsite coal and gas-fired alternatives were not considered because the NRC 

10 staff determined that a possibly undisturbed offsite location would generally generate larger 

11 impacts than either alternative constructed at the previously disturbed CNS-1 site. 

12 8.4.1 Offsite Coal- and Gas-Fired Capacity 

13 While it is possible that coal- and gas-fired alternatives like those considered in Sections 8.1 

14 and 8.2, respectively, could be constructed at sites other than CNS-1, the NRC staff determined 

15 that they would result in greater impacts than alternatives constructed at the CNS-1 site. 

16 Greater impacts would occur from construction of support infrastructure, like transmission lines, 

17 roads, and railway spurs that are already present on the CNS-1 site. Further, the community 

18 around CNS-1 is already familiar with the appearance of a power facility and it is an established 

19 part of the region’s aesthetic character. Workers skilled in power plant operations would also be 

20 available in this area. The availability of these factors is only likely to be available on other 

21 recently-industrial sites. In cases where recently-industrial sites exist, other remediation may 

22 also be necessary in order to make the site ready for redevelopment. In short, an existing power 

23 plant site would present the best location for a new power facility. 

24 8.4.2 Coal-Fired Integrated Gasification Combined-Cycle 

25 While utilities across the United States have considered or are considering plans for integrated 

26 gasification combined-cycle (IGCC) coal-fired power plants, few IGCC facilities have yet been 

27 constructed. All facilities constructed in the United States to date have been smaller than CNS28 1. The technology, however, is commercially available and relies on a gasifier stage and a 

29 combined-cycle stage. Existing combined-cycle facilities (like the ones considered in Section 

30 8.2) could be used as a part of an IGCC alternative. 

31 EIA indicates that IGCC and other advanced coal plants may become increasingly common in 

32 coming years, though uncertainties about construction time periods and commercial viability in 

33 the near future lead NRC staff to believe that IGCC is an unlikely alternative to CNS-1 license 
Environmental Impacts of Alternatives 

February 2010 8-31 Draft NUREG-1437, Supplement 41 

1 renewal (EIA, 2009). For plants whose licenses expire at later dates, IGCC (with or without 

2 carbon capture and storage) may prove to be a viable alternative. 

3 8.4.3 New Nuclear 

4 In its ER, NPPD indicated that it is unlikely that a nuclear alternative could be sited, constructed, 

5 and operational by the time CNS-1’s operating license expires in 2014 (NPPD, 2008). Sources 

6 in the nuclear industry have recently indicated that reactor projects currently under development 

7 are probably eight or nine years from completion (Nucleonics Week, 2008), or possibly online in 

8 the 2016–2017 timeframe. A plant currently under development would also require additional 

9 time to develop an application. Given the relatively short time remaining on the current CNS-1 

10 operating license, NRC staff has not evaluated new nuclear generation as an alternative to 

11 license renewal. 

12 8.4.4 Energy Conservation and Energy Efficiency 

13 Though often used interchangeably, energy conservation and energy efficiency are different 

14 concepts. Energy efficiency means deriving a similar level of services by using less energy, 

15 while energy conservation indicates a reduction in energy consumption. Both fall into a larger 

16 category known as demand-side management. Demand-side management measures address 

17 energy end uses —unlike energy supply alternatives discussed in previous sections. Demand18 side management can include measures that (1) shift energy consumption to different times of 

19 the day to reduce peak loads, (2) interrupt certain large customers during periods of high 

20 demand, (3) interrupt certain appliances during high demand periods (4) replace older, less 

21 efficient appliances, lighting, or control systems (5) encourage customers to switch from gas to 

22 electricity for water heating and other similar measures that utilities use to boost sales. 

23 Unlike other alternatives to license renewal, the GEIS notes that conservation is not a discrete 

24 power generating source; it represents an option that States and utilities may use to reduce their 

25 need for power generation capability (NRC, 1996). 

26 While NPPD does state that demand-side management is encouraged by the utility, and that in 

27 2007 there was over 500 MWe demand reduction (NPPD, 2008), it is unlikely that increased 

28 energy efficiency in the State of Nebraska will have grown enough to offset the loss of CNS-1 by 

29 the license expiration in 2014. Because of this, the NRC staff has not evaluated energy 

30 conservation and efficiency as a discrete alternative to license renewal. It has, however, been 

31 considered as a component of the combination alternative. 

32 8.4.5 Purchased Power 

33 In its ER, NPPD indicated that purchased electrical power is, in theory, a potential alternative to 

34 CNS-1 license renewal; however, for the 2014 to 2034 time frame of CNS-1’s renewal, there are 

35 no guaranteed available power sources to replace the 816 MWe that CNS-1 provides. NPPD 

36 indicates that most of its purchased power supply is imported from Canada, which is expected 

37 to decrease over the next two decades. Within the State of Nebraska, two newly licensed coal38 fired plants starting production in 2009 and 2012 combined will barely meet the amount of 

39 electricity currently provided by CNS-1. Because of the lack of assured availability of purchased 

40 electrical power, the NRC staff has not evaluated purchased power as an alternative to license 

41 renewal. 
Environmental Impacts of Alternatives 

Draft NUREG-1437, Supplement 41 8-32 February 2010 

1 8.4.6 Solar Power 

2 Solar technologies use the sun’s energy to produce electricity. Currently, the CNS-1 site 

3 receives approximately 3.8 to 4.2 kilowatt hours (kWh) per square meter per day, as does most 

4 of the eastern portion of Nebraska (NREL, 2008), for solar collectors oriented at an angle equal 

5 to the installation’s latitude. Since flat-plate photovoltaics tend to be roughly 25 percent efficient, 

6 a solar-powered alternative will require at least 11,620 acres (4,700 ha) of collectors to provide 

7 an amount of electricity equivalent to that generated by CNS-1. Space between parcels and 

8 associated infrastructure increase this land requirement. This amount of land, while large, is 

9 consistent with the land required for coal and natural gas fuel cycles. In the GEIS, the NRC staff 

10 noted that, by its nature, solar power is intermittent (i.e., it does not work at night and cannot 

11 serve baseload when the sun is not shining), and the efficiency of collectors varies greatly with 

12 weather conditions. A solar-powered alternative will require energy storage or backup power 

13 supply to provide electric power at night. Given the challenges in meeting baseload 

14 requirements, the NRC staff did not evaluate solar power as an alternative to license renewal of 

15 CNS-1. 

16 8.4.7 Biomass Waste 

17 In 1999, DOE researchers estimated that Nebraska has biomass fuel resources consisting of 

18 forest, mill, agricultural, and urban residues, as well as energy crop potential. Excluding 

19 potential energy crops, DOE researchers projected that Nebraska had 16,634,800 tons 

20 (15,091,000 MT) of plant-based biomass available at 50 dollars per ton delivered (Walsh, et al., 

21 2000; costs are in 1995 dollars). The Bioenergy Feedstock Development Program at Oak Ridge 

22 National Laboratory estimates that each air-dry pound of wood residue produces approximately 

23 6,400 BTU of heat (ORNL, 2007). Assuming a 33 percent conversion efficiency, using all 

24 biomass available in Nebraska at 50 dollars per ton—the maximum price the researchers 

25 considered—would generate roughly 20.6 terawatt hours of electricity. 

26 Walsh, et al. (2000), note that these estimates of biomass capacity contain substantial 

27 uncertainty, and that potential availability does not mean biomass will actually be available at 

28 the prices indicated or that resources will be usably free of contamination. Some of these plant 

29 wastes already have reuse value, and would likely be more costly to deliver because of 

30 competition. Others, such as forest residues, may prove unsafe and unsustainable to harvest on 

31 a regular basis (the vast majority of biomass capacity in Nebraska, however, comes from 

32 agricultural residues, with very little potential from forest residues). It is likely that the available 

33 resource potential is much less than the estimate totals in Walsh, et al., and the total resource is 

34 not likely to be sufficient to substitute for the capacity provided by CNS-1. As a result, the NRC 

35 staff has not considered a biomass-fired alternative to CNS-1 license renewal. 

36 8.4.8 Hydroelectric Power 

37 According to researchers at Idaho National Energy and Environmental Laboratory (INEEL), 

38 Nebraska has an estimated 345 MWe of technically available, undeveloped hydroelectric 

39 resources at 45 sites throughout the State (INEEL, 1997). Most of these sites have a potential 

40 capacity of less than 1 MWe, although the largest site in Nebraska is capable of providing 22 

41 MWe. Given that the available hydroelectric potential in the State of Nebraska constitutes less 

42 than one-half of the generating capacity of CNS-1, the NRC staff did not evaluate hydropower 

43 as an alternative to license renewal. 
Environmental Impacts of Alternatives 

February 2010 8-33 Draft NUREG-1437, Supplement 41 

1 8.4.9 Wave and Ocean Energy 

2 Wave and ocean energy has generated considerable interest in recent years. Ocean waves, 

3 currents, and tides are often predictable and reliable. Ocean currents flow consistently, while 

4 tides can be predicted months and years in advance with well-known behavior in most coastal 

5 areas. Most of these technologies are in relatively early stages of development, and while some 

6 results have been promising, they are not likely to be able to replace the capacity of CNS-1 by 

7 the time its license expires. While testing of new technologies to produce electricity from the 

8 ocean continues, and because the CNS-1 site is located far from any ocean, the NRC did not 

9 consider wave and ocean energy as an alternative to CNS-1 license renewal. 

10 8.4.10 Geothermal Power 

11 Although geothermal energy has an average capacity factor of 90 percent and can be used for 

12 baseload power where available, geothermal electric generation is limited by the geographical 

13 availability of geothermal resources (NRC, 1996). Nebraska has some geothermal potential in a 

14 heating and thermal capacity, but it does not have geothermal electricity potential for 

15 development (DOE, 2007). The NRC staff concluded that geothermal energy is not a 

16 reasonable alternative to license renewal at CNS-1. 

17 8.4.11 Municipal Solid-Waste 

18 Municipal solid-waste combustors use three types of technologies—mass burn, modular, and 

19 refuse-derived fuel. Mass burning is used most frequently in the United States and involves little 

20 sorting, shredding, or separation. Consequently, toxic or hazardous components present in the 

21 waste stream are combusted, and toxic constituents are exhausted to the air or become part of 

22 the resulting solid wastes. Currently, approximately 89 waste-to-energy plants operate in the 

23 United States. These plants generate approximately 2,700 MWe, or an average of 30 MWe per 

24 plant (Integrated Waste Services Association, 2007). More than 27 average-sized plants will be 

25 necessary to provide the same level of output as the other alternatives to CNS-1 license 

26 renewal. 

27 Estimates in the GEIS suggest that the overall level of construction impact from a 

28 waste-fired plant will be approximately the same as that for a coal-fired power plant. 

29 Additionally, waste-fired plants have the same or greater operational impacts than coal-fired 

30 technologies (including impacts on the aquatic environment, air, and waste disposal). The initial 

31 capital costs for municipal solid-waste plants are greater than for comparable 

32 steam-turbine technology at coal-fired facilities or at wood-waste facilities because of the need 

33 for specialized waste separation and handling equipment (NRC, 1996). 

34 The decision to burn municipal waste to generate energy is driven by the need for an alternative 

35 to landfills rather than energy considerations. The use of landfills as a waste disposal option is 

36 likely to increase as energy prices increase; however, it is possible that municipal waste 

37 combustion facilities may become attractive again. 

38 Regulatory structures that once supported municipal solid-waste incineration no longer exist. 

39 The Tax Reform Act of 1986 made capital-intensive projects such as municipal-waste 

40 combustion facilities more expensive relative to less expensive waste disposal alternatives such 

41 as landfills. Also, the 1994 Supreme Court decision C&A Carbone, Inc. v. Town of Clarkstown, 

42 New York, struck down local flow control ordinances that required waste to be delivered to 

43 specific municipal waste combustion facilities rather than landfills that may have had lower fees. 
Environmental Impacts of Alternatives 

Draft NUREG-1437, Supplement 41 8-34 February 2010 

1 In addition, environmental regulations have increased the cost to construct and maintain 

2 municipal waste combustion facilities. 

3 Given the small average installed size of municipal solid-waste plants and the unfavorable 

4 regulatory environment, the NRC staff does not consider municipal solid-waste combustion to 

5 be a feasible alternative to CNS-1 license renewal. 

6 8.4.12 Biofuels 

7 In addition to wood and municipal solid-waste fuels, there are other concepts for 

8 biomass-fired electric generators, including conversion to liquid biofuels and biomass 

9 gasification. In the GEIS, the NRC staff indicates that none of these technologies progressed to 

10 the point of being competitive on a large scale or of being reliable enough to replace a baseload 

11 plant such as CNS-1. After reevaluating current technologies, the NRC staff finds other 

12 biomass-fired alternatives as still unable to reliably replace the CNS-1 capacity. For this reason, 

13 the NRC staff does not consider other biomass-derived fuels to be feasible alternatives to CNS14 1 license renewal. 

15 8.4.13 Oil-Fired Power 

16 EIA projects that oil-fired plants will account for very few of new generation capacity constructed 

17 in the United States during the 2008 to 2030 time period. Further, EIA does not project that oil18 fired power will account for any significant additions to capacity (EIA, 2009a).

19 The variable costs of oil-fired generation are found to be greater than those of nuclear or coal20 fired operations, and oil-fired generation has greater environmental impacts than natural gas21 fired generation. In addition, future increases in oil prices are expected to make oil-fired 

22 generation increasingly more expensive (EIA, 2009a). The high cost of oil has prompted a 

23 steady decline in its use for electricity generation. Thus, the NRC staff does not consider oil24 fired generation as an alternative to CNS-1 license renewal. 

25 8.4.14 Fuel Cells 

26 Fuel cells oxidize fuels without combustion and its environmental side effects. Power is 

27 produced electrochemically by passing a hydrogen-rich fuel over an anode and passing air (or 

28 oxygen) over a cathode and then separating the two by an electrolyte. The only byproducts 

29 (depending on fuel characteristics) are heat, water, and CO2. Hydrogen fuel can come from a 

30 variety of hydrocarbon resources by subjecting them to steam under pressure. Natural gas is 

31 typically used as the source of hydrogen. 

32 At the present time, fuel cells are not economically or technologically competitive with other 

33 alternatives for large-scale electricity generation. EIA projects that fuel cells may cost $5,374 

per installed kW (total overnight costs4 34 ) (EIA, 2009a), or 3.5 times the construction cost of new 

35 coal-fired capacity, and 7.5 times the cost of new, advanced gas-fired, combined-cycle capacity. 

36 In addition, fuel cell units are likely to be small (the EIA reference plant is 10 MWe). While it may 

37 be possible to use a distributed array of fuel cells to provide an alternative to CNS-1, it would be 

 

4

 Overnight cost is the cost of a construction project if no interest was incurred during construction. 
Environmental Impacts of Alternatives 

February 2010 8-35 Draft NUREG-1437, Supplement 41 

1 extremely costly to do so. Accordingly, the NRC staff does not consider fuel cells to be an 

2 alternative to CNS-1 license renewal. 

3 8.4.15 Delayed Retirement 

4 NPPD has no plans to retire generating capacity in Nebraska prior to 2014 (NPPD, 2008). As a 

5 result, delayed retirement is not a feasible alternative to license renewal. Other generation 

6 capacity may be retired prior to the expiration of the CNS-1 license, but this capacity is likely to 

7 be older, less efficient, and without modern emissions controls. 

8 8.5 NO-ACTION ALTERNATIVE 

9 This section examines environmental effects that occur if NRC takes no action. No action in this 

10 case means that NRC does not issue a renewed operating license for CNS-1 and the license 

11 expires at the end of the current license term, in 2014. If NRC takes no action, the plant will 

12 shutdown at or before the end of the current license. After shutdown, plant operators will initiate 

13 decommissioning according to 10 CFR 50.82. 

14 The NRC staff notes that no action is the only alternative that is considered in-depth that does 

15 not satisfy the purpose and need for this SEIS, because it does not provide power generation 

16 capacity nor would it meet the needs currently met by CNS-1 or the alternatives evaluated in 

17 Sections 8.1 through 8.3. Assuming that a need currently exists for the power generated by 

18 CNS-1, the no-action alternative would require the appropriate energy planning decision makers 

19 to rely on an alternative to replace the capacity of CNS-1 or reduce the need for power. 

20 This section addresses only those impacts that arise directly as a result of plant shutdown. The 

21 environmental impacts from decommissioning and related activities have already been 

22 addressed in several other documents, including the Final Generic Environmental Impact 

23 Statement on Decommissioning of Nuclear Facilities, NUREG-0586, Supplement 1 

24 (NRC, 2002); the license renewal GEIS (Chapter 7, NRC, 1996); and Chapter 7 of this SEIS. 

25 These analyses either directly address or bound the environmental impacts of decommissioning 

26 whenever NPPD ceases operating CNS-1. 

27 The NRC staff notes that, even with a renewed operating license, CNS-1 will eventually shut 

28 down, and the environmental effects addressed in this section will occur at that time. Since 

29 these effects have not otherwise been addressed in this SEIS, the impacts will be addressed in 

30 this section. As with decommissioning effects, shutdown effects are expected to be similar 

31 whether or not they occur at the end of the current license or at the end of a renewed license. 

32 8.5.1 Air Quality 

33 When the plant stops operating, there will be a reduction in emissions from activities related to 

34 plant operation, such as use of diesel generators and employee vehicles. In Chapter 4, the NRC 

35 staff determined that these emissions would have a SMALL impact on air quality during the 

36 renewal term; therefore, if emissions decrease, the impact to air quality would also decrease 

37 and would be a SMALL impact. 

38 8.5.2 Ground Water Use and Quality 

39 The use of ground water would diminish as plant personnel are removed from the site and 

40 operations cease. Some consumption of ground water may continue as a small staff remains 
Environmental Impacts of Alternatives 

Draft NUREG-1437, Supplement 41 8-36 February 2010 

1 onsite to maintain facilities prior to decommissioning. Overall impacts would be smaller than 

2 during operations, but would remain SMALL. 

3 8.5.3 Surface Water Use and Quality 

4 The rate of consumptive use of surface water would decrease as the plant is shut down and the 

5 reactor cooling system continues to remove the heat of decay. Wastewater discharges would 

6 also be reduced considerably. Shutdown would reduce the already SMALL impact on surface 

7 water resources and quality. 

8 8.5.4 Aquatic and Terrestrial Resources 

9 8.5.4.1 Aquatic Ecology 

10 If the plant were to cease operating, impacts to aquatic ecology would decrease, as the plant 

11 would withdraw and discharge less water than it does during operations. Shutdown would 

12 reduce the already SMALL impacts to aquatic ecology. 

13 8.5.4.2 Terrestrial Ecology 

14 Terrestrial ecology impacts would be SMALL. No additional land disturbances on or offsite 

15 would occur. 

16 8.5.5 Human Health 

17 Human health risks would be smaller following plant shutdown. The plant, which is currently 

18 operating within regulatory limits, would emit less gaseous and liquid radioactive material to the 

19 environment. In addition, following shutdown, the variety of potential accidents at the plant 

20 (radiological or industrial) would be reduced to a limited set associated with shutdown events 

21 and fuel handling and storage. In Chapter 4 of this draft supplemental EIS, the NRC staff 

22 concluded that the impacts of continued plant operation on human health would be SMALL. In 

23 Chapter 5, the NRC staff concluded that the impacts of accidents during operation were SMALL. 

24 Therefore, as radioactive emissions to the environment decrease, and as likelihood and variety 

25 of accidents decrease following shutdown, the NRC staff concludes that the risk to human 

26 health following plant shutdown would be SMALL. 

27 8.5.6 Socioeconomics 

28 8.5.6.1 Land Use 

29 Plant shutdown would not affect onsite land use. Plant structures and other facilities would 

30 remain in place until decommissioning. Most transmission lines connected to CNS-1 would 

31 remain in service after the plant stops operating. Maintenance of most existing transmission 

32 lines would continue as before. Impacts on land use from plant shutdown would be SMALL. 

33 8.5.6.2 Socioeconomics 

34 Plant shutdown would have an impact on socioeconomic conditions in the region around CNS35 1. Plant shutdown would eliminate approximately 750 jobs and would reduce tax revenue in the 

36 region. The loss of these contributions, which may not entirely cease until after 

37 decommissioning, would have a SMALL to MODERATE impact. See Appendix J to 

38 NUREG-0586, Supplement 1 (NRC, 2002), for an additional discussion of the potential 

39 socioeconomic impacts of plant decommissioning. 
Environmental Impacts of Alternatives 

February 2010 8-37 Draft NUREG-1437, Supplement 41 

1 8.5.6.3 Transportation 

2 Traffic volumes on the roads in the vicinity of CNS-1 would be reduced after plant shutdown. 

3 Most of the reduction in traffic volume would be associated with the loss of jobs at the plant. 

4 Deliveries to the plant would be reduced until decommissioning. Transportation impacts would 

5 be SMALL as a result of plant shutdown. Transportation impacts would increase if a new energy 

6 facility were constructed at the CNS-1 site or in the immediate vicinity. These impacts are 

7 addressed in Sections 8.1 to 8.3. Such impacts may be SMALL to MODERATE, but of short 

8 duration. 

9 8.5.6.4 Aesthetics 

10 Plant structures and other facilities would remain in place until decommissioning. Noise caused 

11 by plant operation would cease. Aesthetic impacts of plant closure would be SMALL. 

12 8.5.6.5 Historic and Archaeological Resources 

13 Impacts from the no-action alternative on historic and archaeological resources would be 

14 SMALL, since CNS-1 would be decommissioned. A separate environmental review would be 

15 conducted for decommissioning. That assessment would address the protection of historic and 

16 archaeological resources. 

17 8.5.6.6 Environmental Justice 

18 Termination of power plant operations would not disproportionately affect minority and 

19 low-income populations outside the immediate vicinity of CNS-1. Minority and low-income 

20 populations are generally concentrated in urban areas. Thus, impacts from plant shutdown 

21 would be SMALL. See Appendix J of NUREG-0586, Supplement 1 (NRC, 2002), for additional 

22 discussion of these impacts.

23 8.5.7 Waste Management 

24 If the no-action alternative were implemented, the generation of high-level waste would stop and 

25 generation of low-level and mixed waste would decrease. Impacts from implementation of no26 action alternative are expected to be SMALL. 

27 Table 8-4 provides a summary of the environmental impacts of the no action alternative 

28 compared to continued operation of CNS-1. 

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

30 Operation of CNS 1 

No Action Continued CNS-1 Operation 

Air Quality SMALL SMALL 

Ground water SMALL SMALL 

Surface water SMALL SMALL 

Aquatic and terrestrial 

resources 

SMALL SMALL 

Human health SMALL SMALL 

Socioeconomics SMALL to MODERATE SMALL 

Waste management SMALL SMALL 
Environmental Impacts of Alternatives 

Draft NUREG-1437, Supplement 41 8-38 February 2010 

1 8.6 ALTERNATIVES SUMMARY 

2 In this chapter, the NRC staff considers the following alternatives to CNS-1 license renewal: 

3 supercritical coal-fired generation, natural gas combined-cycle generation, and a combination 

4 alternative. No action by NRC and its effects were also considered. The impacts for all 

5 alternatives to CNS-1 license renewal are summarized in Table 8-6 on the following page. 

6 The environmental impacts of the proposed action (issuing a renewed CNS-1 operating license) 

7 would be SMALL for all impact categories, except for the Category 1 issue of collective offsite 

8 radiological impacts from the fuel cycle, high level waste (HLW) and from spent fuel disposal. 

9 The NRC staff did not add a single significant level to these impacts, but the Commission 

10 determined them to be Category 1 issues nonetheless. 

11 The coal-fired alternative is not an environmentally favorable alternative due to impacts on air 

12 quality from NOx, SOx, PM, PAHs, CO, CO2, and mercury (and their corresponding human 

13 health impacts); and due to construction impacts to aquatic, terrestrial, and potential historic and 

14 archaeological resources. 

15 The gas-fired alternative would have slightly lower air emissions, lower waste management, and 

16 lower socioeconomic impacts than the coal-fired alternative. The combination alternative would 

17 have lower air emissions and waste management impacts than both the gas-fired and coal-fired 

18 alternatives; however, the combination alternative would have relatively high construction 

19 impacts to aquatic, terrestrial, and potential historic and archaeological resources due mainly to 

20 the wind turbine component. 

21 In conclusion, the environmentally preferred alternative in this case is the license renewal of 

22 CNS-1. All other alternatives capable of meeting the needs currently served by CNS-1 entail 

23 potentially greater impacts than the proposed action of license renewal of CNS-1. The no-action 

24 alternative necessitates the implementation of one or a combination of alternatives, all of which 

25 have greater impacts than the proposed action, the NRC staff concludes that the no-action 

26 alternative will have environmental impacts greater than or equal to the proposed license 

27 renewal action. 
Environmental Impacts of Alternatives 

Table 8-5. Summary of Environmental Impacts of Proposed Action and AlternativesDraft NUREG-1437, Supplement 41 8-39 February 2010 

1 

Impact Area 

Alternative 

Air Quality 

Ground water 

Surface Water 

Aquatic and Terrestrial 

Resources 

Human Health 

Socioeconomics 

Waste Management 

License renewal SMALL SMALL SMALL SMALL SMALL SMALL Small 

Supercritical coal-fired alternative at 

CNS-1 site MODERATE SMALL SMALL SMALL to MODERATE SMALL SMALL to LARGE MODERATE 

Gas-fired alternative at the CNS-1 

site 

SMALL to 

MODERATE SMALL SMALL SMALL to MODERATE SMALL SMALL to MODERATE SMALL 

Combination of alternatives SMALL to MODERATE SMALL SMALL SMALL to LARGE SMALL to MODERATE SMALL to MODERATE SMALL 

No action alternative SMALL SMALL SMALL SMALL SMALL SMALL to MODERATE SMALL 
Environmental Impacts of Alternatives 

February 2010 8-40 Draft NUREG-1437, Supplement 41 

1 8.7 REFERENCES 

2 10 CFR Part 51. Code of Federal Regulations, Title 10, Energy, Part 51, “Environmental 

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

4 American Coal Ash Association (ACAA). 2007. “ACAA Releases 2006 CCP Production and Use 

5 Survey.” August 24, 2007. Available URL: http://www.acaa6 usa.org/associations/8003/files/2007_ACAA_CCP_Survey_Report_Form%2809-15-08%29.pdf

7 (accessed April 15, 2008). 

8 Department of Energy (DOE). 2007. “GeoPowering the West: Nebraska State Profile.” Available 

9 URL: http://www1.eere.energy.gov/geothermal/gpw/profile_nebraska.html. (accessed July 

10 2009). 

11 Energy Information Administration (EIA). 2006. “Cost and Quality of Fuel for Electric Plants, 

12 2004 and 2005.” DOE/EIA 0191(2006). Washington, D.C. Available URL: 

13 http://www.eia.doe.gov/cneaf/electricity/cq/cqa2005.pdf. Accessed July 2009. ADAMS No. 

14 ML082880730.

15 Energy Information Administration (EIA). 2009. Assumptions to the Annual Energy Outlook 2009 

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18 Energy Information Administration (EIA). 2009a. “Summary Statistics for the United States.” 

19 Table ES1 from Electric Power Annual with Data for 2007. Available URL: 

20 http://www.eia.doe.gov/cneaf/electricity/epa/epates.html 

21 (accessed June 2009). 

22 Energy Information Administration (EIA). 2009b. Table A4. “Approximate Heat Content of 

23 Natural Gas, 1949-2008 (BTU per Cubic Foot).” Available URL: 

24 http://www.eia.doe.gov/emeu/aer/txt/ptb1304.html (accessed July 2009). 

25 Energy Information Administration (EIA). 2009c. “Annual Energy Outlook, 2009-Electricity 

26 Demand” Available URL: http://www.eia.doe.gov/oiaf/aeo/electricity.html (accessed December 

27 2009). 

28 Environmental Protection Agency (EPA). 1998. Compilation of Air Pollutant Emission Factors, 

29 Volume 1: Stationary Point and Area Sources: AP 42, Fifth Edition. “Section 1.1: Bituminous 

30 and Subbituminous Coal Combustion: Final Section Supplement E.” Washington, D.C. 2000. 

31 Environmental Protection Agency (EPA) 2000 ”Notice of Regulatory Determination on Wastes 

32 from the Combustion of Fossil Fuels.” Federal Register, Vol. 65, pp.32214-32237. Washington, 

33 D.C. 

34 Environmental Protection Agency (EPA). 2000a. “Regulatory Finding on the Emissions of 

35 Hazardous Air Pollutants from Electric Utility Steam Generating Units.” Federal Register, Vol. 

36 65, No. 245, pp. 79825–79831. Washington, D.C. December 20, 2000. 

37 Environmental Protection Agency (EPA). 2008a. New Resource Review. Available URL: 

38 http://www.epa.gov/nsr/. Accessed June 2009. ADAMS No.ML083450073 

39 Environmental Protection Agency (EPA). 2009a. “Clean Air Mercury Rule.” Available URL: 

40 http://www.epa.gov/mercuryrule/. Accessed June 2009. ADAMS No. ML091760654 
Environmental Impacts of Alternatives 

February 2010 8-41 Draft NUREG-1437, Supplement 41 

1 General Electric (GE). 2007. “Gas Turbine and Combined Cycle Products.” May 2007. Available 

2 URL: 

3 http://www.gepower.com/prod_serv/products/gas_turbines_cc/en/downloads/gasturbine_cc_pro

4 ducts.pdf (accessed June 2009). 

5 Idaho National Engineering and Environmental Laboratory (INEEL). 1997. “U.S. Hydropower 

6 Resource Assessment for Nebraska.” DOE/ID-10430(NE). Available URL: 

7 http://hydropower.inl.gov/resourceassessment/pdfs/states/ne.pdf (accessed July 2009). 

8 Nebraska Department of Environmental Quality (NDEQ). 2003. Environmental Guidance 

9 Document: Air Quality Permit Process. October 2003. Available URL: 

10 http://www.deq.state.ne.us/Publica.nsf/Pages/03-148 (accessed August 2009). 

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

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

13 U.S. Nuclear Regulatory Commission (NRC). 1999. Generic Environmental Impact Statement 

14 for License Renewal of Nuclear Plants, Main Report, “Section 6.3 – Transportation, Table 9.1, 

15 Summary of Findings on NEPA Issues for License Renewal of Nuclear Power Plants, Final 

16 Report.” NUREG-1437, Volume 1, Addendum 1. Washington, D.C. 

17 U.S. Nuclear Regulatory Commission (NRC). 2002. Generic Environmental Impact Statement 

18 on Decommissioning of Nuclear Facilities: Supplement 1, Regarding the Decommissioning of 

19 Nuclear Power Reactors. NUREG-0586, Supplement 1, Volumes 1 and 2. Washington, D.C. 

20 U.S. Office of Management and Budget (OMB). 2007. Expectmore.gov. “Detailed Information on 

21 the Low Income Home Energy Assistance Program Assessment.” Available URL: 

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23 ADAMS Accession No. ML082880730. 

24 Walsh, M.E., R.L. Perlack, A. Turhollow, D. de la Torre Ugarte, D.A. Becker, R.L. Graham, S.A. 

25 Slinsky, and D.E. Ray (Walsh et. al.). 2000. “Biomass Feedstock Availability in the United 

26 States: 1999 State Level Analysis.” Available URL: 

27 http://bioenergy.ornl.gov/resourcedata/index.html (accessed July 2009). ADAMS Accession No. 

28 ML083050223. 

February 2010 9-1 Draft NUREG-1437, Supplement 41 

1 9.0 CONCLUSION 

2 This draft supplemental environmental impact statement (SEIS) contains the preliminary 

3 environmental review of the Nebraska Public Power District (NPPD) Energy Company, LLC’s 

4 application for a renewed operating license for Cooper Nuclear Station, Unit 1, (CNS-1) as 

5 required by the Code of Federal Regulations (CFR), Part 51 of Title 10 (10 CFR Part 51) and 

6 the U.S. Nuclear Regulatory Commission’s (NRC) regulations that implement the National 

7 Environmental Policy Act (NEPA). This chapter presents conclusions and recommendations 

8 from the site-specific environmental review of CNS-1 and summarizes site-specific 

9 environmental issues of license renewal that were identified during the review. The 

10 environmental impacts of license renewal are summarized in Section 9.1; a comparison of the 

11 environmental impacts of license renewal and energy alternatives is presented in Section 9.2; 

12 unavoidable impacts of license renewal, energy alternatives, and resource commitments are 

13 discussed in Section 9.3; and conclusions and NRC staff recommendations are presented in 

14 Section 9.4. 

15 9.1 ENVIRONMENTAL IMPACTS OF LICENSE RENEWAL 

16 The staff’s review of site-specific environmental issues in this draft SEIS leads to the conclusion 

17 that issuing a renewed license would have SMALL impacts for the eight Category 2 issues 

18 applicable to license renewal at CNS-1, as well as environmental justice and chronic effects of 

19 electromagnetic fields (EMF). 

20 Mitigation measures were considered for each Category 2 issue, as applicable. For ground 

21 water, no measures to mitigate the environmental impacts of plant operation were found to be 

22 warranted because of the limited radius of influence of CNS-1 wells. NPPD has implemented 

23 some impingement and entrainment mitigation measures, such as dual flow screens with 

24 modified Ristroph fish buckets and plans to install a fish handling system, which the staff 

25 concludes will minimize impacts on aquatic resources. The NRC staff identified a variety of 

26 measures that could mitigate potential acute EMF impacts resulting from continued operation of 

27 the CNS-1 transmission lines, including erecting barriers along the length of the transmission 

28 line to prevent unauthorized access to the ground beneath the conductors and installing road 

29 signs at road crossings. These mitigation measures could reduce human health impacts by 

30 minimizing public exposures to electric shock hazard. 

31 The staff identified a variety of measures that could mitigate the potential impacts of 

32 thermophilic microbiological organisms resulting from continued operation of CNS-1. These 

33 mitigation measures include periodically monitoring for thermophilic microbiological organisms 

34 in the water and sediments near the discharge, as well as prohibiting recreational use near the 

35 discharge plume. These mitigation measures could reduce human health impacts by minimizing 

36 public exposures to thermophilic microbiological organisms. NRC staff did not identify any cost37 benefit studies applicable to the mitigation measures mentioned above. 

38 The NRC staff also considered cumulative impacts of past, present, and reasonably foreseeable 

39 future actions, regardless of what agency (Federal or non-Federal) or person undertakes them. 

40 The staff concluded that cumulative impacts of CNS-1’s license renewal would be SMALL for 

41 potentially affected resources. 
Conclusion 

Draft NUREG-1437, Supplement 41 9-2 February 2010 

1 9.2 COMPARISON OF ENVIRONMENTAL IMPACTS OF LICENSE RENEWAL AND 

2 ALTERNATIVES 

3 In the conclusion to Chapter 8, we determined that impacts from license renewal are generally 

4 less than the impacts of alternatives to license renewal, with the exception of energy 

5 conservation and energy efficiency. In comparing possible environmental impacts from 

6 supercritical coal-fired generation, natural gas combined-cycle generation, energy conservation 

7 and energy efficiency, and a combination alternative that includes natural gas, conservation and 

8 efficiency, upgrades to existing hydroelectric dams, and environmental impacts from license 

9 renewal, it was found that the energy conservation and energy efficiency alternative would result 

10 in the lowest environmental impact. Based on the NRC staff’s analysis, it was found that the 

11 impacts of license renewal are reasonable in light of the impacts from alternatives to the license 

12 renewal of CNS-1. 

13 9.3 RESOURCE COMMITMENTS 

14 9.3.1 Unavoidable Adverse Environmental Impacts 

15 Unavoidable adverse environmental impacts are impacts that would occur after implementation 

16 of all feasible mitigation measures. Implementing any of the energy alternatives considered in 

17 this SEIS, including the proposed action, would result in some unavoidable adverse 

18 environmental impacts. 

19 Minor unavoidable adverse impacts on air quality would occur due to emission and release of 

20 various chemical and radiological constituents from power plant operations. Nonradiological 

21 emissions resulting from power plant operations are expected to comply with U.S. 

22 Environmental Protection Agency (EPA) emissions standards, though the alternative of 

23 operating a fossil-fueled power plant in some areas may worsen existing attainment issues. 

24 Chemical and radiological emissions would not exceed the National Emission Standards for 

25 Hazardous Air Pollutants. 

26 During nuclear power plant operations, workers and members of the public would face 

27 unavoidable exposure to radiation and hazardous and toxic chemicals. Workers would be 

28 exposed to radiation and chemicals associated with routine plant operations and the handling of 

29 nuclear fuel and waste material. Workers would have higher levels of exposure than members 

30 of the public, but doses would be administratively controlled and would not exceed standards or 

31 administrative control limits. In comparison, the alternatives involving the construction and 

32 operation of a non-nuclear power generating facility would also result in unavoidable exposure 

33 to hazardous and toxic chemicals to workers and the general public. 

34 The generation of spent nuclear fuel and waste material, including low-level radioactive waste, 

35 hazardous waste, and nonhazardous waste would also be unavoidable. In comparison, 

36 hazardous and nonhazardous wastes would also be generated at non-nuclear power generating 

37 facilities. Wastes generated during plant operations would be collected, stored, and shipped for 

38 suitable treatment, recycling, or disposal in accordance with applicable Federal and State 

39 regulations. Due to the costs of handling these materials, power plant operators would be 

40 expected to conduct all activities and optimize all operations in a way that generates the 

41 smallest amount of waste possible. 
Conclusion 

February 2010 9-3 Draft NUREG-1437, Supplement 41 

1 9.3.2 The Relationship between Local Short-Term Uses of the Environment and the 

2 Maintenance and Enhancement of Long-Term Productivity 

3 The operation of power generating facilities would result in short-term uses of the environment 

4 as described in Chapters 4, 5, 6, 7, and 8. “Short-term” is the period of time that continued 

5 power generating activities take place. 

6 Power plant operations require short-term use of the environment and commitment of 

7 resources, and also commit certain resources (e.g., land and energy) indefinitely or 

8 permanently. Certain short-term resource commitments are substantially greater under most 

9 energy alternatives, including license renewal, than under the No-Action Alternative because of 

10 the continued generation of electrical power and the continued use of generating sites and 

11 associated infrastructure. During operations, all energy alternatives require similar relationships 

12 between local short-term uses of the environment and the maintenance and enhancement of 

13 long-term productivity. 

14 Air emissions from power plant operations introduce small amounts of radiological and 

15 nonradiological constituents to the region around the plant site. Over time, these emissions 

16 would result in increased concentrations and exposure, but are not expected to impact air 

17 quality or radiation exposure to the extent that public health and long-term productivity of the 

18 environment would be impaired. 

19 Continued employment, expenditures, and tax revenues generated during power plant 

20 operations directly benefit local, regional, and State economies over the short term. Local 

21 governments investing project-generated tax revenues into infrastructure and other required 

22 services could enhance economic productivity over the long term. 

23 The management and disposal of spent nuclear fuel, low-level radioactive waste, hazardous 

24 waste, and nonhazardous waste requires an increase in energy and consumes space at 

25 treatment, storage, or disposal facilities. Regardless of the location, the use of land to meet 

26 waste disposal needs would reduce the long-term productivity of the land. 

27 Power plant facilities are committed to electricity production over the short term. After 

28 decommissioning these facilities and restoring the area, the land could be available for other 

29 future productive uses. 

30 9.3.3 Irreversible and Irretrievable Commitments of Resources 

31 This section describes the irreversible and irretrievable commitment of resources that have 

32 been identified in this SEIS. Resources are irreversible when primary or secondary impacts limit 

33 the future options for a resource. An irretrievable commitment refers to the use or consumption 

34 of resources that are neither renewable nor recoverable for future use. Irreversible and 

35 irretrievable commitment of resources for electrical power generation include the commitment of 

36 land, water, energy, raw materials, and other natural and man-made resources required for 

37 power plant operations. In general, the commitment of capital, energy, labor, and material 

38 resources are also irreversible. 

39 The implementation of any of the energy alternatives considered in this SEIS would entail the 

40 irreversible and irretrievable commitment of energy, water, chemicals, and, in some cases, fossil 

41 fuels. These resources would be committed during the license renewal term and over the entire 

42 life cycle of the power plant and would be unrecoverable. 
Conclusion 

Draft NUREG-1437, Supplement 41 9-4 February 2010 

1 Energy expended would be in the form of fuel for equipment, vehicles, and power plant 

2 operations and electricity for equipment and facility operations. Electricity and fuel would be 

3 purchased from offsite commercial sources. Water would be obtained from existing water supply 

4 systems. These resources are readily available, and the amounts required are not expected to 

5 deplete available supplies or exceed available system capacities. 

6 The irreversible and irretrievable commitment of material resources includes materials that 

7 cannot be recovered or recycled, materials that are rendered radioactive and cannot be 

8 decontaminated, and materials consumed or reduced to unrecoverable forms of waste. None of 

9 the resources used by these power generating facilities, however, are in short supply, and for 

10 the most part are readily available. 

11 Various materials and chemicals derived from chemical vendors, including acids and caustics, 

12 are required to support the operation's activities. Their consumption is not expected to affect 

13 local, regional, or national supplies. 

14 The treatment, storage, and disposal of spent nuclear fuel, low-level radioactive waste, 

15 hazardous waste, and nonhazardous waste require the irretrievable commitment of energy and 

16 fuel and will result in the irreversible commitment of space in disposal facilities. 

17 9.4 RECOMMENDATIONS 

18 Based on (1) the analysis and findings in the GEIS, (2) information provided in the 

19 Environmental Report submitted by NPPD, (3) consultation with Federal, State, and local 

20 agencies, (4) a review of pertinent documents and reports, and (5) consideration of public 

21 comments received during scoping, the preliminary recommendation of the NRC staff is for the 

22 Commission to determine that the above considered adverse environmental impacts of license 

23 renewal are not so great that preserving the option of license renewal for energy planning 

24 decision makers (i.e., State regulatory agencies and NPPD) would be unreasonable.
February 2010 10-1 Draft NUREG-1437, Supplement 41 

1 10.0 LIST OF PREPARERS 

2 This supplemental environmental impact statement (SEIS) was prepared by members of the 

3 Office of Nuclear Reactor Regulation, with assistance from other U. S. Nuclear Regulatory 

4 Commission (NRC) organizations and with contract support from Pacific Northwest National 

5 Laboratory. 

6 Table 10-1 provides a list of NRC staff that participated in the development of the SEIS. Pacific 

7 Northwest National Laboratory provided contract support for the severe accident mitigation 

8 alternatives (SAMA) analysis, presented in Chapter 5 and Appendix F. 

9 Table 10-1. List of Preparers. 

Name Affiliation Function or Expertise 

Nuclear Regulatory Commission 

Bo Pham Nuclear Reactor Regulation Branch Chief 

Dave Pelton Nuclear Reactor Regulation Branch Chief 

Emmanuel Sayoc Nuclear Reactor Regulation Project Manager 

Tam Tran Nuclear Reactor Regulation Project Manager 

Bennett Brady Nuclear Reactor Regulation Project Manager 

Dennis Beissel Nuclear Reactor Regulation Hydrology 

Dennis Logan Nuclear Reactor Regulation Aquatic Ecology; Terrestrial 

Ecology 

Stephen Klementowicz Nuclear Reactor Regulation Radiation Protection; Human 

Health 

Jennifer Davis Nuclear Reactor Regulation Historic and Archaeological 

Resources 

Richard Bulavinetz Nuclear Reactor Regulation Terrestrial Ecology 

Ekaterina Lenning Nuclear Reactor Regulation Air Quality 

Robert Palla Nuclear Reactor Regulation Severe Accident Mitigation 

Alternatives 

Jeffrey Rikhoff Nuclear Reactor Regulation Socioeconomics; Land Use; 

Environmental Justice 

Andrew Stuyvenburg Nuclear Reactor Regulation Alternatives 

Allison Travers Nuclear Reactor Regulation Alternatives 

SAMA Contractor(a)

Steve Short Pacific Northwest National Laboratory Severe Accident Mitigation 

Alternatives 

Bruce Schmitt Pacific Northwest National Laboratory Severe Accident Mitigation 

Alternatives 

Jon Young Pacific Northwest National Laboratory Severe Accident Mitigation 

Alternatives 

(a) 10 Pacific Northwest National Laboratory is operated by Batelle for the U.S. Department of Energy

February 2010 11-1 Draft NUREG-1437, Supplement 41 

11.0 INDEX

1 accidents .................................................................................................. xxv, 5-1, 5-2, 5-3, B-8 

2 aesthetic ................................................................................................................................xxiv 

3 alternatives ............................v, xxv, xxvi, 1-6, 5-3, 8-7, 8-27, 9-1, 9-2,9-3, 9-4, 10-1, 12-1, B-8 

4 archaeological resources ............................................................................... xxiv, 1-7, B-8, D-1 

5 Barnwell..................................................................................................................................2-7 

6 biota ................................................................................................................................... B-2 

7 burnup ................................................................................................................................. B-11 

8 chronic effects ............................................................................. 1-4, 4-15, 4-38, 4-50, 9-1, B-7 

9 closed-cycle cooling .............................................................................................................. B-5 

10 cultural resources .................................................................................................................. C-1 

11 decommissioning...........................................................................................................3, 11, 12 

12 design-basis accidents ............................................................................................ xxx, 5-1, 5-2

13 discharges .......................................................................................................9-1, B-2, B-3, B-7 

14 dose ........................................................................................ 2-7, 4-16, 4-17, B-6, B-9, B-10 

15 education.............................................................................................................4-20, 4-21, B-8 

16 electromagnetic fields...........................................................1-4, 4-12, 4-38, 4-50, 9-1, B-5, B-7 

17 entrainment ....................................................................................................................B-2, B-3 

18 environmental justice.......................................................................... 1-4, 4-21, 4-27, 9-1, B-12 

19 EPA .................................................................................................xxxi, 2-7, 4-16, B-10, C-1 

20 GEIS ................xx, xxi, xxii, xxiii, xxiv, xxvii, xxxi, 1-3, 1-4, 1-6, 1-10, 4-1, 4-3,4-5, 4-12, 4-15, 

21 4-20, 4-21, 4-36, 4-50, 5-1, 5-2, 5-3, 6-1, 6-2, 7-2, 9-4, A-1, B-9 

22 ground water .................................................................................. 4-2, 4-16, 9-1, B-4, B-5, C-1 

23 hazardous waste .............................................................................................. 2-8, 9-2, 9-3, 9-4

24 high level waste............................................................................................................B-9, B-10 

25 impingement........................................................................................................... B-2, B-3, B-4 

26 low level waste .....................................................................................................................xxxii 

27 mitigation ........................................xxiii, 1-4, 1-6, 4-3, 4-5, 4-12, 4-15, 5-3, 9-1, 9-2, 10-1, 12-1 

28 mixed waste ............................................................................................................... xxxii, B-11 

29 NEPA .............................................xx, xxi, xxxiii, 1-1, 1-12, 4-36, 5-1, 7-3, 9-1, B-9, B-10, D-1 

30 no-action alternative ..........................................................................................................v, xxvi 

31 nonattainment........................................................................................................................ B-6 

32 NPDES ................................................................................................................ xxxiv, B-2, C-1 

33 Pennsylvania Department of Conservation and Natural Resources ..................................... xxx 

34 Pennsylvania Department of Environmental Protection ......................................................xxxiv 

35 Pennsylvania Fish and Boat Commission ...........................................................................xxxiv 

36 Pennsylvania Game Commission.........................................................................................xxxv 

37 Pennsylvania Historic and Museum Commission.................................................................xxxv 

38 postulated accidents....................................................................................................... 5-1, 5-3 

39 pressurized water reactor.....................................................................................................xxxv 

40 radon-222 ....................................................................................................................... 6-1, B-9 

41 reactor .................................................................xx, xxi, xxx, xxxii, xxxv, 5-1, 5-2, 5-3, B-4, B-9 

42 refurbishment ......................................................................... 4-17, B-1, B-2, B-4, B-6, B-7, B-8 

43 replacement power.................................................................................................................... v 

44 scoping . xx, xxi, xxiii, xxvii, 1-3, 1-6, 4-3, 4-5, 4-12, 4-15, 4-37, 5-2, 5-3, 6-1, 7-2, 9-4, A-1, E-3 

45 severe accidents (SAMA)................................................................... xxxvi, 5-3, 5-4, 10-1, 12-1 

46 solid waste..............................................................................................2-7, 2-8, 6-1, B-12, C-1 

47 spent fuel............................................................................. xxxii, 1-4, 6-1, 6-2, B-9, B-10, B-11 
Index 

Draft NUREG-1437, Supplement 41 11-2 February 2010 

1 stormwater............................................................................................................................4-16 

2 surface water................................................................................. xxiv, 4-3, 4-16, B-1, B-4, C-1 

3 Susquehanna River Basin Commission ..............................................................................xxxvi 

4 threatened and endangered species..............................................1-7, 4-14, B-2, B-6, C-1, D-1 

5 transmission lines....................................................... 4-1, 4-20, 4-21, 4-38, 4-50, 9-1, B-6, B-8 

6 tritium ..................................................................................................................................4-16 

7 uranium ......................................................................................................... 6-1, 6-2, B-9, B-11 

8 wastewater ............................................................................................................................ B-2 

9 Yucca ................................................................................................................ B-9, B-10, B-11 
February 2010 12-1 Draft NUREG-1437, Supplement 41 

1 12.0 LIST OF AGENCIES, ORGANIZATIONS, AND PERSONS TO 

2 WHOM COPIES OF THE SUPPLEMENTAL ENVIRONMENTAL IMPACT 

3 STATEMENT ARE SENT 

4 . 

Name and Title Company and Address 

Mr. Ronald D. Asche 

President and Chief Executive Officer 

Nebraska Public Power District 

1414 15th Street 

Columbus, NE 68601 

Mr. Gene Mace 

Nuclear Asset Manager 

Nebraska Public Power District 

P.O. Box 98 

Brownville, NE 68321 

Mr. John C. McClure 

Vice President and General Counsel 

Nebraska Public Power District 

P.O. Box 499 

Columbus, NE 68602-0499 

Mr. David Van Der Kamp 

Licensing Manager 

Nebraska Public Power District 

P.O. Box 98 

Brownville, NE 68321 

Mr. Michael J. Linder, Director Nebraska Department of Environmental 

Quality 

P.O. Box 98922 

Lincoln, NE 68509-8922 

Chairman Nemaha County Board of Commissioners 

Nemaha County Courthouse 

1824 N Street 

Auburn, NE 68305 

Ms. Julia Schmitt, Manager 

Radiation Control Program 

Nebraska Health & Human Services R & L 

Public Health Assurance 

301 Centennial Mall, South 

P.O. Box 95007 

Lincoln, NE 68509-5007 

Mr. H. Floyd Gilzow 

Deputy Director for Policy 

Missouri Department of Natural Resources 

P.O. Box 176 

Jefferson City, MO 65102-0176 

Senior Resident Inspector U.S. Nuclear Regulatory Commission 

P.O. Box 218 

Brownville, NE 68321 

Regional Administrator, Region IV U.S. Nuclear Regulatory Commission 

612 E. Lamar Blvd., Suite 400 

Arlington, TX 76011-4125 

Director Missouri State Emergency Management Agency 

P.O. Box 116 

Jefferson City, MO 65102-0116 

Chief, Radiation and Asbestos 

Control Section 

Kansas Department of Health and Environment 

Bureau of Air and Radiation 

1000 SW Jackson 

Suite 310 

Topeka, KS 66612-1366 
List of Agencies, Organizations, and Persons 

Draft NUREG-1437, Supplement 41 12-2 February 2010 

Name and Title Company and Address 

Ms. Melanie Rasmussen 

Radiation Control Program Director 

Bureau of Radiological Health 

Iowa Department of Public Health 

Lucas State Office Building, 5th Floor 

321 East 12th Street 

Des Moines, IA 50319 

Mr. Keith G. Henke, Planner 

Division of Community and Public Health 

Office of Emergency Coordination 

930 Wildwood P.O. Box 570 

Jefferson City, MO 65102 

Mr. Art Zaremba, 

Director of Nuclear Safety Assurance 

Nebraska Public Power District 

P.O. Box 98 

Brownville, NE 68321 

Mr. John F. McCann, Director 

Licensing, Entergy Nuclear Northeast 

Entergy Nuclear Operations, Inc. 

440 Hamilton Avenue 

White Plains, NY 10601-1813 

Steward Minahan 

Vice President 

Nuclear and Chief Nuclear Officer 

Cooper Nuclear Station 

72676 – 648A Avenue 

Brownville, NE 68321 

Mike Boyce 

Cooper Strategic Initiatives Manager 

Cooper Nuclear Station 

72676 – 648A Avenue 

Brownville, NE 68321 

Dave Bremer 

License Renewal Project Manager 

Cooper Nuclear Station 

72676 – 648A Avenue 

Brownville, NE 68321 

Bill Victor 

License Renewal Project Licensing Lead 

Cooper Nuclear Station 

72676 – 648A Avenue 

Brownville, NE 68321 

Jim Loynes 

License Renewal Project Engineer 

Cooper Nuclear Station 

72676 – 648A Avenue 

Brownville, NE 68321 

Garry Young 

License Renewal Manager 

Entergy Nuclear 

1448 S.R. 333, N-GSB-45 

Russellville, AK 72802 

Alan Cox 

License Renewal Technical Manager 

Entergy Nuclear 

1448 S.R. 333, N-GSB-45 

Russellville, AK 72802 

Jerry Perry Entergy Nuclear 

1448 S.R. 333, N-GSB-45 

Russellville, AK 72802 

Yolanda Peck 500 S. Main Street 

Rock Port, MO 64482 

Kendall Neiman 1008 Central Ave. 

Auburn, NE 68305 

Annie Thomas 830 Central Ave. 

Auburn, NE 68305 

John Chaney 1522 I Street 

Auburn, NE 68305 

Darrell Kruse 1101 17th Street 

Auburn, NE 68305 
List of Agencies, Organizations, and Persons 

February 2010 12-3 Draft NUREG-1437, Supplement 41 

Name and Title Company and Address 

Daryl J. Obermeyer 2415 McConnell Ave. 

Auburn, NE 68305 

Sherry Black, Director 64381 727A Road 

Brownville, NE 68321 

Marty Hayes 

Chairman 

Auburn Memorial Library 

1810 Courthouse Ave. 

Auburn, NE 68305 

Bob Engles 

Mayor of Auburn, NE 

Board of Brownville, NE 

P.O. Box 67 

223 Main Street 

Brownville, NE 68321 

Jo Stevens 

Mayor of Rock Port, MO 

1101 J Street 

Auburn, NE 68305 

John Cochnar 500 S. Main Street 

Rock Port, MO 64482 

John Askew 

Regional Administrator 

U.S. Fish and Wildlife Service 

Ecological Services 

Nebraska Field Office 

203 West Second Street 

Grand Island, NE 68801 

Regional Administrator U.S. Environmental Protection Agency Region 7 

901 N. 5th Street 

Kansas City, KS 66101 

Joann Scheafer, Director U.S. Environmental Protection Agency Region 7 

901 N. 5th Street 

Kansas City, KS 66101 

Doyle Childers, Director Nebraska Department of Health & Human 

Services 

301 Centennial Mall South 

Lincoln, NE 68509 

Mark Miles 

State Historic Preservation Officer 

Missouri Department of Natural Resources 

P.O. Box 176 

Jefferson City, MO 65102 

Michael J. Smith 

State Historic Preservation Officer 

Department of Natural Resources 

P.O. Box 176 

Jefferson City, MO 65102 

Robert Puschendorf Nebraska State Historical Society 

P.O. Box 82554 

Lincoln, NE 68501 

Carla Mason ADC Digital Communications 

820 Central Ave 

Auburn, NE 68305 

Matthew Leaf KTNC/KLZA Radio 

1602 Stone St. 

Falls City, NE 68355 

Daryl J. Oberneyer ADC Digital Communications 

64381 727A Road 

Brownsville, ME 68321 

1 APPENDIX A. 

2 COMMENTS RECEIVED ON THE COOPER NUCLEAR STATION, 

3 UNIT 1, ENVIRONMENTAL REVIEW

February 2010 A-1 Draft NUREG-1437, Supplement 41 

1 A. COMMENTS RECEIVED ON THE COOPER NUCLEAR STATION, 

2 UNIT 1, ENVIRONMENTAL REVIEW 

3 A.1. Comments Received During Scoping 

4 The scoping process began on January 26, 2009 with the publication of the U.S. Nuclear 

5 Regulatory Commission’s (NRC’s) Notice of Intent to conduct scoping in the Federal Register

6 (74 FR 4476). The scoping process included two public meetings held in Brownville and Auburn, 

7 Nebraska on February 25, 2009. Approximately 120 people attended the meetings. After the 

8 NRC’s prepared statements pertaining to the license renewal process, the meetings were open 

9 for public comments. Attendees provided oral statements that were recorded and transcribed by 

10 a certified court reporter. Transcripts of the entire meeting, as well as written statements 

11 submitted at the public meetings, were issued as an attachment to the Cooper Public Meeting 

12 Summary Report dated April 14, 2009 (NRC, 2009). In addition to the comments received 

13 during the public meetings, comments were received through the mail and e-mail. 

14 Each commenter was given a unique identifier so every comment could be traced back to its 

15 author. Table A-1 identifies the individuals who provided comments applicable to the 

16 environmental review and the Commenter ID associated with each person’s set of comments. 

17 The individuals are listed in the order in which they spoke at the public meeting, and in 

18 alphabetical order for the comments received by letter or e-mail. To maintain consistency with 

19 the Public Meeting Summary Report, the unique identifier used in that report for each set of 

20 comments is retained in this appendix. 

21 Specific comments were categorized and consolidated by topic. Comments with similar specific 

22 objectives were combined to capture the common essential issues raised by participants. 

23 Comments fall into one of the following general groups: 

24 (1) Specific comments that address environmental issues within the purview of the NRC 

25 environmental regulations related to license renewal. These comments address 

26 Category 1 (generic) or Category 2 (site-specific) issues or issues not addressed in the 

27 Generic Environmental Impact Statement (GEIS) for License Renewal of Nuclear Power 

28 Plants. They also address alternatives to license renewal and related Federal actions. 

29 (2) General comments (1) in support of, or opposed to, nuclear power or license renewal or 

30 (2) on the renewal process, the NRC’s regulations, and the regulatory process. These 

31 comments may or may not be specifically related to the Cooper Nuclear Station, Unit 1, 

32 (CNS-1) license renewal application. 

33 (3) Comments that do not identify new information for the NRC to analyze as part of its 

34 environmental review. 

35 (4) Comments that address issues that do not fall within, or are specifically excluded from, 

36 the purview of NRC environmental regulations related to license renewal. These 

37 comments typically address issues such as emergency response and preparedness, 

38 security and terrorism, energy costs, energy needs, current operational safety issues, 

39 and safety issues related to operation during the renewal period. 
Appendix A

Draft NUREG-1437, Supplement 41 A-2 February 2010 

1 Table A-1. Commenters on the Scope of the Environmental Review. Each comment is 

2 identified along with their affiliation and how their comment was submitted. 

Commenter ID Commenter Affiliation Comment Source ADAMS Accession 

Numbera

CNS-1-A Martin Hansen Village Board of Brownville Afternoon Scoping 

Meeting 

ML090840062 

CNS-1-B Glen Krueger Member of the Public Afternoon Scoping 

Meeting 

ML090840062 

CNS-1-C Becky Cromer Falls City Economic 

Development and Growth 

Enterprise 

Afternoon Scoping 

Meeting 

ML090840062 

CNS-1-D Arnold Ehlers City Clerk/Treasurer for the 

City of Nebraska City, 

Nebraska 

Afternoon Scoping 

Meeting 

ML090840062 

CNS-1-E James Gerwick Emergency Management 

Director for Richardson 

County, Nebraska 

Afternoon Scoping 

Meeting 

ML090840062 

CNS-1-F Robert Cole Nemaha County 

Emergency Management 

Director 

Evening Scoping 

Meeting 

ML090840063 

CNS-1-G Rod Vandeberg Mayor of Falls City, 

Nebraska 

Evening Scoping 

Meeting 

ML090840063 

CNS-1-H Larry Shepard U.S. Environmental 

Protection Agency 

Evening Scoping 

Meeting 

ML090840063 

CNS-1-I Bob Engles Mayor of Auburn, Nebraska Evening Scoping 

Meeting 

ML090840063 

CNS-1-J Kendall Neiman Auburn Chamber of 

Commerce 

Evening Scoping 

Meeting 

ML090840063 

CNS-1-K David Sickel County Commissioner 

Richardson County 

Evening Scoping 

Meeting 

ML090840063 

CNS-1-L Ron Asche, Nebraska Public Power 

District 

Evening Scoping 

Meeting 

ML090840063 

CNS-1-M Alan Richard Pawnee City Development 

Corporation 

Letter ML090720067 

CNS-1-N Ashtin Paris Deputy Clerk 

City of Rock Port 

Letter ML090720068 

CNS-1-O James Gerwick Emergency Management 

Director for Richardson 

County, Nebraska 

Letter ML090720066 

CNS-1-P Larry Spepard U.S. Environmental 

Protection Agency 

Email ML091070269 

CNS-1-Q Jill Dolberg Nebraska State Historic 

Preservation Office 

Letter ML090650061 

CNS-1-R Jean Angell Nebraska Department of 

Natural Resources 

Letter ML090860762 

a

 The accession number for the afternoon transcript is ML090840062 

 The accession number for the evening transcript is ML090840063 
Appendix A

February 2010 A-3 Draft NUREG-1437, Supplement 41 

1 Comments received during scoping applicable to this environmental review are presented in this 

2 section along with the NRC response. Comments received during the public meeting have been 

3 transcribed; comments received by letter or e-mail have been copied in this document to 

4 maintain authenticity. Comments are grouped by category. There were two categories as 

5 follows: 

6 (1) Comments in support of license renewal at CNS-1, discussed in Section A.2 

7 (2) General comments regarding the license renewal review of CNS-1, discussed in A.3 

8 A.2. Comments in Support of License Renewal at Cooper Nuclear Station, Unit, 1 

9 Comment CNS-1- A: My name is Martin Hansen, a member of the Village Board of Brownville. 

10 I'm filling in for our chairman, Marty Hayes, today. I would like to welcome the members of the 

11 Nuclear Regulatory System [sic] to our community for this meeting. Brownville, while being a 

12 small community, we see the importance of Cooper Nuclear Station. It is, of course, the largest 

13 employer in our community and throughout southeastern Nebraska. But for our community, it is 

14 a little more than that. This community was here when the construction on Cooper started nearly 

15 40 years ago. We are here on each day of operation which is around the clock. Cooper 

16 continues to operate safely and our community of Brownville appreciates that very much. 

17 Cooper is a partner with the community. It has lent us support. One of the examples is the 

18 Village of Brownville Volunteer Fire Department. The management of Cooper has allowed our 

19 group of dedicated fire fighters to utilize their training facilities that has enhanced its firefighting 

20 capabilities and has cooperated in an effort and has enabled our department to upgrade its 

21 equipment and training capabilities over a number of years. I'm sure that you will hear a lot 

22 more from other communities about the economic impact of Cooper on the community and the 

23 importance it has on the economy. A 2002 economic study found that there would be 

24 detrimental impact to not only Brownville, but to other communities in this area, so Cooper is 

25 important to continue operation through the license extension of 20 years. 

26 Emergency response is an important part of Cooper operation, and any need for that action to 

27 take place would be handled in a manner that is both professional and done for the protection of 

28 the public. Cooper Emergency Response organization takes it very seriously and each resident 

29 in a 10-mile zone around Cooper always receives the appropriate information about any 

30 possible emergency response activity on the site and would have comfort of knowledge that 

31 these plans are in place and tested annually. 

32 Earlier this month, the Village Board of Brownville unanimously approved a resolution in support 

33 of Nebraska Public Power District at Cooper Nuclear Station license renewal for an additional 

34 20 years. I would like to read that resolution into the official record at this time. 

35 Resolution No. 2-2-09-1

36 WHEREAS, the Nebraska Public Power District Cooper Nuclear Station in Brownville became 

37 operational with startup in 1974 and has operated safely and efficiently for more than 30 years 

38 and its 828 megawatts of electricity generated; and 

39 WHEREAS, the Village of Brownville has had a longstanding history with Cooper Nuclear 

40 Station since the plant's construction, through refueling outages, and day-to-day operations; and 
Appendix A

Draft NUREG-1437, Supplement 41 A-4 February 2010 

1 WHEREAS, the Village of Brownville Volunteer Fire Department has been able to utilize training 

2 facilities to enhance the firefighting capabilities and this cooperative effort has allowed the 

3 department to upgrade equipment in training firefighters over the years; 

4 WHEREAS, Nebraska Public Power District has continually reinvested in the Cooper Nuclear 

5 Station facility to access continued safety, clean, reasonable, and affordable production of 

6 electricity for Nebraskans across the State; and 

7 WHEREAS, the Cooper Nuclear Station is a critical asset as part of Nebraska Public Power 

8 District generation resources and the state's unique public power system, continues to assist in 

9 keeping state electricity rates among the lowest in the country; 

10 WHEREAS, more than 700 permanent jobs at Cooper Nuclear Station and extensive use of 

11 contractors in ongoing maintenance and refueling outages are organized and important to the 

12 economy of the Village of Brownville, Nemaha County, and surrounding communities in 

13 southeastern Nebraska; and 

14 WHEREAS, a 2002 economic study of the impact of the loss of Cooper Nuclear Station would 

15 be detrimental to the Village of Brownville and other communities in southeast Nebraska; and 

16 WHEREAS, the United States Nuclear Regulatory Commission is the federal agency charged 

17 with oversight of our nation's vital nuclear facilities and encouraged public input and comment 

18 on license renewal and process from the neighborhood and communities; and 

19 WHEREAS, the Cooper Nuclear Station has continued to be a good neighbor to Brownville for 

20 more than three decades; 

21 NOW, THEREFORE, BE IT RESOLVED that the Village of Brownville Council supports the 

22 renewal of the license for the nuclear generation facility at Cooper Nuclear Station, and to 

23 assure their continued operations of safe, affordable, and important component of Nebraska's 

24 public power supply system for another 20 years; but 

25 BE IT FURTHER RESOLVED that the Village of Brownville clerk is directed to make available 

26 copies of this resolution to the Nuclear Regulatory Commission at its upcoming Environment 

27 Scope Public Meeting. 

28 Again, I wish to thank the Nuclear Regulatory Commission for hosting this important public 

29 meeting, and we'll make ourselves available to you if you have any questions of us, thank you. 

30 (End of Comment CNS-1-A) 

31 Comment CNS-1-B: My name is Glen Krueger and I was the hospital administrator, and I don't 

32 think the present one is here at this time. I was the hospital administrator. I came in 1971, so 

33 was there when it was started and I retired in 2002. And I would like to say that we have had a 

34 full and wonderful cooperation with the Nebraska Public Power District for emergency services. 

35 We were able to send an employee down to Tennessee to learn more about radiation. Yes, we 

36 were learning more when it first started up, but we finally came that we were very comfortable, 

37 that we knew how to take care of if an accident did happen over here. We had full cooperation 

38 from them and I would totally support this new license. 

39 But, also, as a citizen of Auburn, I would like to restate and I would like to have this new permit 

40 be renewed, because of the need that we have in the City of Auburn, if the need -- the people 
Appendix A

February 2010 A-5 Draft NUREG-1437, Supplement 41 

1 that work there. We have a lot of those employees who work in our church and a lot of those 

2 employees, in fact, I have three of those employees in my block where I live. Very appreciative 

3 of them. (End of Comment CNS-1 -B) 

4 Comment CNS-1-C: I also would like to thank you for the opportunity to speak here this 

5 afternoon. My name is Beckie Cromer. I'm Executive Director of our Falls City Economic 

6 Development and Growth Enterprise. And I'm here this afternoon on behalf of the economic 

7 development team from Falls City. We would like to confirm our unwavering support for the 20-

8 year license extension of Cooper Nuclear Station. Falls City EDGE did pass a resolution of 

9 support for the 20-year license extension, and we have forwarded that resolution to NPPD 

10 officials, although, after reading the materials here today, I think we'll also forward that NRC with 

11 the information provided within the packets today. And in addition to that, our mayor will be 

12 speaking in support of Nebraska Public Power District this evening, as well. 

13 Cooper Nuclear Station is an economic development gem that injects millions into our local 

14 economy by providing almost 800 jobs that pay more than double the Nebraska state average. 

15 The decommissioning of Cooper Nuclear Station would result in monumental loss of revenue 

16 and jobs for our southeast Nebraska area. Additionally, Cooper Nuclear Station runs a very safe 

17 operation. It allows Nebraska to offer a diverse portfolio of power to our citizens. 

18 I had the opportunity to tour Cooper Nuclear Station this week with many Falls City community 

19 leaders. The facility was top notch. The staff was professional and knowledgeable, and the 

20 safety measures in place for workers and the surrounding public exceeds benchmarks set by 

21 government agencies. 

22 Southeast Nebraska is proud to have Cooper Nuclear Station as a partner in economic 

23 development and we ask that you grant the licensing request being made by Cooper Nuclear 

24 Station. Thank you. (End of Comment CNS-1 -C) 

25 Comment CNS-1-D: Good afternoon. My name is Arnold Ehlers, City Clerk/Treasurer for the 

26 City of Nebraska City, Nebraska. I am here to present a resolution passed unanimously by the 

27 City Council and Mayor of Nebraska City, supporting the license renewal of Cooper Nuclear 

28 Station. I would also like to make you aware of the economic impact Cooper Nuclear Station 

29 has on southeast Nebraska, as well as southwestern Iowa and northwest Missouri, an economic 

30 impact that is over $500 million a year. But the economic impact is just one part of the 

31 contribution made by Nebraska Public Power District and its employees. NPPD employees 

32 belong to volunteer fire departments, serve on library boards, school boards, and many other 

33 boards and committees too numerous to mention. Their spouses and families are also very 

34 important contributors to the communities in which they live. 

35 Over the years, Cooper has been a good safe partner and good neighbor to all of us. They have 

36 attracted employees from around the world, enhancing the multicultural experiences of the area. 

37 We've actually become a global community due to this. It is a privilege to live in a public power 

38 state and in a city that owns its own utilities. Nebraska City, in fact all of Nebraska, benefits from 

39 the low-cost electricity that Cooper Nuclear plays a significant role in providing. 

40 I have a resolution that I would like to have entered into the record. I won't bore you with the 

41 reading of it, unless it needs to be read. I thank you for this opportunity. (End of Comment CNS42 1-D) 
Appendix A

Draft NUREG-1437, Supplement 41 A-6 February 2010 

1 Comment CNS-1-E: Good afternoon. Many thanks to the Nuclear Regulatory Commission for 

2 hosting this public forum. My name is Jim Gerwick, and I'm the Emergency Management 

3 Director for Richardson County, Nebraska, the county just south of here. 

4 In my position, hardly a month has gone by where some form of interchange has not transpired 

5 between Cooper Nuclear Station's Emergency Management Department and other nuclear 

6 operations staff and my office in Richardson County. The referenced activities include quarterly 

7 emergency communication drills, unannounced communications checks, written 

8 correspondence involving improvements in emergency plans and training in many forms, to 

9 include FEMA, Federal Emergency Management Agency, evaluated radiological emergency 

10 preparedness exercises. 

11 Other joint training activities include NPPD staff involvement in annual training of our local 

12 radiological emergency response organization, and our joint quarterly off-site training meetings. 

13 Cooper Nuclear Station has fully demonstrated its ability to provide safe, reliable electricity for 

14 the citizens of the state of Nebraska. Richardson County has supported Cooper Nuclear Station 

15 in its off-site responsibilities to protect the public and property for many years, since the plant 

16 started, actually, and is glad to be part of the team that supports nuclear power. The bottom line 

17 in our realm of experience, the staff at NPPD and Cooper Nuclear Station is thoroughly 

18 professional and meticulous in attention to detail concerning their approach to public safety. In 

19 short, they are fully integrated and a key member of our public safety team. 

20 And in view of their professional performance and contributions to our community, we support 

21 NPPD's application to continue to operate Cooper Nuclear Station for another 20 years. 

22 In closing, Richardson County is proud to have Cooper Nuclear Station in the Richardson 

23 County area. (End of Comment CNS-1-E) 

24 Comment CNS-1-F: Thank you for the opportunity to speak tonight. I'm Robert Cole. I'm the 

25 Nemaha County Emergency Management Director. I wanted to make a few short statements. I've 

26 already submitted a letter of support on the relicensing application; however, I wanted to touch on a 

27 few of the highlights that I mentioned in the letter. 

28 One of the great things about our relationship with Cooper Nuclear Plant is that they have been 

29 good partners for the communities that they are neighbors to. One example of that would be the 

30 fact that most of my day today was spent taking delivery on sirens that Cooper Nuclear has 

31 donated for several local communities in the area, both in Nebraska and Missouri, that lacked 

32 operational or modern sirens. These retired sirens from Cooper, although they are dating back to 

33 the 1970s, are well maintained and very functional and will certainly be a vital asset to communities 

34 that could not otherwise afford replacement of their siren equipment. That's a real benefit to 

35 everybody. 

36 Also, my relationship with Cooper has been excellent. I correspond or talk to Cooper 

37 representatives at least monthly, generally more often, in regard to emergency planning exercises 

38 and just day-to-day communications checks. Every time I have talked to somebody from the 

39 station, they have always been very professional and very competent, and I have very great 

40 confidence in the plant and their operations. It's a joy to be here in Nemaha County, and one of that 

41 joys is serving the County in this relationship to Cooper Nuclear. Thanks very much for the 

42 opportunity to be here. (End of Comment CNS-1-F) 
Appendix A

February 2010 A-7 Draft NUREG-1437, Supplement 41 

1 Comment CNS-1-G: Good evening. I have prepared comments which I'd be happy to give to you 

2 if you would like them at the end of the meeting. I apologize. I maybe have gotten a little bit too 

3 lengthy, but I'll try to talk fast. 

4 My name is Rod Vandeberg, and I am the mayor of Falls City, Nebraska. Falls City is a community 

5 of 4,200, and is located about 20 miles south of Cooper Nuclear Station as you head toward the 

6 Nebraska/Kansas border. 

7 Interestingly, I personally had the opportunity, along with 18 community members from Falls 

8 City, to tour Cooper Nuclear Station last Monday. I can speak for myself and the others who 

9 took the tour that we were very impressed by the serious and cordial manner in which NPPD 

10 employees were watching out for our personal safety while we were on tour, and also by the 

11 extent of the security presence at the site. This opportunity gave us all a little better first-hand 

12 look at Cooper Nuclear Station, which many of us had not seen, but have heard so much about 

13 over the years. Perhaps properly so, Cooper is a well kept secret. And I would like to take this 

14 opportunity to thank everyone who participated with us in that tour. We had the opportunity to 

15 hear from the gentleman who heads the management company. And then we had the 

16 opportunity to be with several NPPD employees. And it was really an outstanding experience. 

17 The impact of going inside such a facility and seeing how well the facility is maintained and how 

18 expansive the facility is, how it serves to protect employees, public, and the environment was 

19 time well spent. I want to thank NPPD for this opportunity. 

20 Several months ago, I sat in a breakfast meeting right here in this building in Auburn and heard 

21 from your CEO, Ron Asche, and other NPPD employees about the license renewal process, 

22 what the needs for extending of licensing of Cooper for an additional 20 years means, and what 

23 does that mean not only for my community, but all of Nebraska. What I learned is that NPPD 

24 has put an extensive amount of money into facility improvements for safety and operations of 

25 the facility so that it can be an operation that will be able to operate safely and efficiently for an 

26 additional 20 years. What I also heard at that time was that replacing Cooper would take several 

27 billion dollars to construct another generating facility, probably using coal as fuel to replace the 

28 electric generation of Cooper. Just getting a facility sited may be a significant task, and 

29 replacing Cooper with that kind of facility may not be the most environmentally friendly one, as 

30 Cooper does not generate any greenhouse gases from its nuclear operations. 

31 I realize that there are numerous areas that are required to be reviewed by the U.S. Nuclear 

32 Regulatory Commission related to the license renewal application, many dealing with the 

33 environment, another part on how equipment is expected to last if Cooper Nuclear Station were 

34 to operate another 20 years. As I heard at our meeting in the fall, Nebraska Public Power 

35 District's Board of Directors has had the foresight to invest millions of dollars into the operation 

36 in order to continue that operation in a safe manner, and that is what we expect for the residents 

37 of Falls City, Richardson County, and southeast Nebraska. 

38 Our community leaders in Falls City also heard from NPPD, at my request, to tell us more about 

39 the license renewal in a luncheon session in Falls City two or three months ago. Many in the 

40 room that day have had contact with Cooper employees, both personal or for business reasons, 

41 for we have a contingent of employees that reside in Falls City and Richardson County, 101 

42 employees to be exact. 

43 From a socio-economic aspect, that number is important in small communities such as Falls 

44 City. Cooper employees do business in our community. They are part of community activities, 
Appendix A

Draft NUREG-1437, Supplement 41 A-8 February 2010 

1 and they support our schools and services. These individuals operate an important electric 

2 generation for Nebraska, and they do it safely in a nuclear operation. On our tour, we were able 

3 to get a peek at a control room simulator and what these highly trained employees must train to 

4 do. The requirements are rigorous to meet the requirements to become a licensed operator. 

5 A loss of Cooper would cause a severe negative impact on Falls City as would it be for all of 

6 southeastern Nebraska. 

7 NPPD's CEO, Ron Asche, spoke to us last year about several maintenance issues at the plant. 

8 He could have easily passed over telling us that information, but he chose to do so, and he 

9 expressed confidence to us that NPPD would resolve these issues to the satisfaction of the 

10 NRC and return Cooper to the top level of operations for nuclear power plants in the country. 

11 And as I have learned, those words have been put into action and those findings have been 

12 resolved. Frankly, I believe Cooper is one of the safest nuclear plants in the United States. 

13 I, and the members of the City Council of Falls City, recently passed a unanimous resolution of 

14 support for Cooper Nuclear Station's license extension for an additional 20 years. We feel that it 

15 is an important asset for southeast Nebraska and Nebraska in general, and I would like for this 

16 resolution to be included in the official meeting transcript tonight. 

17 I want to thank the Nuclear Regulatory Commission for taking the time to hear from 

18 communities such as ours on this very important issue, not only locally, but nationally, as we 

19 work towards future energy independence. Thank you very much. (End of Comment CNS-1-G) 

20 Comment CNS-1-H: Good evening. Thank you, Dave. And I'd like to thank the NRC. I'd also 

21 like to thank the cities and counties of southeastern Nebraska for the opportunity to attend this 

22 scoping meeting. My name is Larry Shepard. I'm an environmental scientist with the U.S. 

23 Environmental Protection Agency, in our Kansas City Regional Office. EPA has 10 regional 

24 offices around the country. Our regional office is responsible for EPA program activities in 

25 Kansas, Iowa, Missouri, and Nebraska. 

26 My point in speaking tonight was just to help everyone tonight to understand what EPA's role is 

27 in this process, this relicensing process. EPA will be reviewing the Draft Supplemental 

28 Environmental Impact Statement and providing comment, but also in actually scoring both the 

29 document and the project itself. And we will also, in addition to that, be providing comment -- 

scoping comment to NRC by the March 27th 30 deadline. And that was really my whole purpose. If 

31 anyone has any questions after the meeting, I'll be hanging around also. Thank you very much. 

32 (End of Comment CNS-1-H) 

33 Comment CNS-1-I: Good evening. My name is Bob Engles, and I'm the mayor of Auburn, 

34 Nebraska. I'd like to thank the NRC for this opportunity and specifically for holding this public 

35 forum. 

36 As I was watching the NRC presentation, safety review and environmental impact studies were 

37 mentioned as key parts of the process. I trust that both NPPD and the NRC will conduct a 

38 thorough process to identify issues that must be addressed in these areas so that Cooper 

39 Nuclear Station can continue operating for an additional 20 years. 

40 That's exactly why I'm here. I'm here in support of extending the license for Nebraska Public 

41 Power District's Cooper Nuclear Station. I'll speak just a little bit about the socio-economic 

42 impact on my city in particular. From a practical standpoint, I'm not sure it makes sense to 
Appendix A

February 2010 A-9 Draft NUREG-1437, Supplement 41 

1 discard a proven and effective method of power generation, especially when it has served 

2 Auburn, Nemaha County, and the state of Nebraska for so many years as a safe and reliable 

3 source of electrical generation for the last 35 years in a manner that has protected the public 

4 and the environment. 

5 Cooper Nuclear Station is an economic stimulus to Auburn and southeast Nebraska. Their 

6 footprint is a stabilizing factor in our community's economy. For example, they employ 

7 approximately 720 people, and half of those people live in Nemaha County; 234 of those people 

8 live in Auburn. 

9 The plant's annual payroll is approximately $55 million. Over $17 million of that payroll goes to 

10 people that live in Auburn, and with just a little bit of math, that shows that the average income 

11 per employee living in Auburn is about $75,000. These employees are highly educated, highly 

12 trained and skilled, and they do a quality job day in and day out with safety as their prime 

13 responsibility. 

14 Cooper employees have become a part of the fabric of this community over the years. They live 

15 here. They're involved in community activities. They're involved in our churches; they frequent 

16 the business community; they are involved in youth activities and social events within our 

17 community. 

18 These people are our friends. They're our neighbors. Their kids attend our schools. They 

19 volunteer their time to make Auburn and southeast Nebraska a better place in which to live. 

20 Late last year, following NPPD's submittal of a license renewal application, Ron Asche, CEO 

21 and President of NPPD, which owns Cooper, held a series of meetings within the community 

22 with myself and other elected officials from other communities and the business community. Mr. 

23 Asche pointed out that NPPD's Board of Directors has invested over $300 million in 

24 improvements to Cooper in preparation for the license extension. NPPD is serious about making 

25 these improvements that will enhance the safety of the operations, as well as continuing to 

26 generate low-cost electricity, something that Nebraskans expect and which NPPD is mandated 

27 under state law to do. 

28 Several years ago, NPPD discussed the possibility of closing Cooper. This community was 

29 concerned about that, primarily because of the impact on the economy of Auburn and southeast 

30 Nebraska. Closing Cooper would have been unfortunate. But NPPD's Board of Directors saw 

31 the value in keeping the facility operating and have done a great job in moving forward with the 

32 safe operations of the facility, something that was expected to continue for another 20 years. 

33 Indeed, all Nebraskans benefit from the operation of Cooper Nuclear Station. Auburn has 

34 benefited from Cooper's operations directly, even though the plant is 10 miles away. Nebraska 

35 Public Power District has two facilities in our community that we believe are important for the 

36 operations of the site. The former Sheridan Elementary School has been transformed into a 

37 training center for Cooper employees and the many contractors who come into the community 

38 every 18 months for refueling outages. We believe that the training facility plays a great part of 

39 the strong environmental responsibility and safe operations of the facility each day. 

40 A second facility was remodeled in our downtown area and houses a state-of-the-art 

41 Emergency Operations Center which would operate as needed. Exercises are held on a regular 

42 basis from that facility, including ones with local emergency management personnel from 

43 southeast Nebraska. 
Appendix A

Draft NUREG-1437, Supplement 41 A-10 February 2010 

1 As mayor, I'm confident in the ability of NPPD to operate and manage in a safe manner. What 

2 we may hear from people that are concerned about safety issues, we can all be concerned 

3 about safety issues. But throughout the years, I've come to know that the people at Cooper and 

4 NPPD have confidence and that they understand the risks associated with nuclear power 

5 generation and that they have been and continue to do everything in their power to ensure my 

6 safety and our community's safety, because the same people that are working at NPPD Cooper 

7 Nuclear Station live in Auburn. They live in Brownville, Nemaha County, Falls City, and 

8 Nebraska City. 

9 And at this time, I'd like to introduce into the formal record a resolution that our City Council 

10 passed a while back unanimously approving support for the extension of the Cooper Nuclear 

11 Station license. 

12 And once again, I'd like to thank the NRC for hosting these meetings in our community, and if 

13 there's anything our town can do to help you further this process, please do not hesitate to 

14 contact us. Thank you. (End of Comment CNS-1-I) 

15 Comment CNS-1-J: Good evening. My name is Kendall Neiman and I'm President of Auburn 

16 Chamber of Commerce, and also the publisher of the Nemaha County Herald, the local weekly 

17 newspaper here. On behalf of the Auburn Chamber of Commerce, I'm expressing full support 

18 for the Nebraska Public Power District's application to extend the Cooper Nuclear Station for an 

19 additional 20 years. 

20 We believe that Cooper's safety and performance speaks for NPPD's expertise in nuclear plant 

21 operations. Several years ago, it appeared that NPPD might close down the Cooper Nuclear 

22 Station. This was something that southeastern Nebraska could not afford to have happen. A 

23 community group had an economic study done that gave us a look at what we could see locally 

24 if the facility was closed. That was about six years ago, and that picture was not very pretty. 

25 Devastating might be a better word. If Cooper Nuclear were not to continue operating after its 

26 current license expires, we could see those impacts all over southeastern Nebraska. 

27 Over 700 employees live, work, shop, and are involved in the communities in southeastern 

28 Nebraska. A majority of these employees live right here in Auburn and Nemaha County. They 

29 are contributors to the community, but they are also workers at the nuclear power plant that 

30 emphasizes nuclear safety of all as a top priority. 

31 I recently attended an open house held by NPPD in the Cooper Nuclear facility and was able to 

32 learn more about the license extension, safety, emergency response, and other operations of 

33 the facility. It's very complex, but I found that the people that I talked to be very knowledgeable 

34 and they were concerned with safety of the operations, but they were very proud of what they 

35 do on a daily basis. It is our hope that the Nuclear Regulatory Commission's review of the 

36 license application will be thorough in both the environmental review as well as the safety 

37 review of the Cooper Nuclear Station as required for license renewal. We believe that NPPD 

38 has done an excellent job in the operation of the facility as they have turned out a record 

39 generation year in 2007, have maintained a strong safety culture for the safety of the employees 

40 and the public, and maintained a high visible emergency response operation with local 

41 governments and continue to watch over a reliable generating source of electricity for 

42 Nebraskans with a watchful eye. 

43 The Auburn Chamber of Commerce supports this license renewal extension and look forward to 

44 the Nuclear Regulatory Commission's review of the facility and seeing a 20-year extension 
Appendix A

February 2010 A-11 Draft NUREG-1437, Supplement 41 

1 added to the existing license of the facility. Again, thank you for coming to Auburn and giving the 

2 community an opportunity to be heard. (End of Comment CNS-1-J) 

3 Comment CNS-1-K: My name is David Sickel. I'm one of the three County Commissioners from 

4 Richardson County. I'm pleased to have the opportunity to speak to the Nuclear Regulatory 

5 Commission concerning the extension of the Cooper Nuclear Station's license for an additional 

6 20 years. 

7 While Richardson County may be somewhat outside the influence of Cooper Nuclear Station's 

8 operations, it is important to acknowledge that over the years this facility has been able to 

9 operate in a safe and effective manner for the residents of Nebraska. It is important that a 

10 complete review of the environmental impacts for 20 more years of operation be studied 

11 thoroughly by both the Nebraska Public Power District and the Nuclear Regulatory Commission. 

12 As I understand another critical phase is a safety review. Again, this is important this type of 

13 review be conducted to ensure that equipment at the facility can operate an additional 20 years 

14 without having the impact on employee and public safety. The fact that much of this information 

15 is available to the public and can have public involvement is an important aspect of the entire 

16 process. 

17 Cooper Nuclear Station is an important part of our community. It operates safely. The 

18 employees at Cooper are highly trained. Cooper generates a reliable source of electricity for the 

19 people of the state of Nebraska. Employees reside in communities such as Richardson County. 

20 Over the years, the presence of Cooper employees in southeast Nebraska has been an 

21 important part of our economy, our schools, or business community, and the community in 

22 which these folks live. The impact on this area from the loss of Cooper operations would create 

23 an economic hardship when you consider those losses. That loss would impact Richardson 

24 County, southeast Nebraska, and the complete state of Nebraska. 

25 On behalf of the citizens of Richardson County, we are in support of the extension of the Cooper 

26 Nuclear Station's license renewal for an additional 20 years. 

27 In a letter that I wrote to NPPD's CEO and President, Ron Asche, I explained that Richardson 

28 County was proud to have Cooper Nuclear Station in the Richardson County area. Cooper 

29 Nuclear Station clearly demonstrated its ability to provide safe and reliable electricity for citizens 

30 of Nebraska. I would like to mention that as the only public power state in the country, we enjoy 

31 having the fifth lowest cost electricity rates in the United States. Richardson County, through its 

32 Emergency Management has supported the facility in its off-site responsibilities to protect the 

33 public for many years, and we are glad to be part of that team that supports Cooper and nuclear 

34 power. 

35 Thank you for this opportunity to speak to you this evening. (End of Comment CNS-1-K) 

36 Comment CNS-1-L: I'm Ron Asche, the President and CEO of Nebraska Public Power District, 

37 the owner and operator of Cooper Nuclear Station. We began our process of compiling our 

38 license renewal application several years ago, and submitted that to the NRC in September of 

39 this past year. These public meetings tonight conducted by the NRC are a very important 

40 process in that relicensing process. They provide an opportunity for members of the local 

41 communities that surround Cooper Station and for other interested stakeholders to provide input 

42 directly to the NRC regarding our license application and any issues that they may have 

43 regarding the environmental impacts of extending Cooper's license for another 20 years, as well 
Appendix A

Draft NUREG-1437, Supplement 41 A-12 February 2010 

1 as any public safety issues that they may have. And I'd like to thank all of those that came this 

2 evening to express their comments to the Nuclear Regulatory Commission, both in these 

3 meetings today and for comments that you might submit via letter or e-mail, et cetera. These 

4 are a very important part of that process. 

5 I want to close just by saying that NPPD is committed to operating Cooper Station, both now 

6 and in the future, in a manner that protects the health and safety of the public and all of our 

7 employees and workers at the plant, as well as protecting the environment. We look forward to 

8 working together with the NRC over the course of the next several years in addressing issues 

9 that may arise, which we hope will ultimately result in an extension of our license for another 20 

10 years to operate Cooper Station and continue to provide low cost, reliable, and safe energy to 

11 the members of our communities and the state of Nebraska as a whole. Thank you. (End of 

12 Comment CNS-1-L) 
Appendix A

February 2010 A-13 Draft NUREG-1437, Supplement 41 

1 Comment CNS-1-M 

2 :

3 (CNS-1-M) 

CNS-1-M 
Appendix A

Draft NUREG-1437, Supplement 41 A-14 February 2010 

1 Comment CNS 1-N 

2 

3 (CNS-1-N) 

CNS-1-N 
Appendix A

February 2010 A-15 Draft NUREG-1437, Supplement 41 

1 

CNS-1-N 

ti d
Appendix A

Draft NUREG-1437, Supplement 41 A-16 February 2010 

1 Comment CNS-1-0: 

2 

CNS-1-O 
Appendix A

February 2010 A-17 Draft NUREG-1437, Supplement 41 

1 

2 (CNS-1-O)

3 NRC Response to Comments CNS-1-A through CNS-1-O: The comments are supportive of 

4 license renewal. The comments are general in nature, provide no new information and, 

5 therefore, will not be evaluated further. No change to the scope of the Cooper Nuclear Station 

6 Environmental Impact Statement (EIS) will be made as a result of these comments. 

CNS-1-O 

ti d
Appendix A

Draft NUREG-1437, Supplement 41 A-18 February 2010 

1 A.3. Comments Regarding the license renewal review of Cooper Nuclear Station, 

2 Unit, 1 

3 

CNS-1-P 
Appendix A

February 2010 A-19 Draft NUREG-1437, Supplement 41 

1 (CNS-1-P) 

CNS-1-P 

continued 
Appendix A

Draft NUREG-1437, Supplement 41 A-20 February 2010 

1 

2 (CNS-1-Q) 

CNS-1-Q 
Appendix A

February 2010 A-21 Draft NUREG-1437, Supplement 41 

1 

2 (CNS-1-R) The NRC subsequently sent correspondence to the Nebraska Game and Parks 

3 Commission and received the requested list of protected species by email as shown in 

4 Appendix D1. The NPPD also received a letter the U.S. Fish and Wildlife Service that it 

5 “concurs with the NPPD and NRC determination that the proposed relicensing action is not 

6 likely to adversely affect federally listed species or result in the destruction or adverse 

CNS-1-R 
Appendix A

Draft NUREG-1437, Supplement 41 A-22 February 2010 

1 modification of federally designated critical habitat.” This letter is also included in Appendix 

2 D. 

3 NRC Response to Comments CNS-1-Q through CNS-R-: With respect to the comments from 

4 the Nebraska State Historical Society (CNS-1-Q), and the Nebraska Department of Natural 

5 Resources (CNS-1-R), these comments contain matter from consultations with other 

6 government agencies, which support the license renewal review process. No change to the 

7 scope of the Cooper Nuclear Station Environmental Impact Statement (EIS) will be made as a 

8 result of these comments. 

9 With respect to the EPA scoping comments (CNS-1-P) regarding the disposal of spent nuclear 

10 fuel, all utilities planning on extending operation of existing nuclear units should consider 

11 contingencies for long-term storage of waste on-site. 

12 The NRC fully evaluated and addressed this issue in our Generic Environmental Impact 

13 Statement for License Renewal of Nuclear Plants (NUREG-1437) and in its regulations. The 

14 current and potential environmental impacts from spent fuel storage onsite at the current reactor 

15 sites have been studied extensively and are well understood. The storage of spent fuel in spent 

16 fuel pools was considered for each plant in the safety and environmental reviews at the 

17 construction permit and operating license stage. The NRC has studied the safety and 

18 environmental effects from the temporary storage of spent fuel after the cessation of reactor 

19 operations (which may include the term of a revised or renewed license), and it published a 

20 generic determination of no significant environmental impact (the Waste Confidence Rule) in its 

21 regulations at 10 CFR 51.23. 10 CFR 51.23 (a) states 

22 The Commission has made a generic determination that, if necessary, spent fuel 

23 generated in any reactor can be stored safely and without significant 

24 environmental impact for at least 30 years beyond the licensed life for operation 

25 (which may include the term of a revised or renewed license) of that reactor at its 

26 spent-fuel storage basin or at either on-site or off-site independent fuel storage 

27 installations. 

28 In September 2009, the Commission reviewed this rule and declined to approve an update of 

29 the rule. In accordance with this determination, the rule also provides that no discussion is 

30 required concerning the environmental impacts of spent fuel storage for the period following the 

31 term of the reactor operating license, including a renewed license. Therefore, the SEIS will not 

32 include a discussion on the storage of spent nuclear fuel. 

33 With respect to the EPA scoping comments (CNS-1-P), regarding past contamination 

34 associated with the operation of CNS-1, particularly source and fate of tritium in the system, the 

35 draft SEIS will have a discussion on the impacts of radioactive liquid effluents discharged into 

36 the Missouri River. The discussion will evaluate the radiological dose impact to members of the 

37 public as well the impact to the environment. The SEIS will also discuss the results of Cooper’s 

38 radiological environmental monitoring program in which environmental sample media are 

39 collected and analyzed in order to evaluate the radiological impacts, if any, of plant operation on 

40 the environment. 

41 With respect to the EPA scoping comments (CNS-1-P), regarding water quality, the SEIS will 

42 discuss NPDES permits and related activities including any updated information, available river 

43 flow including low flows, USACE river flow control operations, as well as aquatic and terrestrial 

44 ecosystem issues. The NRC staff does recognize that the river ecological studies are generally 

45 dated, and will address this issue in the EIS. The NRC staff is doing a search for more recent 
Appendix A

February 2010 A-23 Draft NUREG-1437, Supplement 41 

1 data. The staffs analysis, findings, as well as references and data used will be outlined in the 

2 EIS and referenced for publicly availability. . 

3 A.4. References 

4 74 FR 4476. U.S. Nuclear Regulatory Commission, Washington, D.C, “United States Nuclear 

5 Regulatory Commission, Nebraska Public Power District, Cooper Nuclear Station, Notice of 

6 Intent to Prepare an Environmental Impact Statement and Conduct Scoping Process, Federal 

7 Register: Vol. 74, No. 15, pp. 4476–4477 January 26, 2009. 

8 NRC (U.S. Nuclear Regulatory Commission). “Summary of Public Environmental Scoping 

9 Meeting Related to the Review of the Cooper Nuclear Station Unit 1 License Renewal 

10 Application,” 2009. ADAMS Accession No. ML000910308.

1 APPENDIX B. 

2 NATIONAL ENVIRONMENTAL POLICY ACT ISSUES FOR 

3 LICENSE RENEWAL OF NUCLEAR POWER PLANTS

February 2010 B-1 Draft NUREG-1437, Supplement 41 

1 B. NATIONAL ENVIRONMENTAL POLICY ACT ISSUES FOR LICENSE 

2 RENEWAL OF NUCLEAR POWER PLANTS 

3 Table B-1. Summary of Issues and Findings. This table is taken from Table B-1 in Appendix B, 

4 Subpart A, to 10 CFR Part 51. Data supporting this table are contained in NUREG-1437, 

5 Generic Environmental Impact Statement for License Renewal of Nuclear Plants. Throughout 

6 this report, “Generic” issues are also referred to as Category 1 issues, and “Site-specific” issues 

7 are also referred to as Category 2 issues. 

Issue Type of Issue Finding 

Surface Water Quality, Hydrology, and Use 

Impacts of 

refurbishment on 

surface water quality 

Generic SMALL. Impacts are expected to be negligible during 

refurbishment because best management practices are 

expected to be employed to control soil erosion and spills. 

Impacts of 

refurbishment on 

surface water use 

Generic SMALL. Water use during refurbishment will not increase 

appreciably or will be reduced during plant outage. 

Altered current 

patterns at intake and 

discharge structures 

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

problem at operating nuclear power plants and are not expected 

to be a problem during the license renewal term. 

Altered salinity 

gradients 

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

at operating nuclear power plants and are not expected to be a 

problem during the license renewal term. 

Altered thermal 

stratification of lakes 

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

problem at operating nuclear power plants and is not expected 

to be a problem during the license renewal term. 

Temperature effects 

on sediment transport 

capacity 

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

operating nuclear power plants and are not expected to be a 

problem during the license renewal term. 

Scouring caused by 

discharged cooling 

water 

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

operating nuclear power plants and has caused only localized 

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

the license renewal term. 

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

operating nuclear power plants and is not expected to be a 

problem during the license renewal term. 

Discharge of chlorine 

or other biocides 

Generic SMALL. Effects are not a concern among regulatory and 

resource agencies, and are not expected to be a problem during 

the license renewal term. 

Discharge of sanitary 

wastes and minor 

chemical spills 

Generic SMALL. Effects are readily controlled through National Pollutant 

Discharge Elimination System (NPDES) permit and periodic 

modifications, if needed, and are not expected to be a problem 

during the license renewal term. 
Appendix B 

Draft NUREG-1437, Supplement 41 B-2 February 2010 

Issue Type of Issue Finding 

Discharge of other 

metals in wastewater 

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

at operating nuclear power plants with cooling-tower-based heat 

dissipation systems and have been satisfactorily mitigated at 

other plants. They are not expected to be a problem during the 

license renewal term. 

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 makeup 

water from a small 

river with low flow) 

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

nuclear power plants with cooling ponds and at plants with 

cooling towers. Impacts on instream and riparian communities 

near these plants could be of moderate significance in some 

situations. See § 51.53(c)(3)(ii)(A). 

Aquatic Ecology 

Refurbishment Generic SMALL. During plant shutdown and refurbishment, there will be 

negligible effects on aquatic biota because of a reduction of 

entrainment and impingement of organisms or a reduced 

release of chemicals. 

Accumulation of 

contaminants in 

sediments or biota 

Generic SMALL. Accumulation of contaminants has been a concern at a 

few nuclear power plants but has been satisfactorily mitigated 

by replacing copper alloy condenser tubes with those of another 

metal. It is not expected to be a problem during the license 

renewal term. 

Entrainment of 

phytoplankton and 

zooplankton 

Generic SMALL. Entrainment of phytoplankton and zooplankton has not 

been found to be a problem at operating nuclear power plants 

and is not expected to be a problem during the license renewal 

term. 

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

operating nuclear plants with once-through cooling systems, 

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

problem at operating nuclear power plants with cooling towers 

or cooling ponds, and is not expected to be a problem during 

the license renewal term. 

Thermal plume barrier 

to migrating fish 

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

at operating nuclear power plants and are not expected to be a 

problem during the license renewal term. 

Distribution of aquatic 

organisms 

Generic SMALL. Thermal discharge may have localized effects but is 

not expected to affect the larger geographical distribution of 

aquatic organisms. 

Premature emergence 

of aquatic insects 

Generic SMALL. Premature emergence has been found to be a 

localized effect at some operating nuclear power plants but has 

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

the license renewal term. 
Appendix B 

February 2010 B-3 Draft NUREG-1437, Supplement 41 

Issue Type of Issue Finding 

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. 

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. 
Appendix B 

Draft NUREG-1437, Supplement 41 B-4 February 2010 

Issue Type of Issue Finding 

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. 

Ground Water Use and Quality 

Impacts of 

refurbishment on 

ground water 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. 

Ground water 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 ground water use conflicts. 

Ground water use 

conflicts (potable and 

service water, and 

dewatering plants that 

use >100 gpm 

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

100 gpm may cause ground water use conflicts with nearby 

ground water users. See § 51.53(c)(3)(ii)(C). 

Ground water 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 ground water or upstream surface water 

users come online before the time of license renewal. See § 

51.53(c)(3)(ii)(A). 

Ground water use 

conflicts (Ranney 

wells) 

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

potential ground water depression beyond the site boundary. 

Impacts of large ground water withdrawal for cooling tower 

makeup at nuclear power plants using Ranney wells must be 

evaluated at the time of application for license renewal. See 

§ 51.53(c)(3)(ii)(C). 

Ground water quality 

degradation (Ranney 

wells) 

Generic SMALL. Ground water quality at river sites may be degraded by 

induced infiltration of poor-quality river water into an aquifer that 

supplies large quantities of reactor cooling water. However, the 

lower quality infiltrating water would not preclude the current 

uses of ground water and is not expected to be a problem 

during the license renewal term. 

Ground water quality 

degradation (saltwater 

intrusion) 

Generic SMALL. Nuclear power plants do not contribute significantly to 

saltwater intrusion. 

Ground water quality 

degradation (cooling 

ponds in salt 

marshes) 

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

ground water quality. Because water in salt marshes is 

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

Ground water quality 

degradation (cooling 

ponds at inland sites) 

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

cooling ponds may degrade ground water quality. For plants 

located inland, the quality of the ground water 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). 
Appendix B 

February 2010 B-5 Draft NUREG-1437, Supplement 41 

Issue Type of Issue Finding 

Terrestrial Ecology

Refurbishment 

impacts

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

insignificant if no loss of important plant and animal habitat 

occurs. However, it cannot be known whether important plant 

and animal communities may be affected until the specific 

proposal is presented with the license renewal application. See 

§ 51.53(c)(3)(ii)(E). 

Cooling tower impacts 

on crops and 

ornamental vegetation 

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

humidity associated with cooling tower operation have not been 

found to be a problem at operating nuclear power plants and 

are not expected to be a problem during the license renewal 

term. 

Cooling tower impacts 

on native plants 

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

humidity associated with cooling tower operation have not been 

found to be a problem at operating nuclear power plants and 

are not expected to be a problem during the license renewal 

term. 

Bird collisions with 

cooling towers 

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

at operating nuclear power plants and are not expected to be a 

problem during the license renewal term. 

Cooling pond impacts 

on terrestrial 

resources 

Generic SMALL. Impacts of cooling ponds on terrestrial ecological 

resources are considered to be of small significance at all sites. 

Power line right of 

way (ROW) 

management (cutting 

and herbicide 

application) 

Generic SMALL. The impacts of ROW maintenance on wildlife are 

expected to be of small significance at all sites. 

Bird collisions with 

power lines 

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

sites. 

Impacts of 

electromagnetic fields 

on flora and fauna 

Generic SMALL. No significant impacts of electromagnetic fields on 

terrestrial flora and fauna have been identified. Such effects are 

not expected to be a problem during the license renewal term. 

Floodplains and 

wetland on power line 

ROW 

Generic SMALL. Periodic vegetation control is necessary in forested 

wetlands underneath power lines and can be achieved with 

minimal damage to the wetland. No significant impact is 

expected at any nuclear power plant during the license renewal 

term. 

Threatened and Endangered Species 

Threatened or 

endangered species 

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

refurbishment and continued operation are not expected to 

adversely affect threatened or endangered species. However, 

consultation with appropriate agencies would be needed at the 

time of license renewal to determine whether or not threatened 

or endangered species are present and whether or not they 

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

Draft NUREG-1437, Supplement 41 B-6 February 2010 

Issue Type of Issue Finding 

Air Quality 

Air quality during 

refurbishment 

(non-attainment 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 number of workers 

expected to be employed during the outage. See 

§ 51.53(c)(3)(ii)(F). 

Air quality effects of 

transmission lines 

Generic SMALL. Production of ozone and oxides of nitrogen is 

insignificant and does not contribute measurably to ambient 

levels of these gases. 

Land Use 

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

refurbishment and the renewal period would be a small fraction 

of any nuclear power plant site and would involve land that is 

controlled by the applicant. 

Power line ROW Generic SMALL. Ongoing use of power line ROWs would continue with 

no change in restrictions. The effects of these restrictions are of 

small significance. 

Human Health 

Radiation exposures 

to the public during 

refurbishment 

Generic SMALL. During refurbishment, the gaseous effluents would 

result in doses that are similar to those from current operation. 

Applicable regulatory dose limits to the public are not expected 

to be exceeded. 

Occupational radiation 

exposures during 

refurbishment 

Generic SMALL. Occupational doses from refurbishment are expected 

to be within the range of annual average collective doses 

experienced for pressurized-water reactors and boiling-water 

reactors. Occupational mortality risk from all causes including 

radiation is in the mid-range for industrial settings. 

Microbiological 

organisms 

(occupational health) 

Generic SMALL. Occupational health impacts are expected to be 

controlled by continued application of accepted industrial 

hygiene practices to minimize exposure to workers. 

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. 
Appendix B 

February 2010 B-7 Draft NUREG-1437, Supplement 41 

Issue Type of Issue Finding 

Electromagnetic fields 

– acute effects 

(electric shock) 

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

from direct access to energized conductors or from induced 

charges in metallic structures have not been found to be a 

problem at most operating plants and generally are not 

expected to be a problem during the license renewal term. 

However, site-specific review is required to determine the 

significance of the electric shock potential at the site. See § 

51.53(c)(3)(ii)(H). 

Electromagnetic fields 

– chronic effects 

Uncategorized UNCERTAIN. Biological and physical studies of 60-hertz (Hz) 

electromagnetic fields have not found consistent evidence 

linking harmful effects with field exposures. However, research 

is continuing in this area and a consensus scientific view has 

not been reached. 

Radiation exposures 

to public (license 

renewal term) 

Generic SMALL. Radiation doses to the public will continue at current 

levels associated with normal operations. 

Occupational radiation 

exposures (license 

renewal term) 

Generic SMALL. Projected maximum occupational doses during the 

license renewal term are within the range of doses experienced 

during normal operations and normal maintenance outages, and 

would be well below regulatory limits. 

Socioeconomic Impacts 

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

expected to be of small significance at plants located in a 

medium or high population area and not in an area where 

growth control measures that limit housing development are in 

effect. Moderate or large housing impacts of the workforce 

associated with refurbishment may be associated with plants 

located in sparsely populated areas or in areas with growth 

control measures that limit housing development. See 

§ 51.53(c)(3)(ii)(I). 

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). 
Appendix B 

Draft NUREG-1437, Supplement 41 B-8 February 2010 

Issue Type of Issue Finding 

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 or not there are 

properties present that require protection. See 

§ 51.53(c)(3)(ii)(K). 

Aesthetic impacts 

(refurbishment) 

Generic SMALL. No significant impacts are expected during 

refurbishment. 

Aesthetic impacts 

(license renewal term) 

Generic SMALL. No significant impacts are expected during the license 

renewal term. 

Aesthetic impacts of 

transmission lines 

(license renewal term) 

Generic SMALL. No significant impacts are expected during the license 

renewal term. 

Postulated Accidents 

Design basis 

accidents 

Generic SMALL. The NRC staff has concluded that the environmental 

impacts of design-basis accidents are of small significance for 

all plants. 

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

releases, fallout onto open bodies of water, releases to ground 

water, and societal and economic impacts from severe 

accidents are small for all plants. However, alternatives to 

mitigate severe accidents must be considered for all plants that 

have not considered such alternatives. See § 51.53(c)(3)(ii)(L). 

Uranium Fuel Cycle and Waste Management 

Offsite radiological 

impacts (individual 

effects from other 

than the disposal of 

spent fuel and high 

level waste) 

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

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

on information in the GEIS, impacts on individuals from 

radioactive gaseous and liquid releases including radon-222 

and technetium-99 are small. 
Appendix B 

February 2010 B-9 Draft NUREG-1437, Supplement 41 

Issue Type of Issue Finding 

Offsite radiological 

impacts (collective 

effects) 

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

population from the fuel cycle, high level waste, and spent fuel 

disposal excepted, is calculated to be about 14,800 person 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 effect which will not ever be mitigated (for example no 

cancer cure in the next thousand years), and that these doses 

projected over thousands of years are meaningful; however, 

these assumptions are questionable. In particular, science 

cannot rule out the possibility that there will be no cancer 

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

very small fractions of regulatory limits, and even smaller 

fractions of natural background exposure to the same 

populations. 

Nevertheless, despite all the uncertainty, some judgment as to 

the regulatory NEPA implications of these matters should be 

made and it makes no sense to repeat the same judgment in 

every case. Even taking the uncertainties into account, the 

Commission concludes that these impacts are acceptable in 

that these impacts would not be sufficiently large to require the 

NEPA conclusion, for any plant, that the option of extended 

operation under 10 CFR Part 54 should be eliminated. 

Accordingly, while the Commission has not assigned a single 

level of significance for the collective effects of the fuel cycle, 

this issue is considered Category 1 (Generic). 

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 millirem per year or 

less. However, while the Commission has reasonable 

confidence that these assumptions will prove correct, there is 

considerable uncertainty since the limits are yet to be 

developed, no repository application has been completed or 

reviewed, and uncertainty is inherent in the models used to 

evaluate possible pathways to the human environment. The 

NAS report indicated that 100 millirem per year should be 

considered as a starting point for limits for individual doses, but 

notes that some measure of consensus exists among national 

and international bodies that the limits should be a fraction of 

the 100 millirem per year. The lifetime individual risk from 100 

millirem annual dose limit is about 3 x 10-3. 

Estimating cumulative doses to populations over thousands of 

years is more problematic. The likelihood and consequences of 
Appendix B 

Draft NUREG-1437, Supplement 41 B-10 February 2010 

Issue Type of Issue Finding 

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 wholebody dose commitment to the maximum individual and to the 

regional population resulting from several modes of breaching a 

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

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

Subsequently, the NRC and other federal agencies have 

expended considerable effort to develop models for the design 

and for the licensing of a high level waste repository, especially 

for the candidate repository at Yucca Mountain. More 

meaningful estimates of doses to population may be possible in 

the future as more is understood about the performance of the 

proposed Yucca Mountain repository. Such estimates would 

involve very great uncertainty, especially with respect to 

cumulative population doses over thousands of years. The 

standard proposed by the NAS is a limit on maximum individual 

dose. The relationship of potential new regulatory requirements, 

based on the NAS report, and cumulative population impacts 

has not been determined, although the report articulates the 

view that protection of individuals will adequately protect the 

population for a repository at Yucca Mountain. However, the 

EPA's generic repository standards in 40 CFR Part 191 

generally provide an indication of the order of magnitude of 

cumulative risk to population that could result from the licensing 

of a Yucca Mountain repository, assuming the ultimate 

standards will be within the range of standards now under 

consideration. The standards in 40 CFR Part 191 protect the 

population by imposing the amount of radioactive material 

released over 10,000 years. The cumulative release limits are 

based on the EPA's population impact goal of 1,000 premature 

cancer deaths worldwide for a 100,000 metric ton (MT) 

repository. 

Nevertheless, despite all the uncertainty, some judgment as to 

the regulatory NEPA implications of these matters should be 

made and it makes no sense to repeat the same judgment in 

every case. Even taking the uncertainties into account, the 

Commission concludes that these impacts are acceptable in 

that these impacts would not be sufficiently large to require the 

NEPA conclusion, for any plant, that the option of extended 

operation under 10 CFR Part 54 should be eliminated. 

Accordingly, while the Commission has not assigned a single 

level of significance for the impacts of spent fuel and high level 

waste disposal, this issue is considered in Category 1 (Generic). 

Nonradiological 

impacts of the 

uranium fuel cycle 

Generic SMALL. The nonradiological impacts of the uranium fuel cycle 

resulting from the renewal of an operating license for any plant 

are found to be small. 
Appendix B 

February 2010 B-11 Draft NUREG-1437, Supplement 41 

Issue Type of Issue Finding 

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 lowlevel waste disposal capacity will be made available when 

needed for facilities to be decommissioned consistent with NRC 

decommissioning requirements. 

Mixed waste storage 

and disposal 

Generic SMALL. The comprehensive regulatory controls and the 

facilities and procedures that are in place ensure proper 

handling and storage, as well as negligible doses and exposure 

to toxic materials for the public and the environment at all 

plants. License renewal will not increase the small, continuing 

risk to human health and the environment posed by mixed 

waste at all plants. The radiological and nonradiological 

environmental impacts of long-term disposal of mixed waste 

from any individual plant at licensed sites are small. In addition, 

the Commission concludes that there is reasonable assurance 

that sufficient mixed waste disposal capacity will be made 

available when needed for facilities to be decommissioned 

consistent with NRC decommissioning requirements. 

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

an additional 20 years of operation can be safely 

accommodated 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 NRC up to 62,000 megawatt days 

per metric-ton uranium Wd/MTU)and the cumulative impacts of 

transporting high-level waste to a single repository, such as 

Yucca Mountain, Nevada are found to be consistent with the 

impact values contained in 10 CFR 51.52(c), Summary Table 

S–4 – Environmental Impact of Transportation of Fuel and 

Waste to and from One Light-Water-Cooled Nuclear Power 

Reactor. If fuel enrichment or burnup conditions are not met, the 

applicant must submit an assessment of the implications for the 

environmental impact values reported in § 51.52. 

Decommissioning 

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

regulatory standards regardless of which decommissioning 

method is used. Occupational doses would increase no more 

than 1 man-rem caused by buildup of long-lived radionuclides 

during the license renewal term. 
Appendix B 

Draft NUREG-1437, Supplement 41 B-12 February 2010 

Issue Type of Issue Finding 

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

renewal period would generate no more solid wastes than at the 

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

Class C or greater than Class C wastes would be expected. 

Air quality Generic SMALL. Air quality impacts of decommissioning are expected to 

be negligible either at the end of the current operating term or at 

the end of the license renewal term. 

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

erosion or spills is no greater whether decommissioning occurs 

after a 20-year license renewal period or after the original 

40-year operation period, and measures are readily available to 

avoid such impacts. 

Ecological resources Generic SMALL. Decommissioning after either the initial operating 

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

to have any direct ecological impacts. 

Socioeconomic 

impacts 

Generic SMALL. Decommissioning would have some short-term 

socioeconomic impacts. The impacts would not be increased by 

delaying decommissioning until the end of a 20-year relicense 

period, but they might be decreased by population and 

economic growth. 

Environmental Justice 

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

environmental justice will be addressed in plant-specific 

reviews. 

1 
1 APPENDIX C. 

2 APPLICABLE REGULATIONS, LAWS, AND AGREEMENTS

February 2010 C-1 Draft NUREG-1437, Supplement 41 

1 C. APPLICABLE REGULATIONS, LAWS, AND AGREEMENTS 

2 The Atomic Energy Act (42 USC § 2021) authorizes U.S. Nuclear Regulatory Commission 

3 (NRC) to enter into agreement with any State to assume to assume regulatory authority for 

4 certain activities. For example, through the Agreement State Program, Nebraska assumed 

5 regulatory responsibility over certain byproduct, source, and small quantities of special nuclear 

6 material. The Nebraska Agreement State Program is administered by the Radiation Control 

7 Program (the program) in the Department of Health. The Program Manager reports to the 

8 Section Administrator for Consumer Health Services, who reports to the Division Director for 

9 Public Health Assurance, who in turn reports to the Director of Regulation and Licensure. 

10 In addition to implementing some Federal programs, State legislatures develop their own laws. 

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

12 and ground water. State legislation may address solid waste management programs, locally 

13 rare or endangered species, and historic and cultural resources. 

14 The Clean Water Act (CWA) allows for primary enforcement and administration through State 

15 agencies, provided the State program is at least as stringent as the Federal program. The State 

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

17 Pollutant Discharge Elimination System (NPDES) program from the EPA to the State. The 

18 primary mechanism to control water pollution is the requirement for direct dischargers to obtain 

19 an NPDES permit, or in the case of States where the authority has been delegated from the 

20 EPA, a State Pollutant Discharge Elimination System (SPDES) permit, pursuant to the CWA. In 

21 Nebraska, the Nebraska Department of Environmental Quality (NDEQ) issues and enforces 

22 NPDES permits. 

23 C.1. Federal Environmental Requirements 

24 Cooper Nuclear Station, Unit 1, (CNS-1) is subject to Federal requirements regarding their 

25 environmental program. Those requirements are briefly described below. See Section 1.9 for 

26 CNS-1’s compliance status with these requirements. 

27 Table C-1 provides a list of the principal Federal environmental regulations and laws that are 

28 applicable to the review of the environmental resources that could be affected by this project 

29 that may affect license renewal applications for nuclear power plants. 

30 Table C-1. Federal Environmental Requirements. 

Law/Regulation Requirements 

Current Operating License and License Renewal 

10 CFR Part 51. Code of 

Federal Regulations (CFR), 

Title 10, Energy, Part 51 

“Environmental Protection Regulations for Domestic Licensing and Related 

Regulatory Functions.” This part contains environmental protection regulations 

applicable to NRC's domestic licensing and related regulatory functions. 

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

Power Plants.” Part 54 of 10 CFR focuses on managing adverse effects of aging; 

rather than identification of all aging mechanisms. The rule is intended to ensure 

that important systems, structures, and components will continue to perform their 

intended function in the period of extended operation. 

10 CFR Part 50 Regulations promulgated by the NRC pursuant to the Atomic Energy Act of 1954, as 

amended (68 Stat. 919), and Title II of the Energy Reorganization Act of 1974 (88 
Appendix C 

Draft NUREG-1437, Supplement 41 C-2 February 2010 

Law/Regulation Requirements 

Stat. 1242), to provide for the licensing of production and utilization facilities. This 

part also gives notice to all persons who knowingly provide 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 

U.S.C. §7401 et seq.) 

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

emissions. Under CAA, Federal actions cannot thwart State and local efforts to 

remedy long-standing air quality problems that threaten public health issues 

associated with the six criteria air pollutants (i.e., ozone, nitrogen dioxide, sulfur 

dioxide, particulate matter, carbon monoxide, and lead). 

Water Resources Protection 

Section 404 of the Clean 

Water Act (CWA) (33 U.S.C. §

1344) 

Section 404 of the CWA established a program to regulate the discharge of 

dredged and fill material into waters of the United States, including wetlands. The 

Army Corps of Engineers (USACE) and the EPA jointly administer this program. 

Under the 404 program, no discharge of dredged or fill material is allowed if a 

practicable alternative exists that is less damaging to the aquatic environment or if 

the nation’s waters would be significantly degraded. A Federal permit is required to 

discharge dredged or fill material into wetlands and waters of the United States. 

Comprehensive 

Environmental Response, 

Compensation, and Liability 

Act (CERCLA)(42 U.S.C. §. 

9601 et seq) 

Section 101 of CERCLA requires a permit to cover consumptive water use over 

20,000 gallons per day (over a 30-day average) of surface and ground water. 

Wild and Scenic River Act (16 

U.S.C. §1271 et seq.) 

Created the National Wild and Scenic Rivers System, established to protect the 

environmental values of free flowing streams from degradation by impacting 

activities including water resources projects. 

Floodplain Executive Order 

(No. 11988. May 24, 1977, 42 

F.R. 26951) and Wetlands 

Executive Order (No. 11990. 

May 24, l977, 42 F.R. 26961) 

Both executive orders require Federal agencies to consider the impacts of their 

actions on floodplains and wetlands through existing review procedures such as 

National Environmental Policy Act of 1969. 

Law/Regulation Requirements 

Waste Management and Pollution Prevention 

Resource Conservation and 

Recovery Act (RCRA) (42 

USC § 6901et seq.) 

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

waste as defined under the RCRA. Hazardous waste is classified under Subtitle C 

of the RCRA. Parts 261 and 262 of Title 40 CFR contain all applicable generators of 

hazardous waste regulations. Part 261.5 (a) and (e) contains requirements for 

Conditionally Exempt Small Quantity Generators (CESQGs). Part 262.34(d) 

contains requirements for Small Quantity Generators (SQGs). Parts 262 and 

261.5(e) contain requirements for Large Quantity Generators (LQGs) 

Pollution Prevention Act (42 

U.S.C. § 13101 et seq) 

Formally established a national policy to prevent or reduce pollution at its source 

whenever feasible. The Act provides funds for State and local pollution prevention 

programs through a grant program to promote the use of pollution prevention 

techniques by business. 
Appendix C 

February 2010 C-3 Draft NUREG-1437, Supplement 41 

Law/Regulation Requirements 

Endangered Species 

Endangered Species Act 

(ESA) (16 U.S.C. § 1531 et 

seq.) 

Forbids any government agency, corporation, or citizen from taking (harming or 

killing) endangered animals without an Endangered Species Permit. 

Fish and Wildlife Coordination 

Act (16 U.S.C. § 661 et seq.) 

To minimize adverse impacts of proposed actions on fish and wildlife resources and 

habitat, requires that Federal agencies consult government agencies regarding 

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

also requires that justifiable means and measures be used in modifying plans to 

protect fish and wildlife in these waters. 

Historic Preservation 

National Historic Preservation 

Act (NHPA) (16 U.S.C. § 470 

et seq.) 

Directs Federal agencies to consider the impact of their actions on historic 

properties. NHPA also encourages state and local preservation societies. 

Farmland 

Farmland and Protection 

Policy Act (7 U.S.C. § 4201 et 

seq.) 

Requires that Federal programs, as practicable, shall be administered in a manner 

compatible with State and local government and private programs and policies to 

protect farmland. 

1 APPENDIX D. 

2 CONSULTATION CORRESPONDENCE

February 2010 D-1 Draft NUREG-1437, Supplement 41 

1 D. CONSULTATION CORRESPONDENCES 

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

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

4 require that Federal agencies consult with applicable State and Federal agencies and groups 

5 prior to taking action that may affect threatened and endangered species, essential fish habitat, 

6 or historic and archaeological resources, respectively. This appendix contains consultation 

7 documentation. 

8 Table D-1 provides a list of the consultation documents sent between the U.S. Nuclear 

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

10 these agencies based on the National Environmental Policy Act of 1969 (NEPA) requirements.

11 Table D-1. Consultation Correspondences. 

Author Recipient Date of Letter/Email 

U.S. Nuclear Regulatory Commission 

(D. Pelton) 

Nebraska State Historic Society 

(M. Smith) 

January 16, 2009 

(ML090080197) 

U.S. Nuclear Regulatory Commission 

(D. Pelton) 

Advisory Council on Historic Preservation 

(D. Klima) 

January 26, 2009 

(ML090080683) 

U.S. Nuclear Regulatory Commission 

(D. Pelton) 

Environmental Services Division, 

Environmental Protection Agency Region 7 

(J. Cothern) 

January 27, 2009 

(ML090230446) 

U.S. Nuclear Regulatory Commission 

(D. Pelton) 

Department of Health and Human 

Services, Regulation and Licensure, Public 

Health Assurance (J. Schmitt) 

January 28, 2009 

(ML090210249) 

U.S Nuclear Regulatory Commission 

(D. Pelton) 

U. S. Fish and Wildlife Service, Ecological 

Services – Nebraska Field Office 

(J. Cochnar) 

January 29, 2009 

(ML090070507) 

U.S Nuclear Regulatory Commission 

(D. Pelton) 

Missouri State Historic Society 

(M. Miles) 

January 29, 2009 

(ML090210750) 

Nebraska State Historical Society 

(J. Dolberg) 

U.S. Nuclear Regulatory Commission 

(D. Pelton) 

February 02, 2009 

(ML090650061) 

U.S Nuclear Regulatory Commission 

(D. Pelton) 

Nebraska Department of Natural 

Resources (A. Bleed) 

February 04, 2009 

(ML090260380) 

U.S. Nuclear Regulatory Commission 

(D. Pelton) 

U.S. Army Corps of Engineers, Omaha 

District (D. Press) 

February 04, 2009 

(ML090160476) 

U.S. Nuclear Regulatory Commission 

(D. Pelton) 

Sac and Fox Tribe of the Mississippi in 

Iowa (A. Pushetonequa)a

February 04, 2009 

(ML090080045) 

Nebraska Department of Natural 

Resources (J.Angell) 

U.S. Nuclear Regulatory Commission 

(D. Pelton) 

March 09, 2009 
Appendix D 

Draft NUREG-1437, Supplement 41 D-2 February 2010 

Author Recipient Date of Letter/Email 

Environmental Protection Agency 

Region 7 (L. Shepard) 

U.S. Nuclear Regulatory Commission 

(E. Sayoc) 

April 16, 2009 

(ML091070269) 

Nebraska Games and Parks 

Commission (R. Simpson) 

U.S. Nuclear Regulatory Commission 

(R. Bulavinetz) 

May 08, 2009 

(ML091400110) 

Fish and Wildlife Service (J. DeWeese) 

Nebraska Public Power District 

(J. Citta) 

June 8, 2009 

(ML091830055) 

a 1 Similar letters went to 14 other Native American Tribes listed in Section 1.8. 

2 D.1. Consultation Correspondence 

3 The following pages contain copies of the letters listed in Table D-1. 
Appendix D 

February 2010 D-3 Draft NUREG-1437, Supplement 41 

1 
Appendix D 

Draft NUREG-1437, Supplement 41 D-4 February 2010 

1 
Appendix D 

February 2010 D-5 Draft NUREG-1437, Supplement 41 

1 
Appendix D 

Draft NUREG-1437, Supplement 41 D-6 February 2010 

1 
Appendix D 

February 2010 D-7 Draft NUREG-1437, Supplement 41 

1 
Appendix D 

Draft NUREG-1437, Supplement 41 D-8 February 2010 

1 
Appendix D 

February 2010 D-9 Draft NUREG-1437, Supplement 41 

1 
Appendix D 

Draft NUREG-1437, Supplement 41 D-10 February 2010 

1 
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February 2010 D-11 Draft NUREG-1437, Supplement 41 

1 
Appendix D 

Draft NUREG-1437, Supplement 41 D-12 February 2010 

1 
Appendix D 

February 2010 D-13 Draft NUREG-1437, Supplement 41 

1 
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Draft NUREG-1437, Supplement 41 D-14 February 2010 

1 
Appendix D 

February 2010 D-15 Draft NUREG-1437, Supplement 41 

1 
Appendix D 

Draft NUREG-1437, Supplement 41 D-16 February 2010 

1 
Appendix D 

February 2010 D-17 Draft NUREG-1437, Supplement 41 

1 
Appendix D 

Draft NUREG-1437, Supplement 41 D-18 February 2010 

1 
Appendix D 

February 2010 D-19 Draft NUREG-1437, Supplement 41 

1 
Appendix D 

Draft NUREG-1437, Supplement 41 D-20 February 2010 

1 
Appendix D 

February 2010 D-21 Draft NUREG-1437, Supplement 41 

1 
Appendix D 

Draft NUREG-1437, Supplement 41 D-22 February 2010 

1 
Appendix D 

February 2010 D-23 Draft NUREG-1437, Supplement 41 

1 
Appendix D 

Draft NUREG-1437, Supplement 41 D-24 February 2010 

1 
Appendix D 

February 2010 D-25 Draft NUREG-1437, Supplement 41 

1 
Appendix D 

Draft NUREG-1437, Supplement 41 D-26 February 2010 

1 
Appendix D 

February 2010 D-27 Draft NUREG-1437, Supplement 41 

1 
Appendix D 

Draft NUREG-1437, Supplement 41 D-28 February 2010 

1 
Appendix D 

February 2010 D-29 Draft NUREG-1437, Supplement 41 

1 

2 
Appendix D 

Draft NUREG-1437, Supplement 41 D-30 February 2010 

1 
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February 2010 D-31 Draft NUREG-1437, Supplement 41 

1 
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Draft NUREG-1437, Supplement 41 D-32 February 2010 

1 
Appendix D 

February 2010 D-33 Draft NUREG-1437, Supplement 41 

1 
Appendix D 

February 2010 D-34 Draft NUREG-1437, Supplement 41 
Appendix D 

February 2010 D-35 Draft NUREG-1437, Supplement 41 
Appendix D 

Draft NUREG-1437, Supplement 41 D-36 February 2010 
Appendix D 

Draft NUREG-1437, Supplement 41 D-37 February 2010 

APPENDIX D. 2 BIOLOGICAL ASSESSMENT 

COOPER NUCLEAR STATION LICENSE 

RENEWAL DATE 2009 DOCKET NO. 50-298 

U.S. NUCLEAR REGULATORY COMMISSION 

ROCKVILLE, MARYLAND

February 2010 D.2-1 Draft NUREG-1437, Supplement 41 

1 D.2 BIOLOGICAL ASSESSMENT OF THE POTENTIAL EFFECTS ON FEDERALLY 

2 LISTED ENDANGERED OR THREATENED SPECIES FROM THE PROPOSED 

3 LICENSE RENEWAL FOR COOPER NUCLEAR STATION 

4 D.2.1 INTRODUCTION AND PURPOSE 

5 The U.S. Nuclear Regulatory Commission (NRC) prepared this biological assessment (BA) to 

6 support the draft supplemental environmental impact statement (SEIS) for the renewal of the 

7 operating licenses for Cooper Nuclear Station Unit 1 (CNS-1), located on the western shore of 

8 the Missouri River near the Village of Brownville, Nemaha County, Nebraska. The current 40-

9 year license expires in 2014. The proposed license renewal for which this BA has been 

10 prepared would extend the operating licenses to 2034. 

11 The NRC is required to prepare the draft SEIS as part of its review of a license renewal 

12 application. The draft SEIS supplements NUREG-1437, Volumes 1 and 2, Generic 

13 Environmental Impact Statement (GEIS) for License Renewal of Nuclear Plants, (NRC 1996, 

1999)a 14 for the license renewal of commercial nuclear power plants. The draft SEIS covers 

15 specific issues, such as the potential impact on endangered and threatened species, that are of 

16 concern at CNS-1 and that NRC could not address generically in the GEIS. 

17 Pursuant to Section 7 of the Endangered Species Act (ESA) of 1973, as amended (16 U.S.C. § 

18 1536(a)-(d)), the NRC staff requested, in a letter dated January 29, 2009 (NRC, 2009), that the 

19 U.S. Fish and Wildlife Service (USFWS) provide information on Federally listed endangered or 

20 threatened species, as well as on proposed or candidate species, and on any designated critical 

21 habitats that may occur in the vicinity of CNS-1. Under Section 7, the NRC is responsible for 

22 providing information on the potential impact that the continued operation of CNS-1 could have 

23 on the Federally listed species, the pallid sturgeon. 

24 D.2.2 PROPOSED ACTION 

25 The proposed action considered in the SEIS is the renewal of the CNS-1 operating license for 

26 an additional 20-year term beyond the period of the existing licenses. If the NRC grants the 

27 operating license renewal, the applicant can operate and maintain the nuclear unit, the cooling 

28 system, and the transmission lines and corridors as they are now until 2034. 

29 D.2.3 SITE DESCRIPTION 

30 CNS-1 is located in Nemaha County, Nebraska 2.25 miles (3.6 km) southeast of Brownville, 

31 Nebraska and approximately 60 miles (96 km) southeast of Lincoln, Nebraska. CNS-1 property 

32 is bounded on the east by the Missouri River and by non-Nebraska Public Power District 

33 (NPPD) owned property on the north, south, and west. Figure 3-1 shows a map of a 50-mile 

34 (80-km) radius around CNS-1. Figure 3-2 shows the area within a 6-mile (9.6-km) radius of 

35 CNS-1. NPPD owns and operates the site. The structures for CNS-1 span approximately 55 

36 acres (22 ha) of the site’s total area of approximately 1,359 acres (550 ha), including 239 acres 

37 (97 ha) on the opposite bank (east) of the Missouri River in Atchison County, Missouri. Over 99 

38 percent of the acreage in Nemaha County is used for agriculture and farming. NPPD currently 

 

a

 The GEIS was originally issued in 1996. Addendum 1 to the GEIS was issued in 1999. Hereafter, all references 

to the “GEIS” include the GEIS and its Addendum 1. 
Appendix D.2 

Draft NUREG-1437, Supplement 41 D.2-2 February 2010 

1 leases 234 acres (947 ha) of the property in Missouri and 715 acres (289 ha) in Nebraska for 

2 agricultural activities such as farming and livestock. 

3 

4 Figure 3-1. Location of Cooper Nuclear Station Unit 1, 50-mile (80-km) Region 

5 (Source: NPPD, 2008b)
Appendix D.2 

February 2010 D.2-3 Draft NUREG-1437, Supplement 41 

1 

2 Figure 3-2. Location of Cooper Nuclear Station Unit 1, 6-miles (10-km) Region 

3 (Source: NPPD, 2008b) 
Appendix D.2 

Draft NUREG-1437, Supplement 41 D.2-4 February 2010 

1 CNS-1 is a single-unit boiling water reactor plant with a nuclear steam supply system supplied 

2 by General Electric Company and a turbine generator set supplied by Westinghouse Electric 

3 Corporation. CNS-1 achieved commercial operation in 1974 with an initial licensed core thermal 

4 power of 2,381 megawatt-thermal (MWt). In 2008, with NRC approval, the applicant performed 

5 a measurement uncertainty recapture uprate that increased the core thermal power by 1.62 

6 percent to its current level of 2,419 MWt and 830 megawatt-electric (MWe) (NPPD, 2008b). 

7 Figure 3-3 shows the general layout of the buildings at CNS-1. The principal structures at CNS8 1 consist of the reactor building, turbine building (including service area appendages), control 

9 building, controlled corridor, radwaste building, augmented radwaste building, intake structure, 

10 off-gas filter building, elevated release point, diesel generator building, multi-purpose facility, 

11 railroad airlock, drywell and suppression chamber, miscellaneous circulating water system 

12 structures (e.g., circulating water conduits, seal well), optimum water chemistry gas generator 

13 building, and office building. Visually dominant features are the 290-foot (88-m) tall reactor 

14 building, the 325-foot (99-m) tall elevated release point, and the 328.8-foot (100-m) tall 

15 meteorological tower. 
Appendix D.2 

February 2010 D.2-5 Draft NUREG-1437, Supplement 41 

1 

2 Figure 3-3. Cooper Nuclear Station Unit 1, General Site Layout (Source: NPPD, 2008b)

3 CNS-1 lies on the western shore of the Missouri River, withdraws river water for its once4 through cooling system, and discharges heated water back to the river. Unless otherwise cited, 

5 NRC staff drew information about CNS-1’s cooling and auxiliary water systems from NPPD 

6 (2006b) and the applicant’s environmental report (ER) (NPPD, 2008b), where more in-depth 

7 information appears. In the vicinity of the plant, the Missouri River has a regulated minimum flow 

of 31,000 cubic feet per second (cfs) (878 m3 8 /sec) to the southeast. The circulating water intake 

9 structure is located on the western shore of the river behind a guide wall and submerged weir 

10 meant to reduce the amount of suspended sediment in the cooling water. The weir attaches to 

11 shoreline structures north of the intake and then runs parallel to the face of the intake at a 

12 distance of 14.25 feet (4.3 m). The wall continues past the intake and ends 40 feet (12 m) 

13 downstream of the corner of the intake structure. In a line riverward of the weir wall and 
Appendix D.2 

Draft NUREG-1437, Supplement 41 D.2-6 February 2010 

1 extending downstream of it, 23 sheet pile vanes (10 feet wide by 6 feet high (3 m wide by 2 m 

2 high)), oriented at a 22 degree angle to the weir, redirect sand and gravel outward from the weir 

3 and the intake structure. After flowing generally south along the weir and vanes, river water 

4 must reverse course and turn northwest to move between the weir and shore and reach the 

5 intake bays. Water velocity between the weir wall and the cooling water intake structure is about 

6 4 ft/sec (1.2 m/sec). 

7 In winter, about 25 to 30 percent of the main condenser discharge water re-circulates through 

8 an ice control tunnel at the front of the intake structure and discharges in front of the trash rack 

9 to prevent icing. Water flows beneath a curtain wall at about 1.1 ft/sec (0.34 m/sec). Water 

10 enters the five intake bays, four of which provide circulating water and are 22 feet (6.7 m) wide 

11 and one of which provides service water and is 22.5 feet (6.8 m) wide. The incoming water then 

12 flows through trash racks, 3/8 inch (1 cm) vertical bars separated 3 inches (7.6 cm) on center, at 

13 up to 0.7 ft/sec (20 cm/sec). 

14 The circulating water intake bays each separate into two screen bays and the service water 

15 intake bay narrows before water encounters the traveling screens, which are oriented at right 

16 angles to the flow. Water filters through 1/8 by 1/2-inch (3.175 by 1.27 cm) smooth-top mesh of 

17 nine modified dual-flow traveling screens (eight for circulating water and one for service water) 

18 twice: on the upward pass in the front and the downward pass behind as the screens, installed 

19 in 2006, rotate continuously at 8.2 ft/min (2.5 m/min). The intake water velocity at the screens is 

20 about 2 ft/sec (0.6 m/sec). 

21 After the 4.2-foot (1.28-m) wide traveling screen panels rotate over the upper cog and begin 

22 moving down, a high pressure (30-60 psig, 200-400 kPa) screen wash of 3,000 gallons per 

minute (gpm) (0.19 m3 23 /sec) supplied by the service water pumps removes fish and debris, which 

24 return together to the river through an 18-inch (0.46-m) diameter steel pipe that discharges 

25 downstream from the intake. Although the screens are fitted with fish baskets, the system has 

26 neither a low-pressure spray system to more gently remove fish from the screens nor a fish 

27 return trough to convey fish and other aquatic organisms back to the river separately from 

potentially damaging debris. Debris loads are about 10 cubic yards per month (8 m3 28 /month). 

29 CNS-1 plans to install “dual-flow conversion screen fish handling systems” during its current 

30 operational term. This system would have low pressure (5-10 psi, 35-70 kPa) fish washing 

31 sprays on both the ascending and descending screens and a fish return trough that is separate 

32 from the debris trough. A recovery basket would collect fish and other aquatic organisms 

33 washed from the screens, and the fish trough would return them to the river. Figures 3-4 

34 through 3-6 show the CNS-1 intake structures. 
Appendix D.2 

February 2010 D.2-7 Draft NUREG-1437, Supplement 41 

1 

2 Figure 3-4. Cooper Nuclear Station Unit 1 Intake Structure Plan (Source: NPPD, 2008b)

3 

4 Figure 3-5. Cooper Nuclear Station Unit 1 Intake Structure Section (Source: NPPD, 2008b)
Appendix D.2 

Draft NUREG-1437, Supplement 41 D.2-8 February 2010 

1 

2 Figure 3-6. Cooper Nuclear Station Unit 1 Typical Dual Flow Screen 

3 (Source: NPPD, 2008b)

4 After water passes through the traveling screens, the two screen bays of each intake bay rejoin 

5 behind the screens. The four circulating water pumps, one per bay, can draw water from the 

bays and can provide up to 159,000 gpm (10 m3 6 /sec) each. The four service water pumps in the 

fifth bay can provide a combined flow of 32,000 gpm (2 m3 7 /sec). Water from the circulating 

8 water pumps travels to and circulates through the condenser, where it cools steam from the 

9 turbines. Because of the scouring from the suspended sediment, CNS-1 typically does not need 
Appendix D.2 

February 2010 D.2-9 Draft NUREG-1437, Supplement 41 

1 to chlorinate the circulating water to control biological film fouling, although it has the capacity to 

2 chlorinate or brominate if needed. NPPD is studying the effectiveness of those options. 

3 Water temperature increases about 17.8 °F (10 °C) as it passes through the condenser tubes. 

4 From the condenser, circulating cooling water flows through concrete tunnels to a seal well 

5 structure and then to the discharge canal, where it travels about 1,000 ft (300 m) to discharge to 

6 the river at a slight angle. Water velocity at the discharge is about 1 ft/sec (0.3 m/sec) at 

7 average river flow and about 5.6 ft/sec (1.7 m/sec) during low flows. The travel time from the 

8 intake structure to the discharge is about 20 minutes at high river flow and 10 to 12 minutes at 

9 low flows. 

10 Cooling water flow varies with electrical load and ambient river water temperature. At full load 

11 during summer, the expected circulating water system flow is highest: about 636,000 gpm 

(40 m3 12 /sec). Circulating water flow is lower under other conditions. In comparison, the lowest 

13 river flow at CNS-1 is about 3,000 cfs. Under these worst conditions, the circulating water 

14 system flow would be about 47 percent of the Missouri River flow. Stone rip-rap at the discharge 

15 structure prevents the discharge from eroding the river bottom. 

16 D.2.4 STATUS REVIEW OF PALLID STURGEON 

17 D.2.4.1 Life History 

18 Sturgeons are members of an order of fish (Acipenseriformes) that probably evolved in the 

19 Devonian age. Living members of this order in North America include the paddlefish and eight 

20 sturgeon species. The paddlefish Polyodon spathula and three sturgeon species, the lake 

21 sturgeon Acipenser fulvescens, pallid sturgeon Scaphirhynchus albus, and the shovelnose 

22 sturgeon S. platorynchus, live in the Missouri and Mississippi Rivers. In the past, commercial 

23 fishermen harvested all three of the sturgeon species in the Missouri and Mississippi rivers. 

24 Today pallid sturgeon are a Federally-listed endangered species, and lake sturgeon are listed 

25 as endangered by Nebraska. The life history information below is from Dryer and Sandvol 

26 (1993) and USFWS (2007) if not otherwise cited. 

27 Pallid sturgeon have a flattened snout, a long tail, and rows of bony armor plates. The upper 

28 side is convex and the lower side is straight. They have an inferior (bottom-facing) mouth and 

29 eat invertebrates, such as the immature stages of insects, and fish. The body shape is well 

30 adapted for swimming close to the bottom of relatively fast flowing, large rivers. The diet, inferior 

31 mouth, and barbels in front of the mouth are well adapted to feeding on or near the bottom in 

32 highly turbid environments. 

33 The USFWS listed pallid sturgeon as endangered in 1990. The historic abundance of pallid 

34 sturgeon is somewhat vague since biologists did not recognize it as a separate species from 

35 shovelnose sturgeon until 1905, but its historical range probably extended from the middle and 

36 lower Mississippi River in the south up through the Missouri River and lower reaches of the 

37 Platte, Kansas, and Yellowstone rivers in the north and west. The pallid sturgeon is one of the 

38 largest fish species in those rivers. Available information suggests that the pallid sturgeon was 

39 not a common species since the time of European settlement. Today pallid sturgeon are among 

40 the rarest fish of the Missouri and Mississippi River basins, and the present range includes the 

41 States of Montana, North and South Dakota, Nebraska, Iowa, Kansas, Missouri, Illinois, 

42 Kentucky, Arkansas, Mississippi, and Louisiana. The populations are largely older fish that will 

43 die off in the near future. 
Appendix D.2 

Draft NUREG-1437, Supplement 41 D.2-10 February 2010 

1 Fisheries biologists know little about pallid sturgeon reproduction or even preferred spawning 

2 habitats and conditions. Hurleya et al. (2004) tracked sonically-tagged pallid sturgeon in the 

3 Mississippi River and found that they exhibited positive selection for the main-channel border, 

4 downstream island tips, between-wing-dam, and wing-dam-tip habitats; they showed negative 

5 selection for main-channel, downstream of wing dams, and upstream of wing dam habitats. The 

6 sturgeon exhibited little habitat selection for temperature or dam discharge. The authors 

7 concluded that habitat enhancement and restoration of habitat diversity might be necessary for 

8 recovery of pallid sturgeon. 

9 Reports of pallid sturgeon reproduction are rare. The U.S. Geological Survey (USGS) (2007), 

10 Nebraska Game and Parks Commission (NGPC), and the U.S. Army Corps of Engineers 

11 (USACE) confirmed spawning of two female pallid sturgeon in the upstream reaches of the 

12 lower Missouri River in May 2007. The capture of young pallid sturgeon that would verify natural 

13 reproduction are also rare: none were captured between 1978 and a Mississippi River trawl 

14 survey in 1998 through 2000 using equipment designed to capture larval fish in deep, turbulent 

15 water (Hrabik et al., 2007). Hrabik et al. (2007) concluded that those latest captures verified 

16 reproduction, possibly from the lower Missouri River to the upper and lower Mississippi River, 

17 although they also found no evidence of recruitment of pallid sturgeon because they captured 

18 no juveniles after 374 trawl hauls that captured over 21,735 fish in that 1998 through 2000 

19 survey. Wildhaber et al. (2007) suggest that one or more of the following factors may be 

20 responsible for the lack of finding larval pallid sturgeon and of recruitment: lack of successful 

21 spawning, low recruitment, high mortality, ineffective sampling methods, inadequate sampling of 

22 drift and settling locations, or rapid dispersal and washout of sturgeon larvae in the Missouri and 

23 Mississippi rivers. Pallid sturgeon larvae are indistinguishable from those of the congeneric 

24 shovelnose sturgeon, which may also help to explain the paucity of reported collections in the 

25 past. Also, the construction of dams and other structures with resulting habitat change and the 

26 elimination of shallow areas in the river with little or no flow have probably deprived sturgeon of 

27 critical nursery areas needed for the survival of immature sturgeon (Missouri Department of 

28 Conservation, 2009). 

29 Larval pallid and shovelnose sturgeon become strongly photopositive and migrate upwards 

30 toward the light starting the first day after hatching. As a result, they remain far above the 

31 bottom, even at the water surface, and migrate far downriver (Kynard et al., 2002). Cultured 

32 yearling pallid sturgeon in laboratory studies also migrate downstream during summer and fall, 

33 which suggests a two-stage (larval, then yearling) downriver migration in the first year of life. 

34 Adult sturgeon are also highly migratory and often migrate hundreds of miles in a year. 

35 The young of both shovelnose and pallid sturgeon eat invertebrates, but as pallid sturgeon 

36 grow, they become more piscivorous. Gerrity and Guy (2006) found that the diet of juvenile 

37 pallid sturgeon of age 6 and 7 was mostly fish, compared to the diet of shovelnose sturgeon, 

38 which is mainly aquatic insects. Sturgeon chub (Macrhybopsis gelida) and sicklefin chub (M. 

39 meeki) together comprised 79 percent of the number of identifiable fish in juvenile pallid 

40 sturgeon stomachs. Populations of these two cyprinid minnows have declined throughout much 

41 of the Missouri River due to the construction of dams and man’s other alterations of river 

42 habitat, and the State of Nebraska lists sicklefin chub as threatened and sturgeon chub as 

43 endangered. While the population of the piscivorous pallid sturgeon has declined in the Missouri 

44 and Mississippi rivers, the population of its similar, insectivorous congener, shovelnose 

45 sturgeon, has not declined. Gerrity and Guy (2006) concluded that the prevalence of sicklefin 

46 chub and sturgeon chub as a food resource of juvenile pallid sturgeon may help explain the 

47 decline of pallid sturgeon populations and that recovery and management of native cyprinids is 

48 a potentially important step in the recovery of pallid sturgeon. 
Appendix D.2 

February 2010 D.2-11 Draft NUREG-1437, Supplement 41 

1 Male pallid sturgeon are believed to mature at 7 to 9 years after which they spawn at intervals of 

2 2 to 3 years. Females may reach sexual maturity at 7 to 15 years and spawn at intervals up to 

3 10 years. Individuals may reach ages of 60 years or more and reach lengths of 6 feet (2 m). 

4 Like many other fish species, the largest individuals are found farthest north in the species’ 

5 range and maximum size decreases with distance south. For example, the maximum weight of 

6 pallid sturgeon in the upper Missouri River in Montana and North Dakota is 86 pounds (39 kg), 

7 in the Missouri River in South Dakota and Nebraska 46 pounds (21 kg), and in the Mississippi 

8 River 26 pounds (12 kg). They become much larger than shovelnose sturgeon, which rarely 

9 weigh more than 8 pounds (3.6 kg). 

10 D.2.4.2 Status of Pallid Sturgeon in the Missouri River 

11 While they were successful in the historical Missouri and Mississippi rivers, with the high flow 

12 and turbidity and diverse habitats of floodplains, backwaters, chutes, sloughs, islands, sand and 

13 gravel bars, and both braided and main channels, they are not so well adapted to the Missouri 

14 and Mississippi rivers today with the construction of dams that isolated subpopulations, 

15 channelization, controlled flow, and elimination of habitat diversity. The USFWS (2007) 

16 concludes that man’s activities have adversely affected all of the 3,350 miles (5,390 km) of river 

17 habitat within their range, and habitat alteration and loss may be the biggest threat to their 

18 existence. Other threats may include hybridization with shovelnose sturgeon, commercial 

19 fishing, and exposure to environmental contaminants such as polychlorinated biphenyls (PCBs), 

20 cadmium, mercury, selenium, chlordane, dichlorodiphenyltrichloroethane (DDT), 

21 dichlorodiphenyltrichloroethylene (DDE), and dieldrin, all of which have been found in pallid 

22 sturgeon tissue in the past. 

23 During the early 1990s, the Missouri Department of Conservation (MDC) developed "action 

24 plans" for lake and pallid sturgeon a goal of reestablishing self-sustaining populations so they 

25 can be delisted as endangered species and ultimately provide limited sport fisheries. These 

26 plans stress the restoration of both species through habitat improvement, artificial propagation, 

27 protection, research, management, and education (MDC, 2009). As part of this effort, the MDC's 

28 Blind Pony Fish Hatchery has raised and stocked over 13,000 fingerling pallid sturgeon and 

29 200,000 fingerling lake sturgeon into the Missouri and Mississippi rivers (MDC, 2009). In 

30 addition to these efforts, the USGS (Wildhaber et al., 2007) has developed a conceptual life 

31 history to organize the understanding about the complex life history of Scaphirhynchus 

32 sturgeons and improve understanding of the effects of management actions on the ecological 

33 requirements of pallid and shovelnose sturgeons. The USFWS’s Pallid Sturgeon Recovery Plan 

34 (Dryer and Sandvol, 1993) designated six recovery priority management areas (RPMAs) for 

35 implementation of recovery tasks, and CNS-1 is located within RPMA 4. 

36 D.2.4.3 Impact Assessment of Cooper Nuclear Station on Pallid Sturgeon 

37 NPPD (2008a) summarizes interactions between NPPD and both State and Federal agencies 

38 regarding conservation of pallid sturgeon. That summary is outlined below: 

39 In March 2006, before filing a license renewal application with NRC, NPPD voluntarily 

40 participated in meetings with the USFWS, the NGPC, the Nebraska Department of 

41 Environmental Quality (NDEQ), the Nebraska Department of Natural Resources (DNR), the 

42 EPA, and the USACE regarding conservation actions to improve the habitat of pallid sturgeon. 

43 NPPD (2008a) summarizes those meetings. Early in the discussions, the USFWS and NGPC 

44 showed interest in developing existing habitat on a parcel of property south of CNS-1 at 

45 Langdon Bend and later also in CNS-1 property on the Nebraska side of the Missouri River 
Appendix D.2 

Draft NUREG-1437, Supplement 41 D.2-12 February 2010 

1 adjacent to Langdon Bend. They hoped to enhance pallid sturgeon habitat by building a chute to 

2 connect active river channels with the old river area. 

3 NPPD had problems with this proposal. Implementing the proposal would reduce CNS-1’s 

4 mixing zone, which now extends 5,000 feet south of CNS-1 along the Nebraska side of the 

5 Missouri River, to less than half, less than 2,500 feet. Reducing the mixing zone would reduce 

6 CNS-1’s capacity to generate electricity, particularly during summer. The proposal also posed 

7 other negative safety and environmental concerns for CNS-1. As an alternative, NPPD then 

8 offered to contribute funds toward other new or existing projects on the Missouri River. The 

9 USFWS rejected this funding alternative in favor of increasing the amount of land for habitat 

10 development. 

11 To meet the goal of improving habitat for pallid sturgeon, NPPD offered a conservation 

12 easement of about 230 acres (93 ha) of land that it owns on the Missouri side of the Missouri 

13 River, opposite CNS-1, for the purposes of habitat development. The USFWS indicated interest 

14 in the proposal, and asked NPPD to also acquire an adjacent property of about 150 acres 

15 (51 ha) so that the entire bend in the river could be developed into better habitat. When the 

16 property owner refused to sell the land, NPPD offered a revised, final proposal to participate in 

17 and promote habitat development along the Missouri River. It proposed to revisit the USFWS’s 

18 and NGPC’s interest in a suitable conservation easement and Memorandum of Understanding 

19 to enable habitat development on NPPD’s approximately 230-acre (93-ha) parcel on the 

20 Missouri side of the river. Further, because NPPD recognized that this parcel alone would not 

21 meet the USFWS’s and NGPC’s conservation habitat development goals, NPPD indicated that 

22 its willingness to make an additional payment of $250,000 to be applied toward another 

23 conservation habitat development project on the Missouri River at the direction of the USFWS 

24 and NGPC. At the time of writing this biological assessment (BA), the involved parties are 

25 discussing details of the conservation agreement. 

26 Plans for and construction of a chute on the parcel may also involve the owners of the 

27 transmission lines and supports that cross the property. NPPD does not own these lines, 

28 although CNS-1 provides power to them. 

29 The probability that CNS-1 will entrain, impinge, or otherwise affect pallid sturgeon eggs or 

30 larvae is low. Hazleton (1979) collected adult and juvenile fish from seven locations in the 

31 vicinity of CNS-1 from 1970 through 1978 and reported no pallid sturgeon captured. They also 

32 conducted impingement sampling from 1974 through 1978 and reported no pallid sturgeon 

33 impinged. Based on 374 trawl hauls that captured over 21,735 fish in a 1998 through 2000 

34 survey, Hrabik et al. (2007) concluded pallid sturgeon may reproduce in the lower Missouri 

35 River to the upper and lower Mississippi River, although no fish may survive to recruitment. 

36 NPPD’s involvement in the conservation agreement, however, could have a positive impact on 

37 the pallid sturgeon population. 

38 D.2.2 CONCLUSION 

39 Based on this review, the staff concludes that the continued operation of CNS-1 for an 

40 additional 20 years may affect, but is not likely to adversely affect, the pallid sturgeon. 
Appendix D.2 

February 2010 D.2-13 Draft NUREG-1437, Supplement 41 

1 D.2.3 REFERENCES 

2 Dryer, M.P., and A.J. Sandvol. 1993. “Recovery plan for the pallid sturgeon Scaphirhynchus 

3 albus.” U.S. Fish and Wildlife Service, Bismarck, North Dakota. 55 pp. 

4 Gerrity, P.C., and C. Guy. 2006. Juvenile pallid sturgeon are piscivorous: A call for conserving 

5 native cyprinids. Transactions of the American Fisheries Society 135:604-609. 

6 Hazleton Environmental Sciences Corporation (Hazelton). 1979. Report to Nebraska Public 

7 Power District, Columbus, Nebraska: The Evaluation of Thermal Effects in the Missouri River 

8 Near Cooper Nuclear Station (0perational Phase), January–December 1978, Project No. 8903. 

9 Hazleton Environmental Sciences Corporation, Lincoln, Nebraska. ADAMS Accession No. 

10 ML092450614. 

11 Hurleya, K.L., R.J. Sheehan, R.C. Heidinger, P.S. Wills, and B.Clevenstine. 2004. Habitat Use 

12 by Middle Mississippi River Pallid Sturgeon. Transactions of the American Fisheries Society 

13 133:1033–1041. 

14 Hrabik, R. A., Herzog, D. P., Ostendorf, D. E., and Petersen, M. D. 2007. Larvae provide first 

15 evidence of successful reproduction by pallid sturgeon, Scaphirhynchus albus, in the Mississippi 

16 River. Journal of Applied Ichthyology 23(4):436-443. 

17 Kynard, B., E. Henyey, and M. Horgan. 2002. Ontogenetic behavior, migration, and social 

18 behavior of pallid sturgeon, Scaphirhynchus albus, and shovelnose sturgeon, S. platorynchus, 

19 with notes on the adaptive significance of body color. Environmental Biology of Fishes 63:389–

20 403. 

21 Missouri Department of Conservation (MDC). 2009. “The Sturgeon of Missouri: Missouri’s 

22 Living Dinosaurs.” Updated 2009. Available URL: athttp://mdc.mo.gov/fish/sport/sturgeon/info/

23 (accessed on May 5, 2009). 

24 Nebraska Public Power District (NPPD). 2006. Proposal for Information Collection, Cooper 

25 Nuclear Station. January 2006. ADAMS Accession No. ML092510103. 

26 Nebraska Public Power District (NPPD). 2008a. Letter from Joe Citta, NPPD to Robert Harms, 

27 USFWS Re: Cooper Nuclear Station License Renewal—Habitat Development Proposal. 

28 September 26, 2008. ADAMS Accession No. ML092520156. 

29 Nebraska Public Power District (NPPD). 2008b. Nebraska Public Power District, Cooper 

30 Nuclear Station, License Renewal Application. September 24, 2008. ADAMS Accession No. 

31 ML083030227. 

32 U.S. Fish and Wildlife Service (USFWS). 2007. Species Profile, Pallid sturgeon, 

33 Scaphirhynchus albus. Available URL: http://www.fws.gov/moriver/PSPROFILE.htm (accessed 

34 on March 16, 2007). 

35 U.S. Geological Service (USGS). 2007. Sturgeon Research Update: Confirmed Pallid Sturgeon 

36 Spawning in the Missouri River in 2007. USGS Fact Sheet 2007–3053, July 2007. 

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

38 for License Renewal of Nuclear Power Plants. NUREG-1437, Volumes 1 and 2, 

39 Washington, D.C. 

40 U.S. Nuclear Regulatory Commission (NRC). 1999. Generic Environmental Impact Statement 

41 for License Renewal of Nuclear Plants. Main Report. NUREG-1437, Volume 1, Addendum 1, 

42 Washington, D.C. 
Appendix D.2 

Draft NUREG-1437, Supplement 41 D.2-14 February 2010 

1 U.S. Nuclear Regulatory Commission (NRC). 2009. Letter from D. Pelton to Mr. John Cochnar, 

2 U.S. Fish and Wildlife Service, Grand Island, Nebraska, Re: Request for List of Protected 

3 Species Dryer, M.P., and A.J. Sandvol. 1993. “Recovery plan for the pallid sturgeon 

4 Scaphirhynchus albus.” U.S. Fish and Wildlife Service, Bismarck, North Dakota. 55 pp. 

5 Wildhaber, M.L., DeLonay, A.J., Papoulias, D.M., Galat, D.L., Jacobson, R.B., Simpkins, D.G., 

6 Braaten, P.J., Korschgen, C.E., and Mac, M.J. 2007. A conceptual life-history model for pallid 

7 and shovelnose sturgeon. U.S. Geological Survey Circular 1315. U.S. Geological Survey, 

8 Reston, Virginia. 18 pp. 
1 APPENDIX E. 

2 CHRONOLOGY OF ENVIRONMENTAL REVIEW 

February 2010 E-1 Draft NUREG-1437, Supplement 41 

1 E. CHRONOLOGY OF ENVIRONMENTAL REVIEW 

2 CORRESPONDENCE 

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

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

5 Cooper Nuclear Station, Unit 1 (CNS-1). All documents, with the exception of those containing 

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

7 Room found on the Internet at the following Web address: http://www.nrc.gov/reading-rm.html. 

8 From this site, the public can gain access to the NRC’s Agencywide Document Access and 

9 Management System (ADAMS), which provides text and image files of NRC’s public documents 

10 in ADAMS. The ADAMS accession number for each document is included below. 

11 E.1. Environmental Review Correspondence 

12 September 24, 2008 Letter from Nebraska Public Power District (NPPD) forwarding the 

13 application for renewal of the operating license for CNS-1, requesting an 

14 extension of the operating license for an additional 20 years. (ADAMS 

15 Accession No. ML0803030227) 

16 September 24, 2008 NPPD’s environmental report (ER) submitted as Appendix E for the 

17 application for renewal of the operating license for CNS- 1, requesting an 

18 extension of the operating license for an additional 20 years. (ADAMS 

19 Accession No. ML083030246) 

20 November 10, 2008 Letter to NPPD, “Receipt and Availability of the License Renewal 

21 Application for the Cooper Nuclear Station Unit 1.” (ADAMS Accession 

22 No. ML082661007) 

23 November 17, 2008 Federal Register Notice of Receipt and Availability of Application for 

24 Renewal of Cooper Nuclear Station Facility Operating License No. DPR25 46 for an Additional 20-Year Period (73 FR 67896). (ADAMS Accession 

26 No. ML0826608920) 

27 December 19, 2008 Letter to NPPD, “Determination of Acceptability and Sufficiency for 

28 Docketing and Opportunity for a Hearing Regarding the Application from 

29 Nebraska Public Power District, for Renewal of the Operating License for 

30 the Cooper Nuclear Station (TAC Nos. MD9763 and Md9737).” (ADAMS 

31 Accession No. ML083330066) 

32 December 19, 2008 Federal Register Notice of Acceptance for Docketing of the Application 

33 and Notice of Opportunity for Hearing Regarding Renewal of Facility 

34 Operating License No. DPR-46 for an Additional 20-Year Period 

35 Nebraska Public Power District Cooper Nuclear Station (73 FR 5877). 

36 (ADAMS Accession No. ML083540747) 

37 January 15, 2009 Federal Register Notice of Intent to Prepare an Environmental Impact 

38 Statement and Conduct Scoping Process for Licensee Renewal for 

39 Cooper Nuclear Station, Unit 1 (73 FR 13923). (ADAMS Accession No. 

40 ML090150526) 
Appendix E 

Draft NUREG-1437, Supplement 41 E-2 February 2010 

1 January 16, 2009 Letter to Michael Smith, Nebraska Historic Preservation Society, 

2 regarding CNS-1, license renewal application” (ADAMS Accession No. 

3 ML090080197) 

4 January 21, 2009 Letter to NPPD transmitting notice of intent to prepare an environmental 

5 impact statement and conduct scoping process for license renewal for 

6 CNS-1.” (ADAMS Accession No. ML083640401) 

7 January 26, 2009 Letter to Sherry Black, Auburn Memorial Library, regarding maintenance 

8 of reference materials at the Auburn Memorial Library related to the 

9 review of the Cooper Nuclear Station license renewal application. 

10 (ADAMS Accession No. ML090230582) 

11 January 26, 2009 Letter to Don Klima, Director, Advisory Council on Historic Preservation, 

12 regarding CNS-1, license renewal application. (ADAMS Accession No. 

13 ML090080683) 

14 January 27, 2009 Letter to Mr. Joseph Cothern, USEPA Region 7, regarding CNS-1, license 

15 renewal application. (ADAMS Accession No. ML090230446) 

16 January 28, 2009 Letter to Julia Schmitt, Department of Health and Human Services, 

17 regarding CNS-1, license renewal application. (ADAMS Accession No. 

18 ML090260380) 

19 January 29, 2009 Notice of forthcoming meeting to discuss the safety review process and 

20 environmental scoping process for CNS-1, license renewal application 

21 review. (ADAMS Accession No. ML090160280) 

22 January 29, 2009 Letter to Mark Miles, State Historic Preservation Officer, Department of 

23 Natural Resources, MO, regarding CNS-1, license renewal application. 

24 (ADAMS Accession No. ML090210750) 

25 January 29, 2009 Letter to John Cochnar, U.S. Fish and Wildlife Service, requesting a list of 

26 protected species for the CNS-1, license renewal review. (ADAMS 

27 Accession No. ML0901507) 

28 February 2, 2009 Letter from the Nebraska State Historic Preservation Office requesting a 

29 map of the boundaries of the environmental review of the license renewal 

30 application for CNS-1. (ADAMS Accession No. ML090650061) 

31 February 4, 2009 Letter to Adrian Pushetonequa, Sac and Fox Tribe of the Mississippi in 

32 Iowa, inviting participation in scoping process related to NRC’s 

33 environmental review of the license renewal application for CNS-1. 

34 (ADAMS Accession No.ML090080045) 

35 February 4, 2009 Letter to Ann Bleed, Nebraska Department of Natural Resources, 

36 requesting a list of protected species for the CNS-1, license renewal 

37 review. (ADAMS Accession No. ML090260380) 

38 February 25, 2009 Agenda and slides for Cooper Nuclear Station scoping and process public 

39 meeting, February 25, 2009. (ADAMS Accession No. ML090750686) 
Appendix E 

February 2010 E-3 Draft NUREG-1437, Supplement 41 

1 February 25, 2009 Transcript of Cooper Nuclear Station license renewal public meeting – 

2 afternoon session, February 25, 2009. (ADAMS Accession No. 

3 ML090840063) 

4 February 25, 2009 Transcript of Cooper Nuclear Station license renewal public meeting – 

5 evening session, February 25, 2009. (ADAMS Accession No. 

6 ML090840062) 

7 February 25, 2009 Comments from the Richardson County, Nebraska, Emergency 

8 Management Agency regarding the license renewal of CNS-1. (ADAMS 

9 Accession No. ML090720066) 

10 February 27, 2009 Letter from the City of Rock Port regarding the license renewal of CNS-1. 

11 (ADAMS Accession No. ML090720068) 

12 March 9, 2009 Letter from Nebraska Department of Natural Resources regarding the 

13 request for a list of protected species for license renewal of CNS-1. 

14 (ADAMS Accession No. ML090650061) 

15 March 10, 2009 Letter from the Pawnee City Economic Development Corporation 

16 regarding the license renewal of CNS-1. (ADAMS Accession No. 

17 ML090720067) 

18 April 3, 2009 Letter to NPPD regarding the review schedule for the application for the 

19 renewal of the operating license for CNS-1. (ADAMS Accession No. 

20 ML090220584) 

21 April 3, 2008 Letter to Stewart B. Minahan, NPPD, regarding environmental site audit 

22 needs for CNS-1 license renewal application from NPPD. (ADAMS 

23 Accession No. ML090830248) 

24 April 9, 2009 Letter to NPPD, “Regulatory Audit Plan for Aging Management Program 

25 Regarding Cooper Nuclear Station Unit 1 License Renewal Application.” 

26 (ADAMS Accession No. ML090930256) 

27 April 9, 2009 Letter to NPPD, “Request for Additional Information Regarding Balance of 

28 Plant Issues for Cooper Nuclear Station Unit 1” (ADAMS Accession No. 

29 ML091060150) 

30 April 14, 2009 Summary of public meeting for Cooper Nuclear Station Scoping and 

31 Process Public Meeting, February 25, 2009 (ADAMS Accession No. 

32 ML090910308) 

33 April 16, 2009 Email comments from Environmental Protection Agency (EPA) Region 7, 

34 regarding the license renewal of CNS-1. (ADAMS Accession 

35 No. ML091070269) 

36 April 30, 2009 Summary of site audit related to the review of the license renewal 

37 application for CNS-1 (TAC NOS. MD9763 and MD9737) (ADAMS 

38 Accession No. ML090970414) 
Appendix E 

Draft NUREG-1437, Supplement 41 E-4 February 2010 

1 May 1, 2009 Letter to NPPD, “Request for Additional Information for the Review of the 

2 Cooper Nuclear Station License Renewal Application” (TAC No. MD9763 

3 and MD9737) (ADAMS Accession No. ML091190597) 

4 May 1, 2009 Letter from NPPD to Fish and Wildlife Service regarding the license 

5 renewal of the Cooper Nuclear Station. (ADAMS Accession No. 

6 ML091830056) 

7 May 5, 2009 Email from Fish and Wildlife Service to R. Bulavinez, NRC. (ADAMS 

8 Accession No. ML091400116) 

9 May 8, 2009 Email and attachment from Nebraska Game and Parks Commission. 

10 (ADAMS Accession No. ML091400110) 

11 May 18, 2009 Letter from NPPD, “Response to Request for Additional Information for 

12 License Renewal Application, Cooper Nuclear Station, Docket No. 50-

13 298, DPR-46. (ADAMS Accession No. ML091600712) 

14 May 29, 2009 Summary report of environmental scoping for the license renewal 

15 application for CNS-1 (TAC NOS. MD9763 and MD9737) (ADAMS 

16 Accession No. ML091200017) 

17 June 8, 2009 Letter to NPPD, “Request for Additional Information for the Review of the 

18 Cooper Nuclear Station License Renewal application (TAC. No. MD9763 

19 and MD9737) (ADAMS Accession No. ML091530316) 

20 June 8, 2009 Letter from Fish and Wildlife Service to NPPD regarding the license 

21 renewal of Cooper Nuclear Station (ADAMS Accession No. 

22 ML091830055) 

23 July 1, 2009 Letter from NPPD, “Response to Request for Additional Information for 

24 License Renewal Application – Severe Accident Mitigation Alternatives, 

25 Cooper Nuclear Station, Docket No. 50-298, DPR-46. (ADAMS Accession 

26 No. ML091880319) 

27 August 26, 2009 Letter from Fish and Wildlife Service to NPPD concerning the license 

28 renewal of the Cooper Nuclear Station. 

29 December 17. 2009 Letter from NPPD,” SAMA Meteorological Anomaly Related to the Cooper 

30 Nuclear Station License Renewal Application,” (ADAMS Accession No. 

31 ML093490997) 
1 APPENDIX F. 

2 U.S. NUCLEAR REGULATORY COMMISSION STAFF 

3 EVALUATION OF SEVERE ACCIDENT MITIGATION 

4 ALTERNATIVES FOR COOPER NUCLEAR STATION, UNIT 1 IN 

5 SUPPORT OF LICENSE RENEWAL APPLICATION REVIEW

February 2010 F-1 Draft NUREG-1437, Supplement 41 

1 F. U.S. NUCLEAR REGULATORY COMMISSION STAFF EVALUATION 

2 OF SEVERE ACCIDENT MITIGATION ALTERNATIVES FOR COOPER 

3 NUCLEAR STATION IN SUPPORT OF LICENSE RENEWAL 

4 APPLICATION REVIEW 

5 NOTE: In December 7, 2009, CNS-1 identified an error in their original SAMA analysis resulting 

6 from the wind data used in their code. NPPD discovered a problem with the process they used 

7 to numerically average the site-specific meteorological data. NPPD performed a sensitivity 

8 analysis of the population dose risk and offsite economic cost risk using corrected 

9 meteorological data, and found that the population dose and offsite economic cost values for 

10 each of the release categories would be slightly less than reported in the ER, and that the 

11 conclusions of the SAMA remain valid (NPPD, 2009c). NRC staff reviewed the revised data as 

12 part of the analysis below. 

13 F.1. Introduction 

14 Nebraska Public Power District (NPPD) submitted an assessment of severe accident mitigation 

15 alternatives (SAMAs) for the Cooper Nuclear Station, Unit 1 (CNS-1) as part of the 

16 environmental report (ER) (NPPD, 2008). This assessment was based on the most recent CNS17 1 probabilistic safety assessment (PSA) available at that time, a plant-specific offsite 

18 consequence analysis performed using the MELCOR Accident Consequence Code System 2 

19 (MACCS2) computer code (NRC, 1998a), and insights from the CNS-1 individual plant 

20 examination (IPE) (NPPD, 1993) and individual plant examination of external events (IPEEE) 

21 (NPPD, 1996). In identifying and evaluating potential SAMAs, NPPD considered SAMA 

22 candidates who addressed the major contributors to core damage frequency (CDF) and large 

23 early release frequency (LERF) at CNS-1, as well as, SAMA candidates for other operating 

24 plants which have submitted license renewal applications. NPPD identified 244 potential SAMA 

25 candidates. This list was reduced to 80 unique SAMA candidates by eliminating SAMAs that are 

26 not applicable at CNS-1 due to design differences, have already been implemented at CNS-1, 

27 or are similar in nature and could be combined with another SAMA candidate. NPPD assessed 

28 the costs and benefits associated with each of the potential SAMAs, and concluded in the ER 

29 that several of the candidate SAMAs evaluated are potentially cost-beneficial. 

30 Based on a review of the SAMA assessment, the U.S. Nuclear Regulatory Commission (NRC) 

31 issued a request for additional information (RAI) to NPPD by letter dated June 8, 2009 

32 (NRC, 2009). Key questions concerned: the impact of unresolved Boiling Water Reactor 

33 Owner’s Group (BWROG) PSA peer review findings on the SAMA analysis results; the process 

34 used to develop and group source terms into containment event tree (CET) end states; the 

35 rationale for identifying and screening SAMAs, and the costs and benefits of several specific 

36 candidate SAMAs and low cost alternatives. NPPD submitted additional information by letter 

37 dated July 1, 2009 (NPPD, 2009a) and email dated August 10, 2009 (NPPD, 2009b). In 

38 response to the RAIs, NPPD provided information regarding the findings of the BWROG peer 

39 review; a discussion and example of the process for assigning severe accident source terms to 

40 CET sequences; additional rationale on the process used to identify and screen SAMAs, and 

41 additional information regarding several specific SAMAs. NPPD’s responses addressed the 

42 NRC staff’s concerns. 

43 An assessment of SAMAs for CNS-1 is presented below. 
Appendix F 

Draft NUREG-1437, Supplement 41 F-2 February 2010 

1 F.2. Estimate of Risk for Cooper Nuclear Station 

2 NPPD’s estimates of offsite risk at CNS-1 are summarized in Section F.2.1. The summary is 

3 followed by the NRC staff’s review of NPPD’s risk estimates in Section F.2.2. 

4 F.2.1. Nebraska Public Power District’s Risk Estimates 

5 Two distinct analyses are combined to form the basis for the risk estimates used in the SAMA 

6 analysis: (1) the CNS-1 Level 1 and 2 PSA model, which is an updated version of the IPE 

7 (NPPD, 1993), and (2) a supplemental analysis of offsite consequences and economic impacts 

8 (essentially a Level 3 PSA model) developed specifically for the SAMA analysis. The SAMA 

9 analysis is based on the most recent CNS-1 Level 1 and Level 2 PSA models available at the 

10 time of the ER, referred to as the CNS-1 2007TM model (2007TM, Rev. 1). The scope of this 

11 CNS-1 PSA does not include external events. 

The CNS-1 CDF is approximately 9.3 × 10-6 12 per year for internal events as determined from 

13 quantification of the Level 1 PSA model. When determined from the sum of the CET sequences, 

or the Level 2 PSA model, the release frequency is approximately 1.2 × 10-5 14 per year. The latter 

15 value was used as the baseline CDF in the SAMA evaluations (NPPD, 2009a). The CDF is 

16 based on the risk assessment for internally-initiated events, which includes internal flooding. 

17 NPPD did not include the contribution from external events within the CNS-1 risk estimates, 

18 however, it did account for the potential risk reduction benefits associated with external events 

19 by multiplying the estimated benefits for internal events by a factor of three. For some fire20 related SAMAs, NPPD separately estimated the risk reduction benefits using the fire risk model. 

21 This is discussed further in Sections F.2.2 and F.6.2. 

22 The breakdown of CDF by initiating event is provided in Table F-1. As shown in this table, 

23 events initiated by transients, loss of DC power, loss of coolant accidents (LOCA), and loss of 

24 feedwater are the dominant contributors to the CDF. Station blackout (SBO) and anticipated 

25 transient without scram (ATWS) sequences may occur following multiple initiators and so their 

26 total contributions to CDF were reported separately. Each contributes less than 3 percent to the 

27 total internal events CDF. 

28 The Level 2 CNS-1 PSA model that forms the basis for the SAMA evaluation represents an 

29 updated version of the original IPE Level 2 model. The current Level 2 model utilizes a single 

30 CET containing both phenomenological and systemic events. The Level 1 core damage 

31 sequences are binned into one of 15 Plant Damage State (PDS) bins which provide the 

32 interface between the Level 1 analysis and Level 2 CET analysis. The CET probabilistically 

33 evaluates the progression of the damaged core with respect to radiation release into the 

34 environment. CET nodes are evaluated using supporting fault trees and logic rules. The CET 

35 end states then are examined for considerations of timing and magnitude of release and 

36 assigned to release categories. 
Appendix F 

February 2010 F-3 Draft NUREG-1437, Supplement 41 

1 Table F-1. Cooper Nuclear Station Core Damage Frequency for Internal Events 

Initiating Event CDF 

(per year) % Contribution to CDF 

Transients 3.0 × 10–6 32 

Loss of DC Power 2.1 × 10–6 22 

LOCA 1.4 × 10–6 15 

Loss of Feedwater 1.0 × 10–6 11 

Loss of Offsite Power 6.5 × 10–7 7 

Loss of Service Water (SW) 6.0 × 10–7 7 

Loss of AC Buses 2.6 × 10–7 3 

Internal Flood 2.6 × 10–7 3 

Interfacing System LOCA 5.1 × 10–8 <1 

Total CDF (Internal Events) 9.3 × 10–6 100

2 The result of the Level 2 PSA is a set of 12 release categories, also referred to as source term 

3 categories, with their respective frequency and release characteristics. The release categories 

4 and their characteristics are provided in Table E.1-10 of the ER (NPPD, 2008). The categories 

5 were defined based on the timing, duration, and magnitude of the release and whether or not 

6 the containment remains intact or fails. The frequency of each release category was obtained by 

7 summing the frequency of the individual accident progression CET endpoints assigned to each 

8 release category. Source terms were developed for each of the 12 release categories using the 

9 results of Modular Accident Analysis Program (MAAP Version 4.0.5) computer code 

10 calculations. 

11 The offsite consequences and economic impact analyses use the MACCS2 code to determine 

12 the offsite risk impacts on the surrounding environment and general public. Inputs for these 

13 analyses include plant-specific and site-specific input values for core radionuclide inventory, 

14 source term and release characteristics, site meteorological data, projected population 

15 distribution (within a 50-mile (80-km) radius) for the year 2034, emergency response evacuation 

16 modeling, and economic data. The magnitude of the onsite impacts (in terms of clean-up and 

17 decontamination costs and occupational dose) is based on information provided in 

18 NUREG/BR-0184 (NRC, 1997a). 

19 In the ER, NPPD estimated the dose to the population within 50 miles (80 km) of the CNS-1 site 

20 to be approximately 0.021 person-Sievert (Sv) (2.1 person-roentgen equivalent man (rem)) per 

21 year. The breakdown of the total population dose by containment release mode is summarized 

22 in Table F-2. Containment failures within the early time frame (less than 3.7 hours following 

23 event initiation) dominate the population dose risk at CNS-1, with failures in the intermediate 

24 time frame (3.7 to 24 hours following event initiation) contributing most of the remaining 

25 population dose risk. 
Appendix F 

Draft NUREG-1437, Supplement 41 F-4 February 2010 

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

Containment Release Mode Population Dose 

(Person-Rem1 Per Year) % Contribution 

Early Containment Failure 1.67 78 

Intermediate Containment Failure 0.47 22 

Late Containment Failure <0.1 <1 

Intact Containment Negligible negligible 

Total 2.14 100

1

One person-rem = 0.01 person-Sv 

2 F.2.2. Review of Nebraska Public Power District’s Risk Estimates 

3 NPPD’s determination of offsite risk at CNS-1 is based on the following three major elements of 

4 analysis: 

5 ● The Level 1 and 2 risk models that form the basis for the 1993 IPE 

6 submittal (NPPD, 1993) and the external event analyses of the 1996 IPEEE 

7 submittal (NPPD, 1996) 

8 ● The major modifications to the IPE model that have been incorporated in 

9 the CNS-1 PSA 

10 ● The MACCS2 analyses performed to translate fission product source terms 

11 and release frequencies from the Level 2 PSA model into offsite 

12 consequence measures. 

13 Each of these analyses was reviewed to determine the acceptability of the NPPD risk estimates 

14 for the SAMA analysis, as summarized below. 

15 The NRC staff's review of the CNS-1 IPE is described in an NRC report dated February 14, 

16 1996 (NRC, 1996). Based on a review of the IPE submittal and responses to RAIs, the NRC 

17 staff concluded that the IPE submittal met the intent of GL 88-20 (NRC, 1988); that is, the 

18 licensee’s IPE process is capable of identifying the most likely severe accidents and severe 

19 accident vulnerabilities. Although no vulnerabilities were identified in the IPE, several 

20 improvements to the plant or procedures were identified. These improvements have been either 

21 implemented at the site or addressed in the SAMA evaluation process (NPPD, 2008). These 

22 improvements are discussed in Section F.3.2. 

23 There have been five revisions to the IPE model since the 1993 IPE submittal. A listing of the 

24 major changes in each revision of the PSA was provided by NPPD in the ER and is summarized 

25 in Table F-3. A comparison of the internal events CDF between the 1993 IPE and the 2007TM 

26 Rev. 1 PSA model used for the SAMA evaluation indicates a decrease of approximately 

88 percent (from 8.0 × 10-5 per year to 9.3 × 10-6 27 per year). A description of those changes that 

28 resulted in the greatest impact on the internal event CDF is provided in Section E.1.4 of the ER 

29 (NPPD, 2008). The decrease is mainly attributed to plant and modeling improvements made 

30 between the IPE and the 1996b model update. 
Appendix F 

February 2010 F-5 Draft NUREG-1437, Supplement 41 

1 Table F-3. Cooper Nuclear Station Probabilistic Safety Assessment Historical Summary 

PSA 

Version Summary of Changes from Prior Model CDF (per year) 

1993 IPE Submittal (excluding internal flooding) 8.0 × 10-5 

1996b - Revised the human reliability analysis to incorporate revisions to 

emergency operating procedures 

- Added credit for newly installed torus hard pipe vent 

- Corrected conservative thermal hydraulic analysis of safety relief valve 

(SRV) flow 

- Improved loss of offsite power model 

1.3 × 10-5 

2001a - Incorporated minor improvements stemming from the 9/97 peer review 

- Updated component failure and unavailability database 

- Developed LERF model 

1.3 × 10-5 

2005TM Updated initiating event frequencies to reflect information in 

NUREG/CR-6890 

1.1 × 10-5 

2006TM Updated model to support the Mitigating System Performance Index (MSPI) 

and maintenance rule update 

1.4 × 10-5 

2007TM 

(Revision 1) 

- Added internal flooding to the Level 1 model 

- Incorporated operator action dependencies 

- Expanded the treatment of common cause failures 

- Developed a more detailed CET and new Level 2 fault trees 

- Added new Level 1 system models including severe accident mitigation 

strategies such as firewater injection 

- Updated PSA model data 

- Developed initiator fault trees to calculate some initiating event 

frequencies, such as loss of turbine equipment cooling (TEC) 

9.3 × 10-6 

2 

The CDF value from the 1993 CNS-1 IPE (8.9 × 10-5 3 per year) is near the upper end of the 

4 range of the CDF values reported in the IPEs for other boiling water reactor (BWR) 3/4 plants. 

5 Figure 11.2 of NUREG-1560 shows that the IPE-based total internal events CDF for BWR 3/4 

plants, ranges from about 9 × 10-8 per year to 1 × 10-4 6 per year, with an average CDF for the 

group of 2 × 10-5 7 per year (NRC, 1997b). It is recognized that other plants have updated the 

8 values for CDF subsequent to the IPE submittals to reflect modeling and hardware changes. 

The internal events CDF result for CNS-1 used for the SAMA analysis (9.3 × 10-6 9 per year) is 

10 comparable to other plants of similar vintage and characteristics. 

11 The NRC staff considered the peer reviews performed for the CNS-1 PSA and the potential 

12 impact of the review findings on the SAMA evaluation. In the ER (NPPD, 2008), NPPD 

13 described the BWROG peer review of the 2007TM Revision 1 model conducted in May 2008. 

14 The peer review was performed using the NEI 05-04 process (NEI, 2007), the ASME PRA 

15 Standard (ASME, 2007), and NRC Regulatory Guide 1.200, Rev. 1 (NRC, 2007). The NRC staff 

16 asked NPPD to provide a summary of each of the peer review findings and an assessment of 

17 the impact of resolving each finding on the SAMA identification and analysis results 

18 (NRC, 2009). In response to this request, NPPD provided a table summarizing the peer review 

19 findings in relation to the applicable supporting requirements (SR) and an assessment of the 

20 impact of the resolution of the findings on the PSA results (NPPD, 2009a). The peer review 

21 identified 22 findings against the SR, including 10 classified as not met. The 10 not-met findings 

22 included documentation of analysis bases, PSA configuration control, identification of internal 

23 flooding mechanisms, and evaluation of human error dependencies. NPPD’s review of the 22 

24 peer review findings resulted in no changes to the PSA model and no impacts on the SAMA 

25 identification and analysis results. The NRC staff considers NPPD’s rationale reasonable and 
Appendix F 

Draft NUREG-1437, Supplement 41 F-6 February 2010 

1 that the final resolution of the peer review findings is not likely to impact the results of the SAMA 

2 analysis. 

3 Because the CNS-1 internal events PSA model has been peer-reviewed and the peer review 

4 findings were all addressed, and NPPD has satisfactorily addressed NRC staff questions 

5 regarding the PSA, the NRC staff concludes that the internal events Level 1 PSA model is of 

6 sufficient quality to support the SAMA evaluation. 

7 As indicated above, the current CNS-1 PSA does not include external events. In the absence of 

8 such an analysis, NPPD used the CNS-1 IPEEE to identify the highest risk accident sequences 

9 and the potential means of reducing the risk posed by those sequences, as discussed below 

10 and in Section F.3.2. 

11 The CNS-1 IPEEE was submitted in October 1996 (NPPD, 1996), in response to Supplement 4 

12 of Generic Letter 88-20 (NRC, 1991). These submittals included a seismic margins analysis, an 

13 internal fire PSA, and evaluations of high winds, external flooding, and other hazards. While no 

14 fundamental weaknesses or vulnerabilities to severe accident risk in regard to the external 

15 events were identified, several opportunities for risk reduction were identified as discussed 

16 below. In a letter dated April 27, 2001, the NRC staff concluded that the submittal met the intent 

17 of Supplement 4 to Generic Letter 88-20, and that the licensee’s IPEEE process is capable of 

18 identifying the most likely severe accidents and severe accident vulnerabilities (NRC, 2001). 

19 The CNS-1 IPEEE used a focused scope Electric Power Research Institute (EPRI) seismic 

20 margins analysis which was completed in conjunction with the Seismic Qualification User’s 

21 Group (SQUG) program (SQUG, 1992). This method is qualitative and does not provide 

22 numerical estimates of the CDF contributions from seismic initiators (EPRI, 1991). For this 

23 assessment, the review level earthquake (RLE) value for CNS-1 was specified by NRC to be 

24 0.3g. Plant walkdowns were performed in which components and structures were screened for 

25 the RLE based on the EPRI guidelines, and specific high confidence low probability of failure 

26 (HCLPF) capacities were calculated for components and structures that did not screen out. All 

27 structures and all but six components were screened out, of which five were Unresolved Safety 

28 Issue (USI) A-46 program outliers. Several improvements were identified to address the six 

29 unscreened components and to reduce seismic risk. While some of these improvements have 

30 been implemented, all were addressed as SAMA candidates, as discussed in Section F.3.2. 

31 The NRC review and closure of USI A-46 for CNS-1 is documented in a letter dated 

32 September 30, 1999 (NRC, 1999). 

33 To provide additional insight into the appropriate seismic CDF to use for the SAMA evaluation, 

34 the NRC staff developed an independent estimate of the seismic CDF for CNS-1 using the 

35 simplified-hybrid approximation method described in a paper by Robert P. Kennedy, entitled 

36 “Overview of Methods for Seismic PRA and Margin Analysis Including Recent Innovations” 

37 (Kennedy, 1999) and using updated 2008 seismic hazard curve data from the U.S. Geologic 

38 Survey (USGS, 2008). The NRC staff’s independent calculations indicate the seismic CDF for 

CNS-1 to be approximately 6 × 10-6 39 per year depending on the seismic hazard curve and plant 

40 fragility assumptions. Since NPPD did not provide a seismic CDF contribution in the ER, the 

41 NRC staff used this result to assess the appropriateness of the external event multiplier used in 

42 the SAMA evaluation. 

43 The CNS-1 IPEEE fire analysis employed a combination of PSA with the EPRI’s fire-induced 

44 vulnerability evaluation (FIVE) methodology (EPRI, 1993). Fire compartments were initially 

45 qualitatively screened out if all compartment boundaries screened out according to Fire 
Appendix F 

February 2010 F-7 Draft NUREG-1437, Supplement 41 

1 Compartment Interaction Analysis (FCIA) criteria and if the compartment did not contain 

2 Appendix R equipment. Quantitative screening was then performed using fire frequencies based 

3 on the FIVE methodology and the assumption that fire failed all of the equipment in the 

4 compartment. The sequence was then quantified using the internal events PSA model. If the 

CDF was greater than 1 × 10-6 5 per year the compartment was subjected to more detailed 

6 analysis. In this analysis, the FIVE fire screening methodology was used in the fire modeling 

7 with one exception. The exception involved the partitioning of oil spill fires into large and small 

8 spills based on a recommendation in the “EPRI Fire PRA Implementation Guide” (EPRI, 1994). 

The total fire CDF, found by summing the values for all compartments, is 1.9 × 10-5 9 per year. 

The fire compartments having a fire CDF greater than 1 × 10-7 10 per year and their contributions to 

11 the fire CDF are listed in Table F-4. 

12 In the ER, NPPD identifies a number of conservatisms in the fire analysis, including: 

13 ● The NRC fire events database indicates a trend toward lower frequency 

14 and less severe fires since the IPEEE fire analysis was performed. 

15 ● Because of little industry experience with crew actions following a fire, crew 

16 actions were conservatively characterized in the fire model. 

17 ● A fire that damaged a cable was assumed to always induce a conductor 

18 failure. 

19 ● Manual fire suppression was only credited in the control room and non20 essential switchgear rooms. 

21 ● Hardware repair activities were not credited. 

22 The NRC staff inquired about additional measures that NPPD had already taken to reduce fire 

23 risk since the IPEEE (NRC, 2009). NPPD provided a description of the measures taken in the 

24 four dominant fire compartments (3A-switchgear room 1F, 3B-switchgear room 1G, 10B-control 

25 room and security access control corridor, and 20A-SW pump room). These measures 

26 consisted primarily of improvements to monitoring and controlling the quantity of combustible 

27 materials and pre-staging of outage materials. 
Appendix F 

Draft NUREG-1437, Supplement 41 F-8 February 2010 

1 Table F-4. Cooper Nuclear Station Fire Compartments and Their Contributions to Fire 

2 Core Damage Frequency 

Fire Compartment Fire Compartment Description CDF 

(per year) 

10B Control Room and Security Alarm Station (SAS) Corridor 3.7 × 10-6 

3B Switchgear Room 1G 2.7 × 10-6 

20A SW Pump Room 1.7 × 10-6 

3A Switchgear Room 1F 1.1 × 10-6 

8-1 Condenser Pit Area 9.7 × 10-7 

9A Cable Spreading Room 8.2 × 10-7 

2A/2C Reactor Building El. 903’-6” – Control Rod Drive (CRD) 

Units – North/South 

8.2 × 10-7 

8G DC Switchgear Room 1B 7.9 × 10-7 

8B Reactor Protection System (RPS) Room 1B 7.3 × 10-7 

8F Battery Room 1B 6.7 × 10-7 

14A Emergency Diesel Generator (EDG) Room 1A 6.1 × 10-7 

14B EDG Room 1B 6.1 × 10-7 

7A Residual Heat Removal Service Water (RHRSW) Booster 

and Service Air Compressor 

5.6 × 10-7 

4A/4C/4D Reactor Building El. 958’-3” – Fuel Pool Heat 

Exchanger/Lube Oil 

5.4 × 10-7 

8A Auxiliary Relay Room 3.7 × 10-7 

9B Cable Expansion Room 3.4 × 10-7 

8H DC Switchgear Room 1A 3.4 × 10-7 

13B Non-Critical Switchgear Room 3.3 × 10-7 

3C/3D/3E Reactor Building El. 932’-6” - REC 2.7 × 10-7 

8E Battery Room 1A 1.8 × 10-7 

1F Suppression Pool Area 1.7 × 10-7 

12D Turbine Building Floor – North 903’-6” El. 1.4 × 10-7 

1B/1G Core Spray (CS) and CRD Room 1.0 × 10-7 

Other Compartments 6.4 × 10-7 

Total Fire CDF 1.9 × 10-5 

3 Based on the conservatisms in the analysis and the actions taken by NPPD to reduce fire risk 

since the IPEEE, the NRC staff concludes that the fire CDF of 1.9 × 10-5 4 per year is reasonable 

5 for the SAMA analysis. 
Appendix F 

February 2010 F-9 Draft NUREG-1437, Supplement 41 

1 The CNS-1 IPEEE analysis of high winds, tornadoes, external floods and other external events 

2 followed the screening and evaluation approaches specified in Supplement 4 to GL 88-20 

(NRC, 1991) and did not identify any sequences or vulnerabilities that exceeded the 1.0 × 10

-6

3 

4 per year criterion except for the design-basis tornado and a lightning strike to the control 

5 building (NPPD, 1996). Plant improvements were identified to address each of these issues and 

6 included as SAMA candidates, as discussed in Section F.3.2. The NRC staff concluded in the 

7 review of the CNS-1 IPEEE that the tornado missiles contribution to CDF is less than the 

8 screening criteria and that lightning did not pose a significant hazard to the plant (NRC, 2001). 

9 Based on the aforementioned results, including the NRC staff assessment of the CNS-1 seismic 

10 CDF, the external events CDF is approximately two times the internal events CDF (based on a 

seismic CDF of 6 × 10-6 per year, a fire CDF of 1.9 × 10-5 11 per year, and an internal events CDF 

of 1.2 × 10-5 12 per year). Accordingly, the NRC staff concurred with NPPD’s conclusion that the 

13 total CDF (from internal and external events) would be approximately three times the internal 

14 events CDF. In the SAMA analysis submitted in the ER, NPPD tripled the benefit that was 

15 derived from the internal events model to account for the combined contribution from internal 

16 and external events. The NRC staff agrees with the licensee’s overall conclusion concerning the 

17 multiplier used to represent the impact of external events and concludes that the licensee’s use 

18 of a multiplier of three to account for external events is reasonable for the purposes of the 

19 SAMA evaluation. This is discussed further in Section F.6.2. 

20 The NRC staff reviewed the general process used by NPPD to translate the results of the Level 

21 1 PSA into containment releases, as well as the results of the Level 2 analysis, as described in 

22 the ER and in response to NRC staff requests for additional information (NPPD 2008, 2009a). 

23 This model is an updated version of the model used in the IPE and reflects the CNS-1 

24 configuration and design as of December 2007. Major revisions and updates to the Level 2 

25 model include equipment performance data for failure rates and system unavailability, plant 

26 configuration changes, improved modeling techniques, inclusion of additional PDS bins to 

27 improve the Level 1and Level 2 PSA interface, and updated accident progression and source 

28 term analyses using a later version of the MAAP computer code. The Level 1 core damage 

29 sequences are binned into one of 15 PDS bins which provide the interface between the Level 1 

30 and Level 2 analysis. The PDS, which are described in Table E.1-8 of the ER (NPPD, 2008), 

31 are defined by a set of functional characteristics for system operation which are important to 

32 accident progression, containment failure and source term definition. The Level 2 models utilize 

33 a single CET for each PDS with functional nodes representing both systemic and 

34 phenomenological events. The CET is used to determine the appropriate release category for 

35 each Level 2 sequence. CET nodes are evaluated using supporting fault trees and logic rules. 

36 NPPD characterized the releases for the spectrum of possible radionuclide release scenarios 

37 using a set of 12 release categories based on the timing and magnitude of the release and 

38 whether or not the containment remained intact. The frequency of each release category was 

39 obtained by summing the frequency of the individual accident progression CET endpoints 

40 binned into the release category. The release characteristics for each release category were 

41 developed by grouping the hundreds of source terms generated for internal initiators into the 

42 12 categories based on similar properties. Source term release fractions were developed for 

43 each of the 12 release categories using the results of 46 Modular Accident Analysis Program 

44 (MAAP 4.0.5) computer code calculations (NPPD, 2009a). In response to an NRC staff RAI, 

45 NPPD identified that for each CET sequence, a value for each of the release-to-environment 

46 mass fractions was obtained from the representative MAAP calculation (NPPD, 2009a). These 

47 mass fractions were then weighted according to the contribution of that sequence to the sum of 

48 the sequences in the end state bin. The final mass fraction representing the end state bin was 
Appendix F 

Draft NUREG-1437, Supplement 41 F-10 February 2010 

1 the sum of these individual weighted mass fractions for each species. The release categories, 

2 their frequencies, and release characteristics are presented in Tables E.1-6 and E.1-7, E.1-9, 

3 and E.1-10 of the ER, respectively (NPPD, 2008). 

4 The NRC staff noted that the iodine and cesium mass fractions for the low-low intermediate 

5 release category in Table E.1-10 of the ER are substantially less than the corresponding mass 

6 fractions for the low-low early and low-low late release categories and requested NPPD to 

7 provide an explanation for this apparent anomaly (NRC, 2009). In response, NPPD explained 

8 that the dominant sequences for the low-low intermediate release category involve offsite 

9 release via containment venting through an intact suppression pool, resulting in effective fission 

10 product scrubbing (NPPD, 2009a). In contrast, the dominant sequences for the low-low early 

11 and low-low late release categories involve release paths from the primary containment that 

12 bypass the suppression pool, resulting in much less fission product scrubbing than for the 

13 low-low intermediate release category. Consequently, the cesium and iodine mass fractions for 

14 the low-low intermediate release category will be less than that for the low-low early and low-low 

15 late release categories. 

16 The NRC staff requested NPPD provide an explanation of the reasons for the difference in the 

total release frequency value of 1.2 × 10-5 17 derived from the CET and the Level 1 CDF value of 

9.3 × 10-6 18 and to provide the rationale for using the total release frequency for the SAMA 

19 analysis (NRC, 2009). In response, NPPD indicated that (NPPD, 2009a): 

20 ● The total release frequency derived from the CET is larger than the Level 1 

21 CDF because of the methodology used in the CET for deriving the split 

22 fraction values. The CET contains numerous paths that do not meet the 

rare event approximation criterion (e.g., split fractions > 5 × 10-2 23 ) in the 

24 quantification approach used. For these paths, the sum of the split fractions 

25 for the corresponding failure and success branches is greater than 1.0 

26 resulting in a conservatively high total CDF. 

27 ● Since the SAMA evaluation requires both Level 1 and 2 PSA results, NPPD 

28 chose the higher value from the CET as the basis for quantifying SAMA 

29 benefits. 

30 NPPD concludes that use of the release frequency, rather than the Level 1 CDF, will have a 

31 negligible impact on the results of the SAMA evaluation because the delta risk calculation, 

32 performed to assess SAMA benefits, effectively cancels out the impact of the simplified model 

33 quantification methodology, and because the external event multiplier and uncertainty multiplier 

34 used in the SAMA analysis (discussed in Section F.6.2) have a much greater impact on the 

35 SAMA evaluation results than the small error arising from the model quantification approach. 

36 The NRC staff agrees with this conclusion. 

37 The NRC staff’s review of the Level 2 IPE concluded that it addressed the most important 

38 severe accident phenomena normally associated with the Mark I containment type, and 

39 identified no significant problems or errors (NRC, 1996). The changes to the Level 2 model 

40 since the IPE to update the methodology and to address peer review recommendations are 

41 described in Section E.1.4 of the ER. The Level 2 PSA model was included in the May 2008 

42 BWROG peer review mentioned previously. Of the 22 peer review findings, one finding in the 

43 SR not-met category was related to identification of limitations in the LERF analysis that would 

44 impact applications. In response to an NRC staff RAI, NPPD reviewed this finding and 
Appendix F 

February 2010 F-11 Draft NUREG-1437, Supplement 41 

1 determined that there were no limitations that would impact projected applications that are not 

2 already documented, and concluded that the finding would not impact the results of the SAMA 

3 analysis. 

4 Based on the NRC staff’s review of the Level 2 methodology, the fact that the Level 2 model 

5 was reviewed in more detail as part of the BWROG peer review and that the peer review 

6 findings do not impact the SAMA analysis, and the responses to the RAIs concerning the 

7 analysis and review process, the NRC staff concludes that the Level 2 PSA provides an 

8 acceptable basis for evaluating the benefits associated with various SAMAs. 

9 As indicated in the ER, the reactor core radionuclide inventory used in the consequence 

10 analysis was derived from ORIGEN2 calculations using a bounding core enrichment and burnup 

11 for CNS-1. A core power of 2,429 megawatt-thermal (MWt) was assumed to bound the licensed 

12 maximum power of 2,419 MWt for the CNS-1 Measurement Uncertainty Recapture power 

13 uprate approved by the NRC in 2008. The NRC staff requested additional information about the 

14 expected fuel burnup and management for the renewal period (NRC, 2009). NPPD responded 

15 that the bounding core inventory assumed an initial enrichment of 3.908 weight percent 

16 Uranium-235 and 1300 effective full-power days (EFPD) of continuous operation to achieve an 

17 end of cycle core average exposure of 35.8 Gwd/MT (NPPD, 2009a), and that this core 

18 inventory reflects the expected fuel management/burnup for the renewal period. 

19 The NRC staff reviewed the process used by NPPD to extend the containment performance 

20 (Level 2) portion of the PSA to an assessment of offsite consequences (Level 3). This included 

21 consideration of the source terms used to characterize fission product releases for the 

22 applicable containment release categories and the major input assumptions used in the offsite 

23 consequence analyses. Version 1.13.1 of the MACCS2 code was utilized to estimate offsite 

24 consequences. Plant-specific input to the code includes the source terms for each release 

25 category and the reactor core radionuclide inventory (both discussed above), site-specific 

26 meteorological data, projected population distribution within a 50-mile (80-km)) radius for the 

27 year 2034, emergency evacuation modeling, and economic data. This information is provided in 

28 Attachment E to the ER (NPPD, 2008). 

29 NPPD used site-specific meteorological data for the five years, 2002 through 2006, as input into 

30 the MACCS2 code. NPPD averaged the data over this interval for this study. The data were 

31 collected from the onsite meteorological monitoring system and regional National Weather 

32 System (NWS) stations. Regional mixing heights were estimated using ground level and 

33 upper-air data collected at National Weather Service Station No. 94980 in Valley, Nebraska 

34 (NE) (approximately 76 miles(120 km) north-northwest of CNS-1) and Station No. 72553 in Falls 

35 City/Brenner, NE (approximately 19 miles (30 km) south of CNS-1). Missing data were 

36 estimated using data substitution methods. These methods include substitution of missing data 

37 with valid data from the previous hour, or valid data collected from other elevations on the 

38 meteorological tower. The NRC staff notes that previous SAMA analyses results have shown 

39 little variation resulting from year-to-year differences in meteorological data and concludes that 

40 the approach taken for collecting and applying the meteorological data in the SAMA analysis is 

41 reasonable. 

42 The population distribution used by the licensee as input to the MACCS2 analysis was 

43 estimated for the year 2034 based on county-level projections obtained from the University of 

44 Nebraska Bureau of Business Research (UN, 2007), Woods & Poole Economics, Inc. for Iowa 

45 (Woods & Poole, 2006), Darrel Eklund, et. al. for Kansas (Eklund, 1999), and the Missouri 

46 Census Data Center (Missouri, 2007). Year 2004 tourist information was used to estimate the 
Appendix F 

Draft NUREG-1437, Supplement 41 F-12 February 2010 

1 transient population for year 2005 (Global Insight, 2006; IDED, 2006; Kaylen, 2006; 

2 NDED, 2006). These data were used to project county-level populations using a regression 

3 method to extrapolate population projections to 2034. For the counties with population in 

4 decline, the population value for year 2014 was used, which corresponds to the license 

5 expiration date for CNS-1. The NRC staff considers the methods and assumptions for 

6 estimating population reasonable and acceptable for purposes of the SAMA evaluation. 

7 The emergency evacuation model was modeled as a single evacuation zone extending out 

8 10 miles (16 km) from the plant. NPPD assumed that 100 percent of the population would move 

9 at an average speed of approximately 19.5 miles per hour (mph) (8.7 meters per second (m/s)) 

10 with a delayed start time of 2.0 hours (NPPD, 2008). The evacuation speed and time were 

11 based on the average values identified in the Missouri and Nebraska time estimate studies. 

12 NPPD performed sensitivity analyses in which the evacuation delay time was increased to 4.0 

13 hours, and the evacuation speed was decreased to 1.0 m/s. These sensitivity cases resulted in 

14 less than 1 percent and 2 percent increases in the total population dose, respectively. The 

15 100 percent population evacuation assumption is slightly less conservative than the assumption 

16 used in NUREG-1150 study (NRC, 1990), which assumed evacuation of 99.5 percent of the 

17 population within the emergency planning zone (EPZ). The NRC staff asked NPPD to address 

18 the potential impact on the population dose if 5 percent of the population fails to evacuate the 

19 EPZ (NRC, 2009). In response, NPPD performed a sensitivity analysis that showed only a slight 

20 increase in population dose (less than 1 percent for the late release) would result 

21 (NPPD, 2009a). The NRC staff concludes that the evacuation assumptions and analysis are 

22 reasonable and acceptable for the purposes of the SAMA evaluation. 

23 Much of the site-specific economic data was obtained from the 2002 Census of Agriculture 

24 (USDA, 2002). These included the value of farm and non-farm wealth. Other generic data that 

25 applies to the region as a whole, such as the cost of evacuating and relocating people, land 

26 decontamination, and property decontamination, were obtained from the code manual for 

27 MACCS2 (NRC, 1997c) . The data from the MACCS2 code manual were inflation-adjusted 

28 using the consumer price index corresponding to the year 2006. Information on regional crops 

29 was obtained from the 2002 Census of Agriculture. Crops for each county were mapped into the 

30 seven MACCS2 crop categories. 

31 The NRC staff concludes that the methodology used by NPPD to estimate the offsite 

32 consequences for CNS-1 provides an acceptable basis from which to proceed with an 

33 assessment of risk reduction potential for candidate SAMAs. Accordingly, the NRC staff based 

34 its assessment of offsite risk on the CDF and offsite doses reported by NPPD. 

35 F.3. Potential Plant Improvements 

36 The process for identifying potential plant improvements, an evaluation of that process, and the 

37 improvements evaluated in detail by NPPD are discussed in this section. 
Appendix F 

February 2010 F-13 Draft NUREG-1437, Supplement 41 

1 F.3.1. Process for Identifying Potential Plant Improvements 

2 NPPD's process for identifying potential plant improvements (SAMAs) consisted of the following 

3 elements: 

4 ● Review of the most significant basic events from the current, plant-specific 

5 PSA, 

6 ● Review of potential plant improvements identified in the CNS-1 IPE and 

7 IPEEE, 

8 ● Review of SAMA candidates identified for license renewal applications for 

9 11 other U.S. General Electric (GE) plants, and 

10 ● Review of other NRC and industry documentation discussing potential plant 

11 improvements. 

12 Based on this process, an initial set of 244 candidate SAMAs, referred to as Phase I SAMAs, 

13 was identified. In Phase I of the evaluation, NPPD performed a qualitative screening of the initial 

14 list of SAMAs and eliminated SAMAs from further consideration using the following criteria: 

15 ● The SAMA modified features are not applicable to CNS-1, 

16 ● The SAMA has already been implemented at CNS-1, or 

17 ● The SAMA is similar in nature and could be combined with another SAMA 

18 candidate. 

19 Based on this screening, 164 SAMAs were eliminated leaving 80 for further evaluation. The 

20 remaining SAMAs, referred to as Phase II SAMAs, are listed in Table E.2-2 of the ER 

21 (NPPD, 2008). In Phase II, a detailed evaluation was performed for each of the 80 remaining 

22 SAMA candidates, as discussed in Sections F.4 and F.6 below. To account for the potential 

23 impact of external events, the estimated benefits, based on internal events, were multiplied by a 

24 factor of three, as previously discussed. 

25 F.3.2. Review of Nebraska Public Power District’s Process 

26 NPPD’s efforts to identify potential SAMAs focused primarily on areas associated with internal 

27 initiating events. The initial list of SAMAs generally addressed the accident sequences 

28 considered to be important to CDF from functional, initiating event, and risk reduction worth 

29 (RRW) perspectives at CNS-1, and included selected SAMAs from prior SAMA analyses for 

30 other plants. 

31 NPPD provided a tabular listing of the PSA basic events sorted according to their RRW 

32 (NPPD, 2008). SAMAs impacting these basic events would have the greatest potential for 

33 reducing risk. NPPD used an RRW cutoff of 1.005, which corresponds to about a 0.5 percent 

34 change in CDF given 100-percent reliability of the SAMA. This equates to a benefit of 

35 approximately $5,300 (after the benefits have been multiplied to account for external events). 

36 NPPD also provided and reviewed the LERF-based RRW events down to an RRW of 1.005. 
Appendix F 

Draft NUREG-1437, Supplement 41 F-14 February 2010 

1 NPPD correlated the top Level 1 and Level 2 events with the SAMAs evaluated in the ER, and 

2 showed that all of the significant basic events are addressed by one or more SAMAs 

3 (NPPD, 2008). 

4 The NRC staff asked NPPD to provide the rationale for identifying candidate SAMAs for 

5 LERF-based success events (NRC, 2009). In response to the RAI, NPPD replied that, unlike 

6 SAMAs identified for the purpose of decreasing the risk of failure events, SAMAs identified for 

7 success events are intended to decrease the risk contribution from the cutsets or basic events 

8 related to the success event (NPPD, 2009a). NPPD further noted that SAMAs identified for 

9 success events are also identified for related failure events, and provided specific examples of 

10 this relationship. The staff finds NPPD’s treatment of success events acceptable. 

11 The NRC staff also asked NPPD to clarify how RRW was calculated for complementary events 

12 and to provide an assessment of the impact on the SAMA identification and evaluation process 

13 if complementary events were not directly coupled in the computation of RRW (NRC, 2009). 

14 NPPD responded that complementary events were directly coupled in the calculation of RRW, 

15 provided an example of this direct coupling, and concluded that since this coupling was 

16 performed correctly there is no impact on the SAMA identification and evaluation process 

17 (NPPD, 2009a). The NRC staff agrees that NPPD appropriately accounted for direct coupling of 

18 complementary events in the calculation of RRW. 

19 The NRC staff requested clarification on the screening criteria used for the Phase I SAMAs 

20 because the ER was inconsistent in describing this process (NRC, 2009). NPPD responded that 

21 the criteria for screening Phase I SAMAs based on SAMA modifying features not applicable to 

22 CNS-1 is broader than this description suggests and includes; (1) SAMAs that have already 

23 been analyzed for CNS-1 and determined to be of low benefit, and (2) SAMAs that have been 

24 previously resolved with NRC based on further evaluation that determined that the modification 

25 was not necessary (NPPD, 2009). 

26 For a number of the Phase II SAMAs listed in the ER, the information provided did not 

27 sufficiently describe the proposed modification. Therefore, the NRC staff asked the applicant to 

28 provide more detailed descriptions of the modifications for several of the Phase II SAMA 

29 candidates (NRC, 2009). In response to the RAI, NPPD provided the requested information on 

30 the modifications for SAMAs 20, 44, 45, 63, 70, 72, 73, 76, 77, and 80 (NPPD, 2009a). 

31 NPPD considered the potential plant improvements described in the IPE and IPEEE in the 

32 identification of plant-specific candidate SAMAs for internal and external events. Although the 

33 IPE did not identify any vulnerabilities, seven potential enhancements to the plant, procedures, 

34 and training at CNS-1 were identified as part of the IPE process. The seven enhancements 

35 include (NPPD, 1993): 

36 ● Upgrading the plant-specific emergency operating procedures based on 

37 Revision 4 of the BWROG Emergency Procedure Guidelines, 

38 ● Performing a load study to relax the assumed four-hour battery lifetime and 

39 provide a procedure to improve battery loading schemes, 

40 ● Providing a procedure to bypass the AC solenoid valve on the nitrogen 

41 supply line to the SRVs, 
Appendix F 

February 2010 F-15 Draft NUREG-1437, Supplement 41 

1 ● Providing a diesel-driven fire water pump or other similar source of low 

2 pressure water independent of AC power, 

3 ● Improving the reliability of the high pressure coolant injection (HPCI) and 

4 reactor core isolation cooling (RCIC) systems, 

5 ● Providing a backup for the SW pumps by modifying the existing system and 

6 making procedural changes, and 

7 ● Providing improved drywell spray capability. 

8 NPPD noted that the first four of these enhancements have already been implemented at CNS9 1 and the remaining three enhancements are addressed by SAMAs. The fifth enhancement, to 

10 improve the reliability of the HPCI and RCIC systems, as addressed by Phase II SAMA 35, 

11 “provide a redundant train or means of ventilation,” and SAMA 67, “improve the reliability of the 

12 HPCI and RCIC systems by upgrading their control systems.” The sixth enhancement, to 

13 provide a backup for the SW pumps, as addressed by Phase II SAMA 68, “proceduralize the 

14 ability to cross-connect the circulating water pumps and the SW going to the TEC heat 

15 exchangers.” The last enhancement, to provide an improved drywell spray capability, was 

16 judged to be already implemented at CNS-1 where the fire water system is used as a backup 

17 source for the drywell spray system. Nevertheless, NPPD further addressed this enhancement 

18 with Phase II SAMA 47, “install a passive drywell spray system to provide a redundant drywell 

19 spray method.” 

20 Based on this information, the NRC staff concludes that the set of SAMAs evaluated in the ER, 

21 together with those identified in response to NRC staff RAIs, addresses the major contributors 

22 to internal event CDF. 

23 Several seismic-related improvements were identified in the CNS-1 IPEEE. The specific seismic 

24 interaction issues are as follows (NPPD, 1996): 

25 ● Potential relay chatter at low seismic levels for ten relays, 

26 ● Potential impact of the 480V critical switchgear 1G with an adjacent 

27 concrete beam, 

28 ● Potential seismic interaction of the solatron/accuvolt line conditioners with a 

29 stairway supported by a masonry wall, 

30 ● Potential inadequate seismic capacity for the SE and NE quad recirculation 

31 fans, 

32 ● Potential impact of the jet pump instrument rack A with an adjacent rack, 

33 ● Inadequate anchorage capacity for loose equipment in the control room and 

34 lack of support for the overhead lighting diffusers, 

35 ● Inadequate anchorage for the aux relay room panels, 
Appendix F 

Draft NUREG-1437, Supplement 41 F-16 February 2010 

1 ● Inadequately braced unistrut trapeze frame in the northeast corner of 

2 elevation 903 feet of the reactor building, and 

3 ● Loose bolt securing one corner of an interior panel of the SW pump B & D 

4 strainer control panel. 

5 All of these were identified as Phase I SAMAs but have already been implemented or previously 

6 resolved under the USI A-46 Program (NRC, 2001). As a result, no Phase II SAMAs were 

7 identified to address these issues. The CNS-1 IPEEE seismic/fire interaction evaluation did 

8 conclude that the CNS-1 water-based fire protection systems were vulnerable to a seismic 

9 event. This vulnerability was addressed by Phase II SAMA 69, “upgrade the seismic capacity of 

10 the diesel fire pump fuel tank and water supply tank.” The NRC staff concludes that the 

11 opportunity for seismic-related SAMAs has been adequately explored and that it is unlikely that 

12 there are additional potentially cost-beneficial, seismic-related SAMA candidates. 

13 The CNS-1 IPEEE fire assessment concluded that the four fire compartments (Control Room 

14 and SAS Corridor, Switchgear Rooms 1F and 1G, and SW Pump Room) that did not screen out 

based on having a fire CDF of less than 1.0 × 10-6 15 per year represent vulnerabilities 

16 (NPPD, 1996). Two plant improvements were identified to address these risk contributors: 

17 ● Addition of a feature to allow remote control of the switchyard breakers from 

18 the control room, or to have a pre-planned recovery/repair action for control 

19 of the switchyard breakers following a fire, and 

20 ● Provide a diverse water supply for the SW system. 

21 Both of these were identified as Phase I SAMAs. As indicated in the ER, an evaluation of 

22 improvements for control of the switchyard breakers showed a decrease in CDF of less than 

23 0.5 percent, therefore, this change was not implemented or evaluated as a Phase II SAMA. The 

24 second improvement was evaluated as Phase II SAMA 68, “proceduralize the ability to 

25 cross-connect the circulating water pumps and the SW pumps going to the TEC heat 

26 exchangers.” NPPD also identified two additional Phase II SAMAs to reduce the fire CDF in 

27 dominant fire zones without suppression and in the control room: (1) SAMA 63, “add automatic 

28 fire suppression systems to the dominant fire zones,” and (2) SAMA 65, “upgrade the ASDS 

29 panel to include additional system controls for the opposite division.” The NRC staff concludes 

30 that the opportunity for fire-related SAMAs has been adequately explored and that it is unlikely 

31 that there are additional potentially cost-beneficial, fire-related SAMA candidates. 

32 As stated earlier, other external hazards (e.g., high winds, external floods, transportation and 

33 nearby facility accidents) are below the threshold screening frequency and are not expected to 

34 impact the conclusions of the SAMA analysis. Nevertheless, two plant improvements were 

35 identified to address the risk contribution from tornados and lightning: 

36 ● Protect the diesel generator exhaust system from tornado-generated 

37 missiles, and 

38 ● Reduce the potential vulnerability of the control building to a 

39 lightning-induced loss of offsite power that also affects the station batteries. 
Appendix F 

February 2010 F-17 Draft NUREG-1437, Supplement 41 

1 Both were identified as Phase I SAMAs. The first, Phase I SAMA 232, “protect the diesel 

2 exhaust from tornado missiles,” has already been implemented at CNS-1. The NRC inquired 

3 about this SAMA being described as resolved in 1998, while the IPEEE SER stated that the 

4 issue had yet to be addressed. NPPD responded that the matter was resolved by a letter from 

5 NPPD to NRC in 2001 clarifying that the modification was in fact completed in 1998. The 

6 second improvement was further evaluated and it was determined that the control building was 

7 not vulnerable to a lightning-induced loss of offsite power which might affect the station 

8 batteries. 

9 The NRC staff questioned NPPD about lower cost alternatives to some of the SAMAs evaluated 

10 (NRC, 2009), including: 

11 ● Providing additional space cooling to the RHRSW booster pump rooms, CS 

12 pump rooms, residual heat removal (RHR) pump rooms, SW pump rooms, 

13 and HPCI pump room via the use of portable equipment, 

14 ● Improving alternate shutdown training and equipment, 

15 ● Enhancing DC power availability (provide cables from diesel generators or 

16 another source to directly power battery chargers), 

17 ● Developing guidance/procedures for local, manual control of reactor core 

18 isolation cooling following loss of DC power, and 

19 ● Enhancing manual venting of containment using either a local hand wheel 

20 or gas bottle supplies as a possible alternative for containment pressure 

21 control. 

22 In response to the RAIs, NPPD addressed the suggested lower cost alternatives 

23 (NPPD, 2009a). This is discussed further in Section F.6.2. 

24 The NRC staff notes that the set of SAMAs submitted is not all-inclusive, since additional, 

25 possibly even less expensive, design alternatives can always be postulated. However, the NRC 

26 staff concludes that the benefits of any additional modifications are unlikely to exceed the 

27 benefits of the modifications evaluated and that the alternative improvements would not likely 

28 cost less than the least expensive alternatives evaluated when the subsidiary costs associated 

29 with maintenance, procedures, and training are considered. 

30 The NRC staff concludes that NPPD used a systematic and comprehensive process for 

31 identifying potential plant improvements for CNS-1, and that the set of SAMAs evaluated in the 

32 ER, together with those evaluated in response to NRC staff inquiries, is reasonably 

33 comprehensive and, therefore, acceptable. This search included reviewing insights from the 

34 plant-specific risk studies and reviewing plant improvements considered in previous SAMA 

35 analyses. While explicit treatment of external events in the SAMA identification process was 

36 limited, it is recognized that the prior implementation of plant modifications for fire risks and the 

37 absence of external event vulnerabilities reasonably justifies primarily examining the internal 

38 events risk results for this purpose. 
Appendix F 

Draft NUREG-1437, Supplement 41 F-18 February 2010 

1 F.4. Risk Reduction Potential of Plant Improvements 

2 NPPD evaluated the risk-reduction potential of the 80 remaining SAMAs that were applicable to 

3 CNS-1. The majority of the SAMA evaluations were performed in a bounding fashion—the 

4 SAMA was assumed to completely eliminate the risk associated with the proposed 

5 enhancement. On balance, such calculations overestimate the benefit and are conservative. 

6 NPPD used model requantification to determine the potential benefits. The CDF, population 

7 dose, and offsite economic cost reductions were estimated using the CNS-1 2007TM model, 

8 Rev. 1. The changes made to the model to quantify the impact of SAMAs are detailed in 

9 Section E.2.3 of Attachment E to the ER (NPPD, 2008). Table F-5 lists the assumptions 

10 considered to estimate the risk reduction for each of the evaluated SAMAs, the estimated risk 

11 reduction in terms of percent reduction in CDF and population dose, and the estimated total 

12 benefit (present value) of the averted risk. The estimated benefits reported in Table F-5 reflect 

13 the combined benefit in both internal and external events. The determination of the benefits for 

14 the various SAMAs is further discussed in Section F.6. 

15 The NRC staff questioned the assumptions used in evaluating the benefits or risk reduction 

16 estimates of certain SAMAs provided in the ER (NRC, 2009). For example, for SAMA 6, 

17 “change the time available to recover offsite power to 24 hours,” the NRC staff requested 

18 clarification on the modeling assumption provided in ER Table 2-2 for this SAMA, which is 

19 inconsistent with the modeling assumption for analysis Case 6, “set failure probability to transfer 

20 the RPS panels to their alternate power source to zero” (NRC, 2009). In response to the RAI, 

21 NPPD clarified that the modeling assumption for SAMA 6, as provided in Table 2-2 of the ER, 

22 was incorrect and should have been the same as described for Case 6. The correct modeling 

23 assumption was used in the cost benefit analysis (NPPD, 2009a). 

24 For SAMA 14, “portable generator for DC power to supply individual panels,” the NRC staff 

25 asked NPPD to clarify the rationale for using the modeling assumption for Case 14, which was 

26 to set the CDF contribution due to unavailability of the HPCI system to zero in the Level 1 

27 PSA model (NRC, 2009). In response to the RAI, NPPD explained that the benefit of providing 

28 an alternate DC power source to HPCI to support emergency core cooling was judged to be 

29 larger than the benefit of providing an alternate DC power source to other panels based on: (1) 

30 the importance of HPCI in intermediate LOCA sequences, and (2) the fact that the 

31 turbine-driven HPCI pump can continue to run in SBO sequences as long as DC control power 

32 is available (NPPD, 2009a). The NRC staff further asked NPPD to explain the large CDF 

33 reduction for this SAMA (32 percent) when the CDF contribution from HPCI unavailability due to 

34 test and maintenance is only 3 percent. In response to the RAI, NPPD responded that the 

35 evaluation of this SAMA conservatively assumes HPCI never fails, which eliminates the CDF 

36 contribution from all events contributing to HPCI unavailability, not just the test and maintenance 

37 event. Other contributing events include loss of DC power, failure of the turbine-driven HPCI 

38 pump to start or continue to run, failure of HPCI hydraulic valve HO10, and failure to bypass the 

39 HPCI high temperature trip. The NRC staff considers the assumptions, as clarified, to be 

40 reasonable and acceptable for purposes of the SAMA evaluation. 

41 The NRC staff questioned how the modeling assumption of eliminating failure of the 

42 diesel-driven fire pump in the Level 1 PSA model for SAMA 69, “upgrade the seismic capacity of 

43 the diesel fire pump fuel tank and water supply tank,” addresses the intent of this SAMA, which 

44 is to mitigate seismic risk (NRC, 2009). In response to the RAI, NPPD explained that while the 

45 diesel fire pump may be needed to fight a fire following a seismic or fire event, its contribution to 

46 preventing core damage is from its dual function of providing an alternate source of water for 
Appendix F 

February 2010 F-19 Draft NUREG-1437, Supplement 41 

1 core cooling. NPPD further argued that the estimated risk reduction benefit for this SAMA is 

2 conservative since the analysis credited the benefit from internal events risk reduction, in 

3 addition to the benefit from external events risk reduction, through use of the external events 

4 multiplier (NPPD, 2009a). The NRC staff agrees that the resulting benefit estimate is 

5 conservative since there would be no reduction in internal events risk from implementation of 

6 the SAMA. 

7 The NRC staff requested clarification on how SAMA 70, “install a curb to prevent debris from 

8 spreading across the floor and contacting the shell,” reduces CDF as indicated in the ER 

9 (NRC, 2009). In response to the RAI, NPPD explained that SAMA 70 does not impact Level 1 

10 CDF and that the CDF reduction value reported in the ER for this SAMA is actually based on the 

11 release frequency reduction for this SAMA (NPPD, 2009a). In a follow-up response to the NRC 

12 staff RAI, NPPD further clarified that the analysis of this SAMA resulted in about a 12 percent 

13 reduction in the frequency for the large early release category, and that this was treated as a 

14 12 percent reduction in CDF in assessing the benefits for this SAMA (NPPD, 2009b). NPPD 

15 indicated that a more accurate assessment of SAMA 70 would require modifying the CET and 

16 that the approach taken results in a conservative estimate of the benefits for this SAMA. 

17 Although this approach is not consistent with regulatory analysis methodology, the NRC staff 

18 agrees that the resulting benefit estimate would be conservative since a reduction in CDF would 

19 result in averted onsite costs that would not be included otherwise for the SAMA. NPPD also 

20 noted that this analysis methodology was unique to SAMA 70 and does not impact the 

21 evaluation of other SAMAs. 

22 For SAMA 75, “Generation Risk Assessment (GRA) implementation into plant activities,” the 

23 NRC staff asked for additional clarification of the SAMA and justification for the assumed factor 

24 of two reduction in the initiating event frequencies impacted by this SAMA (NRC, 2009). In 

25 response to the RAI, NPPD explained that GRA is a new program to identify plant components 

26 most likely to result in a plant trip, insights from which are used to identify and reevaluate 

27 maintenance and operational practices to reduce the likelihood of future plant trips. NPPD 

28 further explained that the GRA program was only recently piloted by CNS-1 for EPRI and that 

29 the factor of two is based on recent plant operating history and opinion based on NPPD’s 

30 experience in the GRA process. The NRC staff considers the assumptions, as clarified, to be 

31 reasonable and acceptable for purposes of the SAMA evaluation. 

32 For two of the SAMAs that specifically address fire events (i.e., SAMA 63, “add automatic fire 

33 suppression systems to the dominant fire zones,” and SAMA 65, “update the alternate shutdown 

34 system (ASDS) panel to include additional system controls for opposite division,” the reduction 

35 in fire CDF and population dose was not directly calculated (in Table F-5 these are noted as 

36 “Not Estimated”). For these SAMAs, a bounding estimate of the impact was made by assuming 

37 the SAMA would eliminate the contribution to fire CDF from fires in the dominant fire zones in 

38 SAMA 63 and the control room in SAMA 65. The dominant fire zones in SAMA 63 are those 

having a fire CDF greater than 1.0 x 10-6 39 per year. Based on information from the IPEEE, the 

40 dominant fire zones are switchgear rooms 1F and 1G, the main control room, and the SW pump 

41 room. Based on logic in Section E.2.3 of the ER, only switchgear rooms 1F and 1G would 

42 benefit from the addition of automatic fire suppression systems. The benefit or averted cost risk 

43 from eliminating the risk in these fire zones is then calculated by multiplying the ratio of the fire 

44 zone CDF to the internal events CDF by the total present dollar-value equivalent associated 

45 with completely eliminating severe accidents from internal events at CNS-1. These SAMAs were 

46 assumed to have no additional benefits in internal events. 
Appendix F 

Draft NUREG-1437, Supplement 41 F-20 February 2010 

1 The NRC staff has reviewed NPPD’s bases for calculating the risk reduction for the various 

2 plant improvements and concludes that the rationale and assumptions for estimating risk 

3 reduction are reasonable and generally conservative (i.e., the estimated risk reduction is higher 

4 than what would actually be realized). Accordingly, the NRC staff based its estimates of averted 

5 risk for the various SAMAs on NPPD’s risk reduction estimates. 

6 F.5. Cost Impacts of Candidate Plant Improvements 

7 NPPD estimated the costs of implementing the 80 candidate SAMAs through the application of 

8 engineering judgment and use of other licensees’ estimates for similar improvements. The cost 

9 estimates conservatively did not include the cost of replacement power during extended 

10 outages required to implement the modifications, nor did they include maintenance and 

11 surveillance costs of the installed equipment (NPPD 2008, 2009a). The cost estimates provided 

12 in the ER did not account for inflation, which is considered another conservatism. 

13 The NRC staff reviewed the bases for the applicant’s cost estimates (presented in Section E.2 

14 of Attachment E to the ER). For certain improvements, the NRC staff also compared the cost 

15 estimates to estimates developed elsewhere for similar improvements, including estimates 

16 developed as part of other licensees’ analyses of SAMAs for operating reactors and advanced 

17 light-water reactors. The NRC staff noted that several of the cost estimates provided by the 

18 applicant were drawn from previous SAMA analyses for a dual-unit site. For those cost 

19 estimates that were taken from a dual-unit SAMA analysis, NPPD reduced the estimated costs 

20 by one-half. In response to an RAI requesting a more detailed description of the changes 

21 associated with SAMAs 20, 44, 45, 63, 70, 72, 73, 76, 77, and 80, NPPD provided additional 

22 information detailing the analysis and plant modifications included in the cost estimate of each 

23 improvement (NPPD, 2009a). The staff reviewed the costs and found them to be reasonable, 

24 and generally consistent with estimates provided in support of other plants’ analyses. 

25 The NRC staff requested additional clarification on the estimated cost of $1,200,000 for 

26 implementation of SAMA 41, “provide ability to align diesel power to more air compressors,” 

27 which is high for what is described as a procedural modification (NRC, 2009). In response to the 

28 RAI, NPPD further described this modification as involving electrical, mechanical, and structural 

29 hardware modifications, in addition to the procedural changes (NPPD, 2009a). Based on this 

30 additional information, the NRC staff considers this estimated cost to be reasonable and 

31 acceptable for purposes of the SAMA evaluation. 

32 The NRC staff concludes that the cost estimates provided by NPPD are sufficient and 

33 appropriate for use in the SAMA evaluation. 
Appendix F 

Table F-5. Severe Accident Mitigation Alternatives Cost/Benefit Screening Analysis for Cooper Nuclear StationFebruary 2010 F-21 Draft NUREG-1437, Supplement 41 

(a) 

 % Risk Reduction Total Benefit ($) 

SAMA Modeling Assumptions 

CDF Population Dose Baseline (Internal + External) Baseline With Uncertainty Cost ($) 

Increase Availability of DC Power Increase time available to recover 

offsite power (before HPCI and RCIC are lost) to 24 hours during SBO scenarios. 

3 3 32K 97K 

1 – Provide additional DC battery capacity. 500K 2 – Replace lead-acid batteries with fuel cells. 1.0M 13 – Portable generator for DC power to supply the battery chargers. 

 200K 

21 – Modify plant procedures to allow use of a portable power supply for battery chargers. 

 Included in 

SAMA 

13(b) 

Improve DC Battery Charging Reliability Eliminate all common cause failures 

due to loss of DC battery chargers. 

<1 0 2.3K 7.0K 

3 – Add battery charger to existing DC system. 90K 15 – Proceduralize battery charger high-voltage shutdown circuit inhibitor. 

 50K 

Improve DC Power Availability and Reliability 4 – Provide DC bus cross-ties for the 250V buses. 

Eliminate failure of the 250V DC buses. 

0 0 0 0 300K 

19 – Modify plant procedures to use existing 125V DC bus cross-ties. 

Eliminate failure of the operator to use the 125V DC bus cross-tie. 

<1 0 2.0K 6.0K 25K 

Improve Availability of the 120V Vital AC Bus 5 – Provide additional DC power to the 120/240V vital AC system. 

Eliminate failure of providing DC power to the no break power panel (NBPP). 

~0 0 470 1.4K >100K 

6 – Add an automatic feature to transfer the 120V vital AC bus from normal to standby power. 

Eliminate failure to transfer the reactor protection system (RPS) panels to their alternate power source. 

0 0 0 0 500K 
Appendix F

Draft NUREG-1437, Supplement 41 F-22 February 2010 

 % Risk Reduction Total Benefit ($) 

SAMA Modeling Assumptions 

CDF Population Dose Baseline (Internal + External) Baseline With Uncertainty Cost ($) 

Increase Availability of Onsite AC Power Eliminate failure of the EDGs. 13 14 140K 430K 7 – Provide an additional diesel generator. 20M 10 – Install a gas turbine generator. 2.0M Increase Reliability of EDGs 11 – Add a new backup source for diesel cooling. 

Eliminate failure of providing SW cooling to the EDGs. 

5 3 45K 130K 2.0M 

16 – Provide a portable EDG fuel oil transfer pump. 

Eliminate failure of the EDG fuel oil transfer pumps. 

<1 <1 6.2K 19K 100K 

Improve Availability of AC Power Eliminate failure of the 4.16-kV buses. 3 5 35K 110K 8 – Improve 4.16-kV bus cross-tie ability. 660K 17 – Provide alternate feeds to essential loads directly from an alternate emergency bus. 

 220K 

Reduce Probability of Loss of Offsite Power During Severe Weather 

Eliminate the weather-centered loss of offsite power initiating event. 

4 4 43K 130K 

9 – Install an additional, buried offsite power source. 

 2.5M 

12 – Bury offsite power lines. 1.1B Reduce Plant-Centered Loss of Offsite Power Eliminate the plant-centered loss of 

offsite power initiating event. 

~0 0 610 1.8K 

18 – Protect transformers from failure. 780K Improve Reliability of the Direct Torus Vent Valves 

Eliminate failure to power the hard pipe torus vent valves. 

4 13 77K 230K 

20 – Provide redundant power to direct torus hard pipe vent valves. 

 710K 
Appendix F 

February 2010 F-23 Draft NUREG-1437, Supplement 41 

 % Risk Reduction Total Benefit ($) 

SAMA Modeling Assumptions 

CDF Population Dose Baseline (Internal + External) Baseline With Uncertainty Cost ($) 

Increase Availability of High Pressure Injection Eliminate the CDF contribution from 

unavailability of the HPCI system. 

32 22 300K 910K 

14 – Portable generator for DC power to supply the individual panels (using available skidmounted portable AC generator). 

 710K 

22 – Install an independent active or passive high pressure injection system. 

 1.0M 

23 – Provide an additional high pressure injection pump with independent diesel. 

 1.0M 

Extend RCIC Operation Eliminate failures due to the RCIC 

backpressure trip. 

4 <1 29K 86K 

24 – Raise HPCI/RCIC backpressure trip set points. 

 >200K 

25 – Revise procedure to allow bypass of RCIC turbine exhaust pressure trip. 

 25K 

Improve Reliability of the Automatic Depressurization System (ADS) 

Eliminate failure of the ADS accumulators. 

0 0 0 0 

26 – Modify ADS components by adding larger accumulators. 

 >100K 

Improve Reliability of the SRVs Eliminate failure to open the SRVs 

when required by reactor pressure vessel overpressure conditions. 

19 <1 140K 410K 

27 – Add signals to open SRVs automatically in a main steam isolation valve (MSIV) closure transient. 

 1.5M 

Increase Availability of Low Pressure Injection Eliminate failure of the low pressure 

injection system. 

55 63 600K 1.8M 

28 – Add a diverse low pressure injection system. 

 8.8M 
Appendix F

Draft NUREG-1437, Supplement 41 F-24 February 2010 

 % Risk Reduction Total Benefit ($) 

SAMA Modeling Assumptions 

CDF Population Dose Baseline (Internal + External) Baseline With Uncertainty Cost ($) 

Emergency Core Cooling System (ECCS) Low Pressure Interlock 

Eliminate failure of the low pressure interlock circuitry. 

24 6 190K 570K 

29 – Install a bypass switch to allow operators to bypass the low reactor pressure interlock circuitry. 

 1.0M 

Improve Reliability of HPCI and RCIC Eliminate failure of the HPCI and RCIC 

turbine driven pumps. 

6 0 42K 130K 

67 – Upgrade the HPCI and RCIC control systems. 

 430K 

Improve Reliability/Redundancy of Steam Tunnel HVAC 

Eliminate failure of the steam tunnel HVAC condenser and eliminate the group 1 isolation (closure of the MSIVs) initiating event. 

3 1 27K 80K 

76 – Improve steam tunnel HVAC reliability/redundancy. 

 >100K 

Improve Reliability of ECCS Equipment Eliminate failure of the auto-start 

features for the ECCS equipment. 

1 0 9.3K 28K 

77 – Improve reliability of auto-start features for the ECCS equipment. 

 >100K 

Improve Reliability of Alternate Injection 78 – Improve training on providing alternate injection via FPS. 

Reduce failure of operator actions to provide alternate injection via the fire water system by a factor of two to 5.0E-02 for events FPS-XHE-FODFPAL and FPS-XHE-FO-RPVIN and to 9.5E-03 for event FPS-XHE-FODISEL.(c) 

5 4 53K 160K 25K 

32 – Include the RHRSW and fire water cross-tie valves in the maintenance program. 

Eliminate the CDF contribution due to the SW cross-tie valves that are not contained in the maintenance program.

~0 0 360 1.1K 50K 

33 – Create ability for emergency connection of existing or new water sources to feedwater and condensate systems. 

Eliminate the CDF contribution due to loss of feedwater and condensate systems as alternate injection paths. 

38 46 430K 1.3M 25K 
Appendix F 

February 2010 F-25 Draft NUREG-1437, Supplement 41 

 % Risk Reduction Total Benefit ($) 

SAMA Modeling Assumptions 

CDF Population Dose Baseline (Internal + External) Baseline With Uncertainty Cost ($) 

Increase Availability of the RHR Heat Exchangers 

Eliminate failure of SW to provide cooling to the RHR heat exchangers. 

21 16 200K 600K 

30 – Revise procedures to allow manual alignment of the fire water system to RHR heat exchangers. 

 25K 

Improve Reliability of Emergency SW System Eliminate all common cause failures 

due to loss of SW system pumps. 

<1 0 3.2K 9.5K 

31 – Add an additional SW pump. 5.9M Increase Availability of the TEC Heat Exchangers 

Eliminate failure of the SW to provide cooling to the TEC heat exchangers. 

15 20 180K 530K 

68 – Proceduralize the ability to cross-connect the circulating water pumps and the SW going to the TEC heat exchangers. 

 50K 

Improve Reliability of Main Feedwater System Eliminate failure of feedwater 

turbine-driven pumps. 

~0 0 90 270 

34 – Add a motor-driven feedwater pump. 1.7M Increase Availability of the Condensate Storage Tank (CST) 

Eliminate the CDF contribution from operator failure to prevent CST inventory drain-down to the hotwell. 

2 2 21K 63K 

72 – Provide a means of automatically preventing drain-down of CST to hotwell during a SBO. 

 230K 

Increase Availability of Room Cooling Eliminate failure of room cooling to the 

RHRSW booster pump rooms. 

4 3 38K 120K 

35 – Provide a redundant train or means of ventilation. 

 2.2M 
Appendix F

Draft NUREG-1437, Supplement 41 F-26 February 2010 

 % Risk Reduction Total Benefit ($) 

SAMA Modeling Assumptions 

CDF Population Dose Baseline (Internal + External) Baseline With Uncertainty Cost ($) 

Increase Availability of EDG System Eliminate failure of the EDG HVAC. 3 3 33K 99K 36 – Add a diesel building high temperature alarm or redundant louver and thermostat. 

 1.3M 

38 – Install diverse set of EDG HVAC fan actuation logic. 

 100K 

39 – Install additional fan and louver pair for EDG heating, ventilation, and air conditioning. 

 6.0M 

40 – Revise operator procedures to provide additional space cooling to the EDG room via the use of portable equipment. 

 25K 

Improve Diagnosis of a Loss of Switchgear HVAC 

Eliminate failure of room cooling to the critical switchgear rooms. 

0 0 0 0 

37 – Add a switchgear room high temperature alarm. 

 400K 

Increase Reliability of Instrument Air Eliminate failure of the instrument air 

compressors. 

17 14 170K 500K 

41 – Provide ability to align diesel power to more air compressors.(d)

 1.2M 

42 – Replace service and instrument air compressors with more reliable compressors which have self-contained air cooling by shaft driven fans. 

 1.4M 

45 – Provide an alternate means of supplying the instrument air header. 

 100K 

Extend SRV Operation Time Eliminate failure of loss of nitrogen and 

air to the SRVs. 

0 0 0 0 

43 – Install nitrogen bottles as backup gas supply for SRVs. 

 >100K 
Appendix F 

February 2010 F-27 Draft NUREG-1437, Supplement 41 

 % Risk Reduction Total Benefit ($) 

SAMA Modeling Assumptions 

CDF Population Dose Baseline (Internal + External) Baseline With Uncertainty Cost ($) 

Improve Availability of SRVs and MSIVs Eliminate failure of nitrogen, air, and 

accumulators for the SRVs and MSIVs.

17 21 190K 570K 

44 – Improve SRV and MSIV pneumatic components. 

 1.5M 

Improve Reliability of the Decay Heat Removal System – Torus Cooling 

Eliminate loss of torus cooling mode of RHR and RHRSW system events. 

35 37 370K 1.1M 

46 – Install an independent method of suppression pool cooling. 

 5.8M 

71 – Upgrade existing equipment to transfer water from the torus to the radwaste system. 

 11M 

73 – Provide ability to maintain suppression pool temperature lower. 

 1.3M 

Improve Reliability of the Decay Heat Removal System – Drywell Spray 

Eliminate loss of drywell sprays mode of RHR and RHRSW system events. 

17 55 320K 960K 

47 – Install a passive drywell spray system to provide a redundant drywell spray method. 

 5.8M 

Improve Reliability of Fission Product Scrubbing 

Reduce accident progression source terms by a factor of two (excluding noble gases). 

0 25 89K 270K 

48 – Install a filtered containment vent. 1.5M 49 – Enhance fire protection system and/or standby gas treatment system hardware and procedures. 

 2.5M 

Improve Reliability of Containment Venting Eliminate failure of the operator to 

control the venting evolution. 

~0 0 35K 110K 

50 – Modify containment venting procedure to control containment venting within a narrow band. 

 250K 
Appendix F

Draft NUREG-1437, Supplement 41 F-28 February 2010 

 % Risk Reduction Total Benefit ($) 

SAMA Modeling Assumptions 

CDF Population Dose Baseline (Internal + External) Baseline With Uncertainty Cost ($) 

Improve Reliability of Vacuum Breakers Eliminate failure of the vacuum 

breakers. 

1 4 23K 69K 

51 – Install improved vacuum breakers (redundant valves in each line). 

 500K 

Improve Reliability of Containment Overpressure Relief 

Eliminate failure of the hard pipe vent. 7 22 130K 380K 

52 – Provide passive overpressure relief by changing the containment vent valves to “fail open” and improving the strength of the rupture disk. 

 1.0M 

53 – Install an alternate path to the torus hard pipe vent via the wet well using a rupture disk. 

 5.7M 

Improve Reliability of Debris Barriers Eliminate the CDF contribution due to 

failure of the drywall (DW) barriers to prevent debris from contacting the shell. 

12 40 230K 680K 

70 – Install a curb to prevent debris from spreading across the floor and contacting the shell. 

 840K 

Reduce Probability of an Interfacing Systems Loss of Coolant Accident (ISLOCA) 

Eliminate all ISLOCA initiating events. <1 1 8.6K 26K 

54 – Increase frequency of valve leak testing. 100K 56 – Revise emergency operating procedures (EOPs) to improve ISLOCA identification. 

 50K 

57 – Improve operator training on ISLOCA coping. 

 110K 

Improve Reliability of MSIVs Eliminate failure of the MSIVs to close 

or remain closed. 

<1 0 2.7K 8.2K 

55 – Improve MSIV design to decrease the likelihood of containment bypass scenarios. 

 1.0M 
Appendix F 

February 2010 F-29 Draft NUREG-1437, Supplement 41 

 % Risk Reduction Total Benefit ($) 

SAMA Modeling Assumptions 

CDF Population Dose Baseline (Internal + External) Baseline With Uncertainty Cost ($) 

Improve Reliability of the Standby Liquid Control (SLC) System 

Eliminate the CDF contribution due to failure to initiate SLC and failures due to the boron concentration being too low. 

<1 2 12K 37K 

58 – Increase boron concentration in the SLC system. 

 >50K 

Improve Availability of Boron Injection Eliminate failure of the SLC system. 1 4 22K 67K 59 – Add an independent boron injection system. 

 >100K 

60 – Provide ability to use the CRD for alternate boron injection. 

 150K 

Improve SRV Reseat Reliability Eliminate failure of the SRVs to reseat. 1 <1 11K 32K 61 – Increase reliability of SRV to reseat after SLC injection. 

 2.2M 

Reduce Probability of Internal Flooding 62 – Improve internal flooding procedures. Eliminate failure of the operator to 

implement flood mitigation measures. 

2 2 17K 52K 460K 

74 – Provide flow diversion to help mitigate the fire water pipe break in the control building ground floor corridor. 

Eliminate failure to isolate the large and medium fire water pipe breaks in the control building ground floor corridor. 

<1 0 2.0K 6.1K >100K 

Increase Reliability of the Fire Water System Eliminate failure of the diesel-driven 

fire pump. 

3 2 27K 82K 

64 – Proceduralize the use of a fire pumper truck to pressurize the fire water system. 

 50K 

69 – Upgrade the seismic capacity of the diesel fire pump fuel tank and water supply tank. 

 >100K 

Improve Fire Suppression Capability Eliminate the fire CDF contribution 

from critical Switchgear Rooms 1F and 1G. 

Not Estimated 120K 350K 

63 – Add automatic fire suppression systems to the dominant fire zones. 

 375K 
Appendix F

Draft NUREG-1437, Supplement 41 F-30 February 2010 

 % Risk Reduction Total Benefit ($) 

SAMA Modeling Assumptions 

CDF Population Dose Baseline (Internal + External) Baseline With Uncertainty Cost ($) 

Reduce Risk from Fires that Require Control Room Evacuation 

Eliminate the fire CDF contribution from the main control room. 

Not Estimated 110K 340K 

65 – Upgrade the alternate shutdown system (ASDS) panel to include additional system controls for Division 1 equipment. 

 790K 

Reduce Probability of Large Break LOCA Eliminate all large break LOCA 

initiating events. 

1 3 19K 58K 

66 – Provide digital large break LOCA protection. 

 100K 

Reduce Frequency of Plant Trips and Shutdowns 

Reduce the probability of all initiating events except pipe breaks, floods, and loss of offsite power (LOOP) by a factor of two. 

39 35 390K 1.2M 

75 – Include Generation Risk Assessment (trip and shutdown modeling) in plant activities. 

 500K 

Improve Availability of RHRSW System Eliminate failure to use the RHRSW 

system without a SWBP. 

11 10 110K 330K 

79 – Modify procedures to allow use of the RHRSW system without a service water booster pump (SWBP). 

 25K 

Improve Plant Identification of Reference Leg Leakdowns 

Eliminate failure of cognitive recognition of a leakdown of the reference legs. 

1 0 5.3K 16K 

80 – Install additional instrumentation to assist in identifying a reference leg leakdown. 

 >100K 

(a)SAMAs in bold are potentially cost-beneficial (b)In response to an NRC staff RAI, NPPD clarified that SAMA 21 was originally included as a unique SAMA because it was believed that a suitable, existing 

portable power supply was available to supply the battery chargers (NPPD, 2009a). However, after further investigation, it was determined that the available 

skid-mounted portable power supply is not sufficient to supply the battery chargers and that a portable power supply would need to be purchased (which is the 

same as SAMA 13). 

(c)Modeling assumption information provided in response to NRC staff RAI 6d (NPPD, 2009a). (d)SAMA title changed in response to NRC staff RAI 6e (NPPD, 2009a).
Appendix F

February 2010 F-31 Draft NUREG-1437, Supplement 41 

1 F.6. Cost-Benefit Comparison 

2 NPPD's cost-benefit analysis and the NRC staff’s review are described in the following sections. 

3 F.6.1. Nebraska Public Power District’s Evaluation 

4 The methodology used by NPPD was based primarily on NRC’s guidance for performing 

5 cost-benefit analysis (i.e., NUREG/BR-0184, Regulatory Analysis Technical Evaluation 

6 Handbook) (NRC, 1997a). The guidance involves determining the net value for each SAMA 

7 according to the following formula: 

8 Net Value =(APE + AOC + AOE + AOSC) - COE where, 

9 APE = present value of averted public exposure ($) 

10 AOC = present value of averted offsite property damage costs ($) 

11 AOE = present value of averted occupational exposure costs ($) 

12 AOSC = present value of averted onsite costs ($) 

13 COE = cost of enhancement ($) 

14 If the net value of a SAMA is negative, the cost of implementing the SAMA is larger than the 

15 benefit associated with the SAMA and it is not considered cost-beneficial. NPPD’s derivation of 

16 each of the associated costs is summarized below. 

17 NUREG/BR-0058 has recently been revised to reflect the agency's policy on discount rates. 

18 Revision 4 of NUREG/BR-0058 states that two sets of estimates should be developed, one at 

19 3 percent and one at 7 percent (NRC, 2004). NPPD provided a base set of results using the 

20 7 percent discount rate and a sensitivity study using the 3 percent discount rate (NPPD, 2008). 

21 Averted Public Exposure (APE) Costs

22 The APE costs were calculated using the following formula: 

23 APE = Annual reduction in public exposure (∆ person-rem per year) 

24 x monetary equivalent of unit dose ($2,000 per person-rem) 

25 x present value conversion factor (10.76 based on a 20-year period with a 

26 7-percent discount rate) 

27 As stated in NUREG/BR-0184 (NRC, 1997a), the monetary value of the public health risk after 

28 discounting does not represent the expected reduction in public health risk due to a single 

29 accident. Rather, it is the present value of a stream of potential losses extending over the 

30 remaining lifetime (in this case, the renewal period) of the facility. Thus, it reflects the expected 

31 annual loss due to a single accident, the possibility that such an accident could occur at any 

32 time over the renewal period, and the effect of discounting these potential future losses to 

33 present value. For the purposes of initial screening, which assumes elimination of all severe 

34 accidents caused by internal events, NPPD calculated an APE of approximately $46,000 for the 

35 20-year license renewal period (NPPD, 2008). 
Appendix F

Draft NUREG-1437, Supplement 41 F-32 February 2010 

1 Averted Offsite Property Damage Costs (AOC)

2 The AOCs were calculated using the following formula: 

3 AOC = Annual CDF reduction 

4 x offsite economic costs associated with a severe accident (on a 

5 per-event basis) 

6 x present value conversion factor 

7 This term represents the sum of the frequency-weighted offsite economic costs for each release 

8 category, as obtained for the Level 3 risk analysis. For the purposes of initial screening, which 

9 assumes elimination of all severe accidents caused by internal events, NPPD calculated an 

10 annual offsite economic cost of about $7,000 based on the Level 3 risk analysis. This results in 

11 a discounted value of approximately $75,000 for the 20-year license renewal period 

12 (NPPD, 2008). 

13 Averted Occupational Exposure (AOE) Costs

14 The AOE costs were calculated using the following formula: 

15 AOE = Annual CDF reduction 

16 x occupational exposure per core damage event 

17 x monetary equivalent of unit dose 

18 x present value conversion factor 

19 NPPD derived the values for averted occupational exposure from information provided in 

20 Section 5.7.3 of the regulatory analysis handbook (NRC, 1997a). Best estimate values provided 

21 for immediate occupational dose (3,300 person-rem) and long-term occupational dose 

22 (20,000 person-rem over a 10-year cleanup period) were used. The present value of these 

23 doses was calculated using the equations provided in the handbook in conjunction with a 

24 monetary equivalent of unit dose of $2,000 per person-rem, a real discount rate of 7 percent, 

25 and a time period of 20 years to represent the license renewal period. For the purposes of initial 

26 screening, which assumes elimination of all severe accidents caused by internal events, NPPD 

27 calculated an AOE of approximately $4,400 for the 20-year license renewal period 

28 (NPPD, 2008). 

29 Averted Onsite Costs

30 Averted onsite costs (AOSC) include averted cleanup and decontamination costs and averted 

31 power replacement costs. Repair and refurbishment costs are considered for recoverable 

32 accidents only and not for severe accidents. NPPD derived the values for AOSC based on 

33 information provided in Section 5.7.6 of NUREG/BR-0184, the regulatory analysis handbook 

34 (NRC, 1997a). 

35 NPPD divided this cost element into two parts – the onsite cleanup and decontamination cost, 

36 also commonly referred to as averted cleanup and decontamination costs (ACC), and the 

37 replacement power cost. 
Appendix F 

February 2010 F-33 Draft NUREG-1437, Supplement 41 

1 ACC were calculated using the following formula: 

2 ACC = Annual CDF reduction 

3 x present value of cleanup costs per core damage event 

4 x present value conversion factor 

5 The total cost of cleanup and decontamination subsequent to a severe accident is estimated in 

NUREG/BR-0184 to be $1.5 x 109 6 (undiscounted). This value was converted to present costs 

7 over a 10-year cleanup period and integrated over the term of the proposed license extension. 

8 For the purposes of initial screening, which assumes elimination of all severe accidents caused 

9 by internal events, NPPD calculated an ACC of approximately $134,000 for the 20-year license 

10 renewal period. 

11 Long-term replacement power costs (RPC) were calculated using the following formula: 

12 RPC = Annual CDF reduction 

13 x present value of replacement power for a single event 

14 x factor to account for remaining service years for which replacement 

15 power is required 

16 x reactor power scaling factor 

17 NPPD based its calculations on the 910 megawatt-electric (MWe) reference plant in 

18 NUREG/BR-0184 (NRC, 1997b), and did not scale down to the 830 MWe rating for CNS-1. 

19 Therefore, NPPD did not apply a power scaling factor to determine the replacement power 

20 costs, which are conservative. For the purposes of initial screening, which assumes elimination 

21 of all severe accidents caused by internal events, NPPD calculated an RPC of approximately 

22 $91,000 and an AOSC of approximately $225,000 for the 20-year license renewal period 

23 (NPPD, 2008). 

24 Using the above equations, NPPD estimated the total present dollar-value equivalent 

25 associated with completely eliminating severe accidents from internal events at CNS-1 to be 

26 about $351,000. Use of a multiplier of 3 to account for external events increases the value to 

27 $1.05M and represents the dollar-value associated with completely eliminating all internal and 

28 external event severe accident risk at CNS-1, also referred to as the Modified Maximum Averted 

29 Cost Risk (MMACR). 

30 NPPD’s Results

31 If the implementation costs for a candidate SAMA exceeded the calculated benefit, the SAMA 

32 was considered not to be cost-beneficial. In the baseline analysis contained in the ER (using a 

33 7 percent discount rate) NPPD identified eight potentially cost-beneficial SAMAs. The potentially 

34 cost-beneficial SAMAs are: 

35 ● SAMA 25 – Develop procedures to allow bypass of the reactor core 

36 isolation cooling (RCIC) turbine exhaust pressure trip, extending the time 

37 available for RCIC operation. 

38 ● SAMA 30 – Revise procedures to allow manual alignment of the fire water 

39 system to the RHR heat exchangers, providing improved ability to cool the 

40 RHR heat exchangers in a loss of SW. 
Appendix F

Draft NUREG-1437, Supplement 41 F-34 February 2010 

1 ● SAMA 33 – Provide for the ability to establish an emergency connection of 

2 existing or new water sources to feedwater and condensate systems, 

3 increasing availability of feedwater. 

4 ● SAMA 40 – Revise procedures to provide additional space cooling to the 

5 EDG room via the use of portable equipment, increasing availability of the 

6 EDG. 

7 ● SAMA 45 – Provide an alternate means of supplying the instrument air 

8 header, increasing availability of instrument air. 

9 ● SAMA 68 – Revise procedures to allow the ability to cross-connect the 

10 circulating water pumps and the SW going to the TEC heat exchangers, 

11 allowing continued use of the power conversion system after SW is lost. 

12 ● SAMA 78 – Improve training on alternate injection via the fire water system, 

13 increasing the availability of alternate injection. 

14 ● SAMA 79 – Revise procedures to allow use of the RHRSW system without 

15 a SW booster pump, increasing availability of the RHRSW system. 

16 NPPD performed additional analyses to evaluate the impact of an alternative discount rate 

17 (3 percent) and remaining plant life (26 years instead of 20 years) on the results of the SAMA 

18 assessment. No additional SAMA candidates were determined to be potentially cost-beneficial 

19 (NPPD, 2008). 

20 If the benefits are increased by an additional factor of 3 to account for uncertainties, three 

21 additional SAMA candidates were determined to be potentially cost-beneficial: 

22 ● SAMA 14 – Provide a portable generator to supply DC power to individual 

23 panels during a SBO, increasing the time available for AC power recovery. 

24 ● SAMA 64 – Revise procedures to allow use of a fire pumper truck to 

25 pressurize the fire water system, increasing availability of the fire water 

26 system. 

27 ● SAMA 75 – Implement GRA (trip and shutdown risk modeling) into plant 

28 activities, decreasing the probability of trips/shutdown. 

29 The potentially cost-beneficial SAMAs, and NPPD’s plans for further evaluation of these SAMAs 

30 are discussed in more detail in Section F.6.2. 

31 F.6.2. Review of Nebraska Public Power District’s Cost-Benefit Evaluation 

32 The cost-benefit analysis performed by NPPD was based primarily on NUREG/BR-0184 

33 (NRC, 1997a) and discount rate guidelines in NUREG/BR-0058 (NRC, 2004) and was executed 

34 consistent with this guidance. 

35 SAMAs identified primarily on the basis of the internal events analysis could provide benefits in 

36 certain external events, in addition to internal events. To account for the additional benefits in 
Appendix F 

February 2010 F-35 Draft NUREG-1437, Supplement 41 

1 external events, NPPD multiplied the internal event benefits by a factor of 3 for each SAMA, 

2 except for two SAMAs that specifically address fire risk (SAMAs 63 and 65). Doubling the 

3 internal event estimate for SAMAs 63 and 65 would not be appropriate because these SAMAs 

4 are specific to fire risks and would not have a corresponding benefit on the risk from internal 

5 events. The NRC staff notes that the CNS-1 external events CDF is approximately 200 percent 

6 of the internal events CDF from the CNS-1 2007TM PSA model (based on the fire CDF of 1.9 x 

7 10-5 per year, a seismic CDF of 6 x 10-6 per year as estimated by the NRC staff, a negligible 

8 HFO contribution, and an internal events CDF of 1.2 x 10-5 per year). Accordingly, the total 

9 CDF from internal and external events would be approximately 2.1 times the internal events 

10 CDF from the CNS-1 2007 TM PSA model. Because the CDF from internal fires and other 

11 external events, as reported by NPPD, is about twice the CDF for internal events, the NRC staff 

12 agrees that the factor of 3 multiplier for external events is reasonable. 

13 NPPD provided the results of additional sensitivity analyses in the ER, including use of a 

14 3 percent discount rate and use of a longer plant life. These analyses did not identify any 

15 additional potentially cost-beneficial SAMAs. 

16 NPPD considered the impact that possible increases in benefits from analysis uncertainties 

17 would have on the results of the SAMA assessment. In the ER, NPPD states that an uncertainty 

18 analysis of the internal events CDF resulted in a 95th percentile value that is a factor of 

19 1.86 times the mean CDF. The ER further states that an uncertainty factor of 3 was 

20 conservatively selected for the uncertainty analysis. The NRC staff asked NPPD to provide the 

21 results of the internal events CDF uncertainty analysis and to provide further justification for the 

22 use of a factor of 3 for the SAMA uncertainty analysis. In response to the RAI, NPPD provided 

23 the results of the internal events CDF, which indicates that the 95th percentile is a factor of 

24 1.86 x the mean CDF as described in the ER. NPPD further clarified that the uncertainty factor 

25 of 3 was developed from an earlier version of the uncertainty analysis and that the SAMA 

26 analysis was not subsequently updated to avoid rework (NPPD, 2009a). Since the Phase I 

27 SAMAs were not screened based on quantitative criteria, a reexamination of the Phase I 

28 SAMAs based on the upper bound benefits was not necessary. NPPD considered the impact on 

29 the Phase II screening if the estimated benefits were increased by a factor of 3 (in addition to 

30 the multiplier of 3 for external events). Three additional SAMAs became cost-beneficial in 

31 NPPD’s analysis (SAMAs 14, 64, and 75 as described above). 

32 The NRC staff noted that SAMA 14, “portable generator for DC power to supply the individual 

33 panels,” and SAMA 13, “portable generator for DC power to supply the battery chargers,” both 

34 involve use of a portable generator and requested that NPPD reassess whether or not SAMA 13 

35 would be cost-beneficial if it were to use the same portable generator as for SAMA 14, which 

36 was determined to be cost beneficial (NRC, 2009). In response, NPPD stated that since the 

37 SAMA submittal, SAMA 13 has been implemented at CNS-1 (NPPD, 2009a). 

38 The NRC staff also noted that all of the SAMAs considered for basic event 

39 PCI-CNT-FF-PREEX, “pre-existing containment failure,” involve major hardware modifications. 

40 The NRC staff asked NPPD to provide an assessment of lower cost alternatives, such as 

41 periodic monitoring of containment integrity during normal operation or procedures to isolate the 

42 containment following an event (NRC, 2009). In response to the RAI, NPPD stated that these 

43 two specific alternatives have already been implemented at CNS-1 (NPPD, 2009a). NPPD 

44 further clarified that basic event PCI-CNT-FF-PREEX represents a preexisting containment 

45 failure leading to loss of net positive suction head (NPSH) to the ECCS pumps and that since 

46 the CNS-1 containment is inerted during normal operation, a leak large enough to lead to loss of 

47 NPSH would require significant nitrogen makeup and would be noticed by the operators. 
Appendix F

Draft NUREG-1437, Supplement 41 F-36 February 2010 

1 The NRC staff noted that for certain SAMAs considered in the ER, there may be alternatives 

2 that could achieve much of the risk reduction at a lower cost. The NRC staff asked the applicant 

3 to evaluate several additional lower cost alternatives to the SAMAs considered in the ER, 

4 including SAMAs that had been found to be potentially cost-beneficial at other BWR plants. 

5 These alternatives were: (1) providing additional space cooling to the RHRSW booster pump 

6 rooms, CS pump rooms, RHR pump rooms, SW pump rooms, and HPCI pump room via the use 

7 of portable equipment, (2) improving alternate shutdown training and equipment, (3) enhancing 

8 DC power availability by providing cables from diesel generators or another source to directly 

9 power battery chargers, (4) developing guidance/procedures for local, manual control of reactor 

10 core isolation cooling following loss of DC power, and (5) manually venting containment using 

11 either a local hand wheel or gas bottle supplies (NRC, 2009). NPPD provided a further 

12 evaluation of these alternatives and concluded that each had already been implemented at 

13 CNS-1 (NPPD, 2009a). 

14 In the ER and in response to an NRC staff RAI, NPPD indicated that detailed engineering 

15 project cost-benefit analyses have been initiated for the 11 potentially cost-beneficial SAMAs 

16 (NPPD 2008, 2009a). 

17 In light of the many potentially cost-beneficial SAMAs identified in the ER, the NRC staff asked 

18 NPPD to identify those SAMAs having higher priority for being considered for implementation 

19 based on risk reduction potential and implementation cost, and which SAMAs would no longer 

20 be cost-beneficial if these higher priority SAMAs were implemented (NRC, 2009). In response to 

21 the RAI (NPPD, 2009a), NPPD performed a qualitative assessment to prioritize the 

22 cost-beneficial SAMAs. NPPD determined that SAMAs 30, 33, 68, and 79 would have the 

23 highest priority based on their potential for significant reduction in risk and relatively low 

24 implementation cost. NPPD further identified SAMAs 14, 45, 75, and 78 as a second priority 

25 based on their potential for risk reduction and mitigation of plant risk contributors not addressed 

26 by SAMAs 30, 33, 68, and 79. The impact of the remaining potentially cost-beneficial SAMAs is 

27 expected to be reduced significantly if the higher priority SAMAs are implemented. The NRC 

28 considers this approach for prioritizing SAMAs to be reasonable. 

29 The NRC staff concludes that, with the exception of the potentially cost-beneficial SAMAs 

30 discussed above, the costs of the other SAMAs evaluated would be higher than the associated 

31 benefits. 

32 F.7. Conclusions 

33 NPPD compiled a list of 244 SAMAs based on a review of the most significant basic events from 

34 the plant-specific PSA, insights from the plant-specific IPE and IPEEE, Phase II SAMAs from 

35 license renewal applications for other plants, and review of other NRC and industry 

36 documentation. A qualitative screening removed SAMA candidates that (1) modified features 

37 not applicable to CNS-1, (2) had already been implemented at CNS-1, or (3) were similar and 

38 could be combined with another SAMA. Based on this screening, 164 SAMAs were eliminated 

39 leaving 80 candidate SAMAs for evaluation. 

40 For the remaining SAMA candidates, a more detailed design and cost estimate were developed 

41 as shown in Table F-5. The cost-benefit analyses showed that eight of the SAMA candidates 

42 were potentially cost-beneficial in the baseline analysis (Phase II SAMAs 25, 30, 33, 40, 45, 68, 

43 78, and 79). NPPD performed additional analyses to evaluate the impact of parameter choices 

44 and uncertainties on the results of the SAMA assessment. Three additional SAMAs were 

45 identified as potentially cost-beneficial in the ER (Phase II SAMAs 14, 64, and 75). NPPD has 
Appendix F 

February 2010 F-37 Draft NUREG-1437, Supplement 41 

1 indicated that detailed engineering project cost-benefit analyses have been initiated for the 11 

2 potentially cost-beneficial SAMAs. 

3 The NRC staff reviewed the NPPD analysis and concludes that the methods used and the 

4 implementation of those methods were sound. The treatment of SAMA benefits and costs 

5 support the general conclusion that the SAMA evaluations performed by NPPD are reasonable 

6 and sufficient for the license renewal submittal. Although the treatment of SAMAs for external 

7 events was somewhat limited, the likelihood of there being cost-beneficial enhancements in this 

8 area was minimized by improvements that have been realized as a result of the IPEEE process, 

9 and inclusion of a multiplier to account for external events. 

10 The NRC staff concurs with NPPD’s identification of areas in which risk can be further reduced 

11 in a cost-beneficial manner through the implementation of the identified, potentially 

12 cost-beneficial SAMAs. Given the potential for cost-beneficial risk reduction, the NRC staff 

13 agrees that further evaluation of these SAMAs by NPPD is warranted. However, these SAMAs 

14 do not relate to adequately managing the effects of aging during the period of extended 

15 operation. Therefore, they need not be implemented as part of license renewal pursuant to Title 

16 10 of the Code of Federal Regulations, Part 54. 

17 F.8. References 

18 American Association of Mechanical Engineers (ASME). 2007. “Standard for Probabilistic Risk 

19 Assessment for Nuclear Power Plant Applications.” RA-Sc-2007. August 2007. 

20 Eklund, Darrel L. et.al. 1999. “Using Water Demand to Determine Population Estimates and 

21 Projections for Kansas.” June 8, 1999. 

22 Electric Power Research Institute (EPRI). 1991. “A Methodology for Assessment of Nuclear 

23 Power Plant Seismic Margin.” EPRI NP-6041-SL, Revision 1, Palo Alto, CA. August 1991. 

24 Electric Power Research Institute (EPRI). 1993. “Fire-Induced Vulnerability Evaluation (FIVE).” 

25 EPRI TR-100370, Revision 1, Palo Alto, CA. September 1993. 

26 Electric Power Research Institute (EPRI). 1994. “EPRI Fire PRA Implementation Guide.” 

27 Prepared by Science Applications International Corporation for EPRI, Palo Alto, CA. January 

28 1994. 

29 Global Insight. 2006. “How Important is Tourism in Kansas? The Tourism Satellite Account 

30 Perspective.” Kansas Tourism in 2004, prepared by Global Insight. October 3, 2006. 

31 Iowa Department of Economic Development (IDED). 2006. “Iowa Tourism Results As of 

32 October 1, 2006.” Iowa Department of Economic Development Tourism Office. 

33 Kaylen, M. 2006. “Economic Impact of Missouri's Tourism and Travel Industry: July 2004–June 

34 2005 (FY05).” Executive Summary, MU-Tourism Economics Research Initiative, Columbia, 

35 Missouri. May 2006. 

36 Kennedy, R. P. (Kennedy). 1999. “Overview of Methods for Seismic PRA and Margin Analysis 

37 Including Recent Innovations.” Proceedings of the OECD-NEA Workshop of Seismic Risk, 

38 Tokyo, Japan. 10–12 August 1999. 

39 Missouri. 2007. “Population Projections for Missouri and the U.S.” Missouri Census Data 

40 Center. Available URL: http://mcdc2.missouri.edu/trends/projections/shtml (accessed on June 

41 12, 2007). 
Appendix F

Draft NUREG-1437, Supplement 41 F-38 February 2010 

1 Missouri State Emergency Management Agency. 1991. “Evacuation Time Estimate Study 

2 Atchison County Missouri.” August 1991. 

3 Nebraska Civil Defense Agency. 1993. “Evacuation Time Estimate Study Nemaha and 

4 Richardson Counties Nebraska.” January 1993. 

5 Nebraska Department of Economic Development (NDED). 2006. “2006 Fiscal Year Annual 

6 Report, July 1, 2005 - June 30, 2006.” Lincoln, Nebraska. 

7 Nebraska Public Power District (NPPD). 1993. “Generic Letter 88-20, Individual Plant 

8 Examination for Severe Accident Vulnerabilities – 10CFR50.54(f), IPE Report Submittal, Cooper 

9 Nuclear Station, Docket No. 50-298, DPR-46.” March 1993. ADAMS Accession Nos. 

10 ML073600192 (Volume 1) and ML073600193 (Volume 2). 

11 Nebraska Public Power District (NPPD). 1996. “Individual Plant Examination for External Events 

12 Report – 10 CFR 50.54(f), Cooper Nuclear Station, NRC Docket No. 50-298, License No. 

13 DPR-46.” October 1996. ADAMS Accession No. ML073580487. 

14 Nebraska Public Power District (NPPD). 2008. Cooper Nuclear Station — License Renewal 

15 Application, Appendix E: Applicant’s Environmental Report, Operating License Renewal Stage. 

16 Columbus, Nebraska. September 24, 2008. ADAMS Accession No ML083030246 (main report) 

17 and ML083030252 (attachments). 

18 Nebraska Public Power District (NPPD). 2009a. Letter from Stewart B. Minahan, NPPD to NRC 

19 Document Control Desk. Subject: Response to Request for Additional Information for License 

20 Renewal Application – Severe Accident Mitigation Alternatives, Cooper Nuclear Station, Docket 

21 No. 50-298, DPR-46. July 1, 2009. 

22 Nebraska Public Power District (NPPD). 2009b. Email from David W. Bremer, NPPD, to Bennett 

23 Brady, NRC. Subject: NRC Teleconference to discuss SAMA RAI Follow-up Questions and ER 

24 Questions. August 10, 2009. 

25 Nebraska Public Power District (NPPD). 2009c. Letter from NPPD, SAMA Meteorological 

26 Anomaly Related to the Cooper Nuclear Station License Renewal Application, December 7, 

27 2009. (ADAMS Accession No. 093490997) 

28 Nuclear Energy Institute (NEI). 2007. “Process for Performing Follow-on PRA Peer Reviews 

29 Using the ASME PRA Standard.” NEI 05-04, Rev. 1 (Draft G). November 2007. 

30 Seismic Qualification Users Group (SQUG). 1992. “Generic Implementation Procedure (GIP) for 

31 Seismic Verification of Nuclear Plant Equipment.” Revision 2, Corrected. February 14, 1992. 

32 University of Nebraska (UN). 2007. “Business in Nebraska Population Projection.” University of 

33 Nebraska Bureau of Business Research. Available URL: http://www.bbr.unl.edu/PopProjections/

34 (accessed on June 20, 2007). 

35 U.S. Department of Agriculture (USDA). 2002. “2002 Census of Agriculture.” National 

36 Agriculture Statistics Service. Available URL: 

37 http://www.nass.usda.gov/Census_of_Agriculture/index.asp (accessed on June 2007). 

38 U. S. Geologic Survey (USGS). 2008. “2008 NSHM Gridded Data, Peak Ground Acceleration.” 

39 Available URL: http://earthquake.usgs.gov/hazards/products/conterminous/2008/data/

40 U.S. Nuclear Regulatory Commission (NRC). 1988. Generic Letter 88-20, “Individual Plant 

41 Examination for Severe Accident Vulnerabilities.” November 23, 1988. 

42 U.S. Nuclear Regulatory Commission (NRC). 1990. Severe Accident Risks: An Assessment for 

43 Five U.S. Nuclear Power Plants. NUREG-1150, Washington, D.C. December 1990. 
Appendix F 

February 2010 F-39 Draft NUREG-1437, Supplement 41 

1 U.S. Nuclear Regulatory Commission (NRC). 1991. Generic Letter No. 88-20, Supplement 4, 

2 Individual Plant Examination of External Events for Severe Accident Vulnerabilities. 

3 NUREG-1407, Washington, D.C. June 28, 1991. 

4 U.S. Nuclear Regulatory Commission (NRC). 1996. Letter from David L. Wigginton, U.S. NRC, 

5 to Guy R. Horn, NPPD. Subject: Cooper Nuclear Station – Individual Plant Examination (IPE) for 

6 Internal Events (TAC No. M74400), Washington, D.C. February 14, 1996. 

7 U.S. Nuclear Regulatory Commission (NRC). 1997a. Regulatory Analysis Technical Evaluation 

8 Handbook. NUREG/BR-0184, Washington, D.C. January 1997. 

9 U.S. Nuclear Regulatory Commission (NRC). 1997b. Individual Plant Examination Program: 

10 Perspectives on Reactor Safety and Plant Performance. NUREG-1560, Washington, D.C. 

11 December 1997. 

12 U.S. Nuclear Regulatory Commission (NRC). 1997c. Code Manual for MACCS2: Volume 1, 

13 User’s Guide. NUREG/CR-6613, Washington, D.C. May 1998. 

14 U.S. Nuclear Regulatory Commission (NRC). 1999. Letter from Lawrence Burkhart, U.S. NRC, 

15 to G.R. Horn, NPPD. Subject: Plant-Specific Safety Evaluation Report for USI A-46 Program 

16 Implementation at Cooper Nuclear Station (TAC No. M69439). Washington, D.C. September 30, 

17 1999. 

18 U.S. Nuclear Regulatory Commission (NRC). 2001. “Cooper Nuclear Station – Review of 

19 Individual Plant Examination of External Events (TAC No. 83611).” Washington, D.C. April 27, 

20 2001. 

21 U.S. Nuclear Regulatory Commission (NRC). 2002. Perspectives Gained From the Individual 

22 Plant Examination of External Events. NUREG-1742, Vols. 1 & 2, Final Report, Washington 

23 D.C. April 2002. 

24 U.S. Nuclear Regulatory Commission (NRC). 2004. Regulatory Analysis Guidelines of the U.S. 

25 Nuclear Regulatory Commission. NUREG/BR-0058, Rev. 4, Washington, D.C. September 2004. 

26 U.S. Nuclear Regulatory Commission (NRC). 2007. “An Approach for Determining the Technical 

27 Adequacy of Probabilistic Risk Assessment Results for Risk-Informed Activities.” Regulatory 

28 Guide 1.200, Rev. 1, Washington, D.C. January 2007. 

29 U.S. Nuclear Regulatory Commission (NRC). 2009. Letter from Tam Tran, U.S. NRC, to Stewart 

30 B. Minahan, NPPD. Subject: Request for Additional Information for the Review of the Cooper 

31 Nuclear Station License Renewal Application (TAC Nos. MD9763 and MD9737), Washington, 

32 D.C. June 8, 2009. ADAMS Accession No. ML091530316. 

33 Woods & Poole. 2006. “2006 State Profile: Iowa.” Woods & Poole Economics, Inc.

BIBLIOGRAPHIC DATA SHEET

(See instructions on the reverse)

NRC FORM 335

(9-2004)

NRCMD 3.7

U.S. NUCLEAR REGULATORY COMMISSION 1. REPORT NUMBER

(Assigned by NRC, Add Vol., Supp., Rev.,

 and Addendum Numbers, if any.)

NUREG-1437, Supplement 41

3. DATE REPORT PUBLISHED

MONTH

February

YEAR

2010

4. FIN OR GRANT NUMBER

2. TITLE AND SUBTITLE

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

Supplement 41

Regarding Cooper Nuclear Station, Unit 1 

Draft Report

5. AUTHOR(S)

See Chapter 10 of report

6. TYPE OF REPORT

Technical

7. PERIOD COVERED (Inclusive Dates)

8. PERFORMING ORGANIZATION - NAME AND ADDRESS (If NRC, provide Division, Office or Region, U.S. Nuclear Regulatory Commission, and mailing address; if contractor,

Division of License Renewal

9. SPONSORING ORGANIZATION - NAME AND ADDRESS (If NRC, type "Same as above"; if contractor, provide NRC Division, Office or Region, U.S. Nuclear Regulatory Commission, 

Same as 8 above

provide name and mailing address.)

and mailing address.)

10. SUPPLEMENTARY NOTES

Docket Number 50-298

11. ABSTRACT (200 words or less)

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

Nebraska Public Power District (NPPD) to the Nuclear Regulatory Commission (NRC) to renew the Operating License for

Cooper Nuclear Station, Unit 1 (CNS-1), for an additional 20 years under 10 CFR Part 54. The SEIS includes the NRC staff's

analysis that considers and weighs the environmental impacts of the proposed action, the environmental impacts of alternatives

to the proposed action, and mitigation measures available for reducing or avoiding adverse impacts. It also includes the staff's

recommendation regarding the proposed action.

The NRC staff's preliminary recommendation is that the Commission determine that the adverse environmental impacts of

license renewal for CNS-1 are not so great that preserving the option of license renewal for energy-planning decision makers

would be unreasonable. The recommendation is based on (1) the analysis and findings in the GEIS; (2) the Environmental

Report submitted by NPPD; (3) consultation with Federal, State, and local agencies; (4) the staff's own independent review; and

(5) the staff's consideration of public comments.

12. KEY WORDS/DESCRIPTORS (List words or phrases that will assist researchers in locating the report.)

Cooper Nuclear Station, Unit 1

NPPD

Nebraska Public Power District

Supplement to the Generic Environmental Impact Statement

DSEIS

National Environmental Policy Act

NEPA

License Renewal

GEIS

NUREG 1437, Supplement 41

14. SECURITY CLASSIFICATION

13. AVAILABILITY STATEMENT

unlimited

(This Page)

unclassified

(This Report)

unclassified

15. NUMBER OF PAGES

16. PRICE

NRC FORM 335 (9-2004) PRINTED ON RECYCLED PAPER

Office of Nuclear Reactor Regulation

U.S. Nuclear Regulatory Commission

Washington, DC 20555-0001