NUREG-1437 

Supplement 40 

Generic Environmental 

Impact Statement for 

License Renewal of 

Nuclear Plants 

Supplement 40 

Regarding 

Kewaunee Power Station 

Draft Report for Comment 

Office of Nuclear Reactor Regulation 
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NUREG-1437 

Supplement 40 

Generic Environmental 

Impact Statement for 

License Renewal of 

Nuclear Plants 

Supplement 40 

Regarding 

Kewaunee Power Station 

Draft Report for Comment 

Manuscript Completed: January 2010 

Date Published: February 2010 

Office of Nuclear Reactor Regulation 

February 2010 iii Draft NUREG-1437, Supplement 40 

1 Proposed Action Issuance of a renewed operating license, DPR-43, for Kewaunee Power 

2 Station, in Kewaunee County, Wisconsin, near the town of Kewaunee. 

3 Type of Statement Draft Supplemental Environmental Impact Statement 

4 Agency Contact Vanice Perin 

5 U.S. Nuclear Regulatory Commission 

6 Office of Nuclear Reactor Regulation 

7 Mail Stop O-11F1 

8 Washington, D.C. 20555-0001 

9 Phone: 301-415-8143 

10 E-mail: Vanice.Perin@nrc.gov 

11 Comments Any interested party may submit comments on this supplemental 

12 environmental impact statement. Please specify NUREG-1437, 

13 Supplement 40, draft, in your comments. Comments must be received by 

14 April 21, 2010. Comments received after the expiration of the comment 

15 period will be considered if it is practical to do so, but assurance of 

16 consideration of late comments will not be given. Comments may be 

17 submitted e-mail to KewauneeEIS.Resource@nrc.gov or mailed to: 

18 Chief, Rulemaking, Directives, and Editing Branch 

19 Division of Administrative Services 

20 Office of Administration 

21 Mail Stop TWB-05-B01M 

22 U.S. Nuclear Regulatory Commission 

23 Washington, D.C. 20555-0001

February 2010 v Draft NUREG-1437, Supplement 40

1 ABSTRACT 

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

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

4 license for Kewaunee Power Station (KPS) 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 and natural gas combined-cycle 

8 generation; and a combination of alternatives that included natural gas combined-cycle 

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

10 the operating license (the no-action alternative). 

11 The preliminary determination is that the adverse environmental impacts of license renewal for 

12 KPS are not so great that preserving the option of license renewal for energy-planning decision 

13 makers would be unreasonable. 

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Abstract..........................................................................................................................................v 

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

2.1.1 Reactor and Containment Systems ...................................................................... 2-5 

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

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

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

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

2.1.3 Nonradioactive Waste Management..................................................................... 2-8 

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

2.1.3.2 General Plant Trash ..................................................................................... 2-9 

2.1.3.3 Universal Waste ........................................................................................... 2-9 

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

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

2.1.3.6 Pollution Prevention and Waste Minimization ............................................ 2-10 

2.1.4 Plant Operation and Maintenance ...................................................................... 2-11 

2.1.5 Power Transmission Systems ............................................................................ 2-11 

2.1.6 Cooling and Auxiliary Water Systems................................................................. 2-14 

2.1.7 Facility Water Use and Quality ........................................................................... 2-15 

2.1.7.1 Ground Water Use ..................................................................................... 2-15 

2.1.7.2 Surface Water Use..................................................................................... 2-15 

2.1.7.3 Dredging..................................................................................................... 2-15 

2.2 Affected Environment .................................................................................................. 2-15

2.2.1 Land Use ............................................................................................................ 2-16

2.2.2 Air Quality and Meteorology ............................................................................... 2-16 

2.2.2.1 Regional Air Quality Impacts...................................................................... 2-17 

2.2.3 Ground Water Resources ................................................................................... 2-18 

2.2.3.1 Kewaunee Power Station Water Supply Wells........................................... 2-19 

2.2.3.2 Kewaunee Power Station Ground Water Monitoring.................................. 2-20 

2.2.4 Surface Water Resources................................................................................... 2-20 

2.2.5 Aquatic Resources.............................................................................................. 2-22 

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

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2.2.7 Threatened and Endangered Species ................................................................ 2-30 

2.2.7.1 Aquatic Threatened and Endangered Species .......................................... 2-30 

2.2.7.2 Terrestrial Threatened and Endangered Species ...................................... 2-32 

2.2.8 Socioeconomic Factors ...................................................................................... 2-34 

2.2.8.1 Housing ...................................................................................................... 2-36 

2.2.8.2 Public Services........................................................................................... 2-37 

2.2.8.3 Offsite Land Use ........................................................................................ 2-39 

2.2.8.4 Visual Aesthetics and Noise....................................................................... 2-41 

2.2.8.5 Demography............................................................................................... 2-41 

2.2.8.6 Economy .................................................................................................... 2-46 

2.2.9 Historic and Archaeological Resources .............................................................. 2-53 

2.2.9.1 Cultural Background................................................................................... 2-53 

2.2.9.2 Historic and Archaeological Resources at the Kewaunee Power Station 

Site ............................................................................................................ 2-57 

2.3 Related Federal and State Activities ........................................................................... 2-57 

2.4 References.................................................................................................................. 2-58 

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

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

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

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

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

4.3 Generic Groundwater Issues......................................................................................... 4-2 

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

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

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

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

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

4.5.2.1 Nalco Environmental Sciences, 1975-1976 ................................................. 4-5 

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

4.5.3 Impingement ....................................................................................................... 4-10 

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

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

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

4.5.5 Total Impacts on Aquatic Resources .................................................................. 4-19 

4.6 Terrestrial Resources ................................................................................................... 4-19 

4.7 Threatened and Endangered Species.......................................................................... 4-20 

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

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

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

4.8.1 Generic Human Health Issues............................................................................ 4-22 

 4.8.1.1 Radiological Environmental Monitoring ..................................................... 4-22 

 4.8.1.2 Radioactive Effluent and Dose Information ............................................... 4-23 

4.8.2 Electromagnetic Fields – Acute Shock ............................................................... 4-24 

4.8.3 Electromagnetic Fields – Chronic Effects ........................................................... 4-26 

4.9 Socioeconomics .......................................................................................................... 4-26 

4.9.1 Generic Socioeconomic Issues .......................................................................... 4-27 

4.9.2 Housing Impacts ................................................................................................. 4-28 

4.9.3 Public Services: Public Utilities........................................................................... 4-29 

4.9.4 Offsite Land Use ................................................................................................. 4-29 

4.9.4.1 Population-Related Impacts ....................................................................... 4-30 

4.9.4.2 Tax-Revenue-Related Impacts .................................................................. 4-30 

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4.9.5 Public Services: Transportation Impacts During Operations .............................. 4-30 

4.9.6 Historic and Archaeological Resources .............................................................. 4-31 

4.9.7 Environmental Justice......................................................................................... 4-33 

4.9.7.1 Minority Population in 2000........................................................................ 4-35 

4.9.7.2 Low-Income Population in 2000................................................................. 4-37 

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

4.9.7.4 Subsistence Consumption of Fish and Wildlife .......................................... 4-39 

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

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

4.11.1 Cumulative Impacts on Water and Aquatic Resources .................................... 4-42 

4.11.2 Cumulative Impacts on Terrestrial Resources.................................................. 4-44 

4.11.3 Cumulative Impacts on Human Health ............................................................. 4-45 

4.11.4 Cumulative Impacts on Socioeconomics .......................................................... 4-46 

4.11.5 Cumulative Impacts on Air Quality.................................................................... 4-47 

4.11.6 Summary of Cumulative Impacts...................................................................... 4-48 

4.12 References................................................................................................................ 4-49 

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

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

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

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

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

5.2.3 Potential Plant Improvements............................................................................... 5-4 

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

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

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

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

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

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

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

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

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

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

6.2.1.2 Quantitative Studies ..................................................................................... 6-3 

6.2.2 Conclusions: Relative GHG Emissions................................................................. 6-8 

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

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

7.1 References.................................................................................................................... 7-1 

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

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

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

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

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

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

8.1.5 Human Health..................................................................................................... 8-10 

8.1.6 Socioeconomics.................................................................................................. 8-10 

8.1.7 Waste Management............................................................................................ 8-14 

8.2 Coal-Fired Generation................................................................................................. 8-14

8.2.1 Air Quality ........................................................................................................... 8-16 

8.2.2 Groundwater Use and Quality ............................................................................ 8-19 

8.2.3 Surface Water Use and Quality .......................................................................... 8-20 

8.2.4 Aquatic and Terrestrial Ecology.......................................................................... 8-20 

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8.2.5 Human Health..................................................................................................... 8-21 

8.2.6 Socioeconomics.................................................................................................. 8-22 

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

8.3 Combination Alternatives ............................................................................................ 8-26 

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

8.3.2 Groundwater Use and Quality ............................................................................ 8-30 

8.3.3 Surface Water Use and Quality .......................................................................... 8-31 

8.3.4 Aquatic and Terrestrial Ecology.......................................................................... 8-31 

8.3.5 Human Health..................................................................................................... 8-32 

8.3.6 Socioeconomics.................................................................................................. 8-32 

8.3.7 Waste Management............................................................................................ 8-36 

8.4 Purchased Power ........................................................................................................ 8-37 

8.5 Alternatives Considered but Dismissed....................................................................... 8-37 

8.5.1 Wind Power ........................................................................................................ 8-37 

8.5.2 Wood-Fired Power.............................................................................................. 8-38 

8.5.3 Energy Conservation .......................................................................................... 8-38 

8.5.4 Solar Power ........................................................................................................ 8-39 

8.5.5 Hydroelectric Power............................................................................................ 8-39 

8.5.6 Geothermal Power.............................................................................................. 8-39 

8.5.7 Biofuels ............................................................................................................... 8-39 

8.5.8 New Nuclear Power ............................................................................................ 8-40 

8.5.9 Oil-fired Power .................................................................................................... 8-40 

8.5.10 Fuel Cells.......................................................................................................... 8-40 

8.5.11 Municipal Solid Waste ...................................................................................... 8-41 

8.5.12 Delayed Retirement .......................................................................................... 8-41 

8.6 No-Action Alternative................................................................................................... 8-42 

8.6.1 Air Quality ........................................................................................................... 8-43 

8.6.2 Groundwater Use and Quality ............................................................................ 8-43 

8.6.3 Surface Water Use and Quality .......................................................................... 8-43 

8.6.4 Aquatic and Terrestrial Resources ..................................................................... 8-43 

8.6.5 Human Health..................................................................................................... 8-43 

8.6.6 Socioeconomics.................................................................................................. 8-44 

8.6.7 Waste Management............................................................................................ 8-45 

8.7 Alternatives Summary ................................................................................................. 8-45 

8.8 References.................................................................................................................. 8-46 

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

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

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

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

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

9.3.2 Relationship Between Local Short-Term Uses of the Environment and the 

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

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

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

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

APPENDIX A Comments Received on the Environmental Review .......................................... A-1 

APPENDIX B National Environmental Policy Act Issues for License Renewal of Nuclear Power 

Plants................................................................................................................ B-1 

Draft NUREG-1437, Supplement 40 x February 2010 
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APPENDIX C Applicable Regulations, Laws, and Agreements................................................C-1 

APPENDIX D Consultation Correspondences..........................................................................D-1 

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

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

Mitigation Alternatives for Kewaunee Power Station in Support of License 

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

FIGURES 

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

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

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

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

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

Figure 2-4. Kewaunee Power Station Transmission Line System ........................................... 2-13 

Figure 2-5. Primary Aquifers beneath the Kewaunee Power Station Site ............................... 2-19 

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

(DEK, 2008; USCB, 2003).................................................................................... 4-36 

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

(DEK, 2008; USCB, 2003).................................................................................... 4-38 

TABLES 

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

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

Table 2-1. Potable Water Usage (Gallons) at Kewaunee Power Station................................. 2-20 

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

Kewaunee Power Station ..................................................................................... 2-21 

Table 2-3. Listed Aquatic Species ........................................................................................... 2-31 

Table 2-4. Kewaunee Power Station Employee Residence by County (Wisconsin) ............... 2-35 

Table 2-5. Housing in Kewaunee, Manitowoc, and Brown Counties in Wisconsin .................. 2-36 

Table 2-6. Public Water Supply Systems (thousand gallons per day) ..................................... 2-38 

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

2006 Average Annual Daily Traffic Counts .......................................................... 2-39 

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

Wisconsin, from 1970 to 2000 and projected for 2008 to 2050............................ 2-41 

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

Three-County Socioeconomic Region of Influence (ROI) in 2000........................ 2-42 

Table 2-10. Demographic Profile of the Population in the Kewaunee Power Station ThreeCounty Socioeconomic Region of Influence in 2005-2007, 3-Year Estimate....... 2-43 

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

Power Station ....................................................................................................... 2-44 

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

50 Miles of the Kewaunee Power Station............................................................. 2-45 

Table 2-13. Major Employers in Kewaunee County in 2005.................................................... 2-46 

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

Influence, 2005–2007 3-Year Estimates .............................................................. 2-47 

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

Property in the Town of Carlton, 2004 to 2008 ..........................................2-50 

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

Property in the Town of Carlton, 2004 to 2008...........................................................2-51 

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

Kewaunee County for Utility Property in the Town of Carlton, Projected for 2009.....2-52 

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

Town Revenues, 2004 to 2008 ..................................................................................2-53 

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

Town Revenues, 2004 to 2008 ..................................................................................2-53 

Table 3-1. Issues Related to Refurbishment..................................................................................3-2

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

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

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

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

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

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

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

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

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

Table 4-10. KPS Thermal Plume Characteristics in Summer under Extreme Conditions..............4-17 

Table 4-11. KPS Thermal Plume Characteristics in Winter under Extreme Conditions.................4-18 

Table 4-12. Terrestrial Resources Issues ......................................................................................4-20 

Table 4-13. Threatened or Endangered Species...........................................................................4-20 

Table 4-14. Human Health Issues .................................................................................................4-22 

Table 4-15. Category 1 Issues Applicable to Socioeconomics during the Renewal Term.............4-27 

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

during the Renewal Term ...........................................................................................4-28 

Table 4-17. Summary of Cumulative Impacts on Resource Areas ................................................4-48 

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

Table 5-2. Kewaunee Power Station Internal Events Core Damage Frequency ...........................5-3 

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

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

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

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

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

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

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

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

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

Continued Kewaunee Power Station Operation.........................................................8-16 

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

Continued Kewaunee Power Station Operation.........................................................8-27 

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

Kewaunee Power Station Operation ..........................................................................8-42 

Table 8-5. Summary of Environmental Impacts of Proposed Action and Alternatives...................8-46 

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

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

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

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

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

Draft NUREG-1437, Supplement 40 xii February 2010 
Table of Contents 

February 2010 xiii Draft NUREG-1437, Supplement 40 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

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

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

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

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

steam generator) and late containment failures without containment spray 

dominate the population dose risk at Kewaunee Power Station ............................ F-4 

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

Table F.2-4. Important Fire Areas and Their Contribution to Fire Core Damage Frequency... F-12 

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

Kewaunee Power Station ..................................................................................... F-23 

 

February 2010 xv Draft NUREG-1437, Supplement 40 

1 EXECUTIVE SUMMARY 

2 BACKGROUND 

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

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

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

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

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

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

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

10 reactor operating license requires preparation of an Environmental Impact Statement (EIS) or a 

11 supplement to an existing EIS. In addition, 10 CFR 51.95(c) states that the EIS prepared at the 

12 operating license renewal stage will be a supplement to the Generic Environmental Impact 

13 Statement for License Renewal of Nuclear Plants (GEIS), NUREG-1437, Volumes 1 and 2 

14 (NRC 1996, 1999). 

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

16 described in 10 CFR Part 51 by publishing in 73 Federal Registrar Notice 59678, October 9, 

17 2009, a Notice of Intent to prepare an EIS and conduct scoping. We held a public scoping 

18 meeting on October 22, 2008, in the Town of Carlton, Wisconsin, and conducted a site audit at 

19 KPS in late May 2009. During the preparation of this draft SEIS for KPS, we reviewed DEK’s 

20 environmental report and compared it to the GEIS, consulted with other agencies, conducted a 

21 review of the issues following the guidance set forth in NUREG-1555, Supplement 1: Standard 

22 Review Plans for Environmental Reviews for Nuclear Power Plants, Supplement 1: Operating 

23 License Renewal (NRC 2000), and considered public comments received during the scoping 

24 process.

25 PROPOSED ACTION 

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

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

28 (DPR-43) expires December 21, 2013. NRC’s Federal action is the decision whether or not to 

29 renew the license for an additional 20 years. 

30 PURPOSE AND NEED FOR ACTION 

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

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

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

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

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

36 findings in the safety review required by the Atomic Energy Act of 1954 or findings in the NEPA 

37 environmental analysis that would lead the NRC to not grant a license renewal, the NRC does 

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

39 whether a particular nuclear power plant should continue to operate. If the renewed license is 
Executive Summary 

Draft NUREG-1437, Supplement 40 xvi February 2010 

1 issued, State regulatory agencies and DEK will ultimately decide whether the plant will continue 

2 to operate based on factors such as the need for power or other matters within the State’s 

3 jurisdiction or the purview of the owners. If the operating license is not renewed, then the facility 

4 must be shut down on or before December 21, 2013, when the current operating license 

5 expires. 

6 ENVIRONMENTAL IMPACTS OF LICENSE RENEWAL 

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

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

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

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

11 not identify any information that is both new and significant related to Category 1 issues that 

12 would call into question the conclusions in the GEIS. Similarly, neither the scoping process nor 

13 the NRC staff’s review has identified any new issue applicable to KPS that has a significant 

14 environmental impact. Therefore, the NRC staff relies upon the conclusions of the GEIS for all 

15 the Category 1 issues applicable to KPS. 

16 LAND USE 

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

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

19 no impacts beyond those discussed in the GEIS. 

20 AIR QUALITY 

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

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

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

24 GEIS. 

25 GROUND WATER USE AND QUALITY 

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

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

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

29 the GEIS. 

30 SURFACE WATER USE AND QUALITY 

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

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

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

34 beyond those discussed in the GEIS. 
Executive Summary 

February 2010 xvii Draft NUREG-1437, Supplement 40 

1 AQUATIC RESOURCES 

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

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

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

5 SMALL through the period of license renewal. 

6 TERRESTRIAL RESOURCES 

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

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

9 there are no impacts beyond those discussed in the GEIS. 

10 THREATENED AND ENDANGERED SPECIES 

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

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

13 is not expected to adversely affect any threatened or endangered species during the license 

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

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

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

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

18 environmental review checklists, environmental evaluation forms, and best management 

19 practices. 

20 HUMAN HEALTH 

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

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

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

24 information during the environmental review. Therefore, there are no impacts beyond those 

25 discussed in the GEIS. 

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

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

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

29 electric shock during the renewal period would be SMALL. 

30 For electromagnetic fields—chronic effects, the NRC staff considers the GEIS finding of 

31 “uncertain” still appropriate and will continue to follow developments on this issue. 

32 SOCIOECONOMICS 

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

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

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

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

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

Draft NUREG-1437, Supplement 40 xviii February 2010 

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

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

3 transportation impacts. 

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

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

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

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

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

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

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

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

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

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

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

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

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

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

18 subsistence consumption of fish and wildlife. 

19 SEVERE ACCIDENT MITIGATION ALTERNATIVES 

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

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

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

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

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

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

26 Based on our review of potential SAMAs, we conclude that KPS made a reasonable, 

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

28 KPS, and the plant improvements already made, we conclude that none of the potentially cost29 beneficial SAMAs relate to adequately managing the effects of aging during the period of 

30 extended operation; therefore, they need not be implemented as part of the license renewal 

31 pursuant to 10 CFR Part 54. 

32 ALTERNATIVES 

33 We considered the environmental impacts associated with alternatives to license renewal. 

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

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

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

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

38 Wherever possible, we evaluated potential environmental impacts for these alternatives located 

39 both at the KPS site and at some other unspecified alternate location. We evaluated each 
Executive Summary 

February 2010 xix Draft NUREG-1437, Supplement 40 

1 alternative using the same impact areas that we used in evaluating impacts from license 

2 renewal. The results of this evaluation are summarized in the table on the following page. 

3 COMPARISON OF ALTERNATIVES 

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

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

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

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

8 to those discussed in this document. 

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

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

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

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

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

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

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

16 plant. 

17 RECOMMENDATION 

18 Our preliminary determination is that the adverse environmental impacts of license renewal for 

19 KPS are not so great that preserving the option of license renewal for energy planning decision 

20 makers would be unreasonable. This determination is based on (1) the analysis and findings in 

21 the GEIS; (2) information submitted in DEK’s Environmental Report; (3) consultation with other 

22 Federal, State, and local agencies; (4) a review of other pertinent studies and reports; and (5) a 

23 consideration of public comments received during the scoping process. 
Executive Summary 

Draft NUREG-1437, Supplement 40 xx February 2010 

1 

Impact Area 

Alternative 

Air Quality 

Ground Water 

Surface Water 

Aquatic and Terrestrial 

Resources 

Human Health 

Socioeconomics 

Waste Management 

KPS License 

Renewal SMALL SMALL SMALL SMALL SMALL to 

MODERATE SMALL SMALL 

Supercritical coalfired at KPS site MODERATE SMALL SMALL MODERATE SMALL SMALL to 

LARGE MODERATE 

Supercritical coalfired at an 

alternate site 

MODERATE SMALL SMALL MODERATE SMALL SMALL to 

LARGE MODERATE 

Gas-fired at KPS 

site MODERATE SMALL SMALL SMALL to 

MODERATE SMALL SMALL to MODERATE SMALL 

Gas-fired at an 

alternative site MODERATE SMALL SMALL to 

MODERATE 

SMALL to 

MODERATE SMALL SMALL to MODERATE SMALL 

Combination of 

Alternatives #1 MODERATE SMALL SMALL to 

MODERATE 

SMALL to 

LARGE 

SMALL to 

MODERATE 

SMALL to 

LARGE SMALL 

No Action 

Alternative SMALL SMALL SMALL SMALL SMALL SMALL to 

MODERATE SMALL 

2 
February 2010 xxi Draft NUREG-1437, Supplement 40 

1 ABBREVIATIONS AND ACRONYMS

2 AADT average annual daily traffic 

3 ACC cleanup and decontamination costs 

4 ACHP Advisory Council on Historic Preservation 

5 ADAMS Agencywide Documents Access and Management System 

6 AEA Atomic Energy Act of 1954 

7 AEC U.S. Atomic Energy Commission 

8 AEO Annual Energy Outlook 

9 AEP area of potential effect 

10 AFW auxiliary feedwater 

11 ALARA as low as reasonably achievable 

12 AOC Averted Offsite Property Damage Costs 

13 AOCs Areas of Concern 

14 AOE Averted Occupational Exposure 

15 AOSC Averted onsite costs 

16 APE Averted Public Exposure 

17 AQCR air quality control region 

18 ATC American Transmission Company 

19 ATWS anticipated transient without scram 

20 AVD AVD Archaeological Services, Inc. 

21 

22 BPJ best professional judgment 

23 BTA best technology available 

24 Btu/ft3 British thermal units per cubic feet 

25 Btu/kWh British thermal units per kilowatt hour 

26 Btu/lb British thermal units per pound 

27 

28 CAA Clean Air Act 

29 CAIR Clean Air Interstate Rule 

30 CAMR Clean Air Mercury Rule 

31 CDF core damage frequency 

32 CDM clean development mechanism 
Abbreviations and Acronyms 

Draft NUREG-1437, Supplement 40 xxii February 2010 

1 CEQ Council on Environmental Quality 

2 CET containment event tree 

3 cfd cubic feet per day 

4 CFR Code of Federal Regulations 

5 cfs cubic feet per second 

6 CFT core flood tank 

7 CH4 methane 

8 CO carbon monoxide 

9 CO2 carbon dioxide 

10 CST condensate storage tank 

11 CVCS chemical and volume control system 

12 CWA Clean Water Act 

13 

14 DBA design-basis accident 

15 DEK Dominion Energy Kewaunee, Inc. 

16 DG diesel generator 

17 diesel-engine generator 

18 DOE Department of Energy 

19 DOT Department of Transportation 

20 

21 ECCS emergency core cooling system 

22 EDG emergency diesel generator 

23 EIA Energy Information Administration 

24 EIS environmental impact statement 

25 ELF extremely low frequency 

26 EMF electromagnetic fields 

27 EMS environmental management system 

28 EPA Environmental Protection Agency 

29 ER environmental report 

30 

31 F&O Fact & Observation 

32 FERC Federal Energy Regulatory Commission 
Abbreviation and Acronyms 

February 2010 xxiii Draft NUREG-1437, Supplement 40 

1 FES final environmental statement 

2 FIPs Federal Implementation Plans 

3 FIVE fire-induced vulnerability evaluation 

4 fps foot per second 

5 FR final regulations 

6 FSAR final safety analysis report 

7 FV Fussell-Vesely 

8 

9 gCeq/kWh grams conversion equivalent per kilowatt-hour 

10 GE General Electric Company 

11 GEIS generic environmental impact statement 

12 GHG greenhouse gas 

13 GLFC Great Lakes Fishery Commission 

14 GLWQA Great Lakes Water Quality Agreement 

15 gpd gallons per day 

16 gpm gallons per minute 

17 GWh gigawatt hours 

18 

19 HAP hazardous air pollutants 

20 HCLPF high confidence in low probability of failure 

21 HEP human error probability 

22 HFC hydrofluorocarbons 

23 HFE hydrofluorinated ethers 

24 HFO high winds, floods, and other 

25 Hg mercury 

26 HVAC heating, ventilation, and air conditioning 

27 Hz hertz 

28 

29 IAEA International Atomic Energy Agency 

30 IEEE Institute of Electrical and Electronics Safety Code 

31 IJC International Joint Commission 

32 IPA integrated plant assessment 
Abbreviations and Acronyms 

Draft NUREG-1437, Supplement 40 xxiv February 2010 

1 IPCC Intergovernmental Panel on Climate Change 

2 IPE individual plant examination 

3 IPEEE individual plant examination of external events 

4 ISLOCA interfacing systems loss-of-coolant accident 

5 

6 J joule 

7 

8 KPS Kewaunee Power Station 

9 kV kilovolt 

10 kW kilowatt 

11 kWh kilowatt-hours 

12 

13 LaMPs Lakewide Management Plans 

14 LERF large early release frequency 

15 LLMW low-level mixed waste 

16 LMMB Lake Michigan Mass Balance Study 

17 LOCA loss of coolant accident 

18 Lpd liters per day 

19 

20 m/s meters per second 

m3 21 /s cubic meters per second 

22 MAAP Modular Accident Analysis Program 

23 MACCS2 MELCOR Accident Consequence Code System 2 

24 MACT Maximum Achievable Control Technology 

25 MCC motor control center 

26 movement control center 

27 mgd millions of gallons per day 

28 Midwest RPO Midwest Regional Planning Organization 

29 MISO Midwest Independent Transmission System Operator 

30 MIT Massachusetts Institute of Technology 

31 MMACR Modified Maximum Averted Cost Risk 

32 mrem milliroentgen equivalent man 
Abbreviation and Acronyms 

February 2010 xxv Draft NUREG-1437, Supplement 40 

1 mSv mean square voltage 

2 MT metric tons 

3 MW megawatts 

4 MWd/MTU megawatt days per metric ton of uranium 

5 MWe megawatts-electric 

6 MWh megawatt hours 

7 MWt megawatts-thermal 

8 

9 N2O nitrous oxide 

10 NAS National Academy of Sciences 

11 NCDC National Climatic Data Center 

12 NCore national core 

13 NEA Nuclear Energy Agency 

14 NEPA National Environmental Policy Act 

15 NES Nalco Environmental Sciences 

16 NESC National Electric Safety Code 

17 NF3 nitrogen trifluoride 

18 ng nanograms 

19 NHPA National Historic Preservation Act 

20 NIEHS National Institute of Environmental Health and Sciences 

21 NIRS/WISE Nuclear Information and Resource Service/World 

22 Information Service on Energy 

23 NOAA National Oceanic and Atmospheric Administration 

24 NOx Nitrogen oxides 

25 NPDES National Pollutant Discharge Elimination System 

26 NRC U.S. Nuclear Regulatory Commission 

27 NRHP National Register of Historic Places 

28 NSR New Source Review 

29 NUREG/BR nuclear regulatory brochure 

30 NWS National Weather Service 

31 

32 ODCM offsite dose calculation manual 

33 
Abbreviations and Acronyms 

Draft NUREG-1437, Supplement 40 xxvi February 2010 

1 PBNP Point Beach Nuclear Plant 

2 PCBs polychlorinated biphenyls 

3 PDS plant damage state 

4 PFC perfluorocarbons 

5 PIC Proposal for Information Collection 

6 PILOT payment in lieu of taxes 

7 PMNP platform mounted nuclear plant 

8 PORV power-operated relief valve 

9 plant-operated relief valve 

10 POST Parliamentary Office of Science and Technology 

11 ppt parts per thousand 

12 PRA probabilistic risk assessment 

13 PWR pressurized water reactor 

14 

15 RAI request for additional information 

16 RAP remedial action program 

17 RCP reactor coolant pump 

18 RCRA Resource Conservation and Recovery Act 

19 RCS reactor coolant system 

20 rem roentgen equivalent man 

21 REMP radiological environmental monitoring program 

22 RHR residual heat removal 

23 RLE Review Level Earthquake 

24 RO reverse osmosis 

25 ROI region of interest 

26 ROW right of way 

27 RPC replacement power cost 

28 RPO regional planning organizations 

29 RWST refueling water storage tank 

30 

31 SAMA severe accident mitigation alternative 

32 SAR safety analysis report 
Abbreviation and Acronyms 

February 2010 xxvii Draft NUREG-1437, Supplement 40 

1 SBO station blackout 

2 SCR selective catalytic reduction 

3 SEIS supplemental environmental impact statement 

4 SER safety evaluation Report 

5 SF6 sulfur hexafluoride 

6 SGTR steam generator tube rupture 

7 SHPO State Historic Preservation Officer 

8 SMA seismic margins assessment 

9 SO2 sulfur dioxide 

10 SOx sulfur oxides 

11 SP sampling points 

12 SPDES State Pollutant Discharge Elimination System 

13 SR supporting requirement 

14 STC source term category 

15 Sv sievert 

16 

17 TER Technical Evaluation Report 

18 TWh terawatt-hours 

19 

20 USFWS U.S. Fish and Wildlife Service 

21 U.S.C. United States Code 

22 USCB U.S. Census Bureau 

23 USGCRP United States Global Change Research Program 

24 

25 VCT volume control tank 

26 WDHS Wisconsin Department of Health Services 

27 WDNR Wisconsin Department of Natural Resources 

28 WET Whole Effluent Toxicity 

29 WHS Wisconsin Historical Society 

30 WOG Westinghouse Owner’s Group 

31 WPDES Wisconsin pollutant discharge elimination system 

32 WPSC Wisconsin Public Service Corporation 

February 2010 1-1 Draft NUREG-1437, Supplement 40 

1 1.0 PURPOSE AND NEED FOR ACTION 

2 

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

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

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

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

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

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

9 40-year licensing period was based on economic and antitrust considerations rather than on the 

10 technical limitations of the nuclear facility.

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

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

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

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

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

16 period of extended operation. 

17 1.1 PROPOSED FEDERAL ACTION 

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

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

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

21 not to renew the license for an additional 20 years. 

22 1.2 PURPOSE AND NEED FOR PROPOSED FEDERAL ACTION 

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

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

25 plant operating license to meet future system generating needs. These needs may be 

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

27 NRC. This definition of purpose and need reflects the Commission’s recognition that, unless 

28 there are findings in the safety review required by the AEA or findings in the NEPA 

29 environmental analysis that would lead the NRC to not grant a license renewal, the NRC does 

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

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

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

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

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

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

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

Draft NUREG-1437, Supplement 40 1-2 February 2010 

1 1.3 MAJOR ENVIRONMENTAL REVIEW MILESTONES 

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

3 for public involvement. 

4 

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

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

7 NRC staff published a Notice of Acceptability and Opportunity for Hearing on October 1, 2008, 

8 in the Federal Register (Volume 73, p. 57154, (73 FR 57154)). The NRC published another 

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

10 scoping, thereby beginning the 60-day scoping period. 

Review 

Application 

Environmental 

Site Audit 

Draft 

SEIS 

 Issued 

Application 

Submitted to 

NRC 

*Scoping 

Process 

*Draft 

SEIS 

Process 

Final SEIS 

Issued 

NRC 

Decision 

* Opportunity 

 for Public 

 

Involvement 
Purpose and Need for Action 

February 2010 1-3 Draft NUREG-1437, Supplement 40 

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

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

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

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

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

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

7 received during the scoping process (NRC, 2009a). Appendix A to this draft supplemental EIS 

8 presents the comments considered to be within the scope of the environmental license renewal 

9 review and the associated NRC responses. 

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

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

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

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

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

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

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

17 supplemental environmental impact statement (SEIS), as shown in Figure 1-1. This document is 

18 made available for public comment for 75 days. During this time, NRC staff will host public 

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

20 the draft SEIS findings as necessary and publish the final SEIS. 

21 The safety review is conducted simultaneously with the environmental review. The staff 

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

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

24 or deny the issuance of a new license. 

25 1.4 GENERIC ENVIRONMENTAL IMPACT STATEMENT 

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

27 license renewal to improve the efficiency of the license renewal process. The Generic 

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

29 NUREG-1437 (NRC, 1996) documented the results of the NRC staff’s systematic approach to 

30 evaluate the environmental consequences of renewing the licenses of individual nuclear power 

31 plants and operating them for an additional 20 years. NRC staff analyzed in detail and resolved 

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

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

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

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

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

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

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

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

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

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

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

Draft NUREG-1437, Supplement 40 1-4 February 2010 

1 measures would be warranted for impacts that would have the same significance level for all 

2 plants. 

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

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

5 significance for potential impacts: SMALL, MODERATE, and LARGE, as defined below. 

6 

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

8 destabilize nor noticeably alter any important 

9 attribute of the resource. 

10 MODERATE – Environmental effects are 

11 sufficient to alter noticeably, but not to destabilize, 

12 important attributes of the resource. 

13 LARGE – Environmental effects are clearly 

14 noticeable and are sufficient to destabilize 

15 important attributes of the resource. 

16 The GEIS includes a determination of whether or 

17 not the analysis of the environmental issue could 

18 be applied to all plants and whether or not 

19 additional mitigation measures would be 

20 warranted (Figure 1-2). Issues are assigned a Category 1 or a Category 2 designation. As set 

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

22 (1) The environmental impacts associated with the issue have been determined to apply 

23 either to all plants or, for some issues, to plants having a specific type of cooling system 

24 or other specified plant or site characteristics. 

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

26 the impacts (except for collective offsite radiological impacts from the fuel cycle and from 

27 high-level waste and spent fuel disposal). 

28 (3) Mitigation of adverse impacts associated with the issue has been considered in the 

29 analysis, and it has been determined that additional plant-specific mitigation measures 

30 are likely not to be sufficiently beneficial to warrant implementation. 

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

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

33 identifying new and significant information is presented in Chapter 4. Site-specific issues 

34 (Category 2) are those that do not meet one or more of the criteria of Category 1 issues and, 

35 therefore, additional site-specific review for these issues is required. The results of that site36 specific review are documented in the SEIS. 

Significance indicates the importance 

of likely environmental impacts and is 

determined by considering two 

variables: context and intensity. 

 

Context is the geographic, 

biophysical, and social context in 

which the effects will occur. 

 

Intensity refers to the severity of the 

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

February 2010 1-5 Draft NUREG-1437, Supplement 40 

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

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

3 

4 

5 1.5 SUPPLEMENTAL ENVIRONMENTAL IMPACT STATEMENT 

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

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

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

9 environmental impacts from alternatives and Chapter 9 presents the preliminary 

10 recommendation to the Commission on whether or not the environmental impacts of license 

11 renewal are so great that preserving the option of license renewal would be unreasonable. The 

12 recommendation will be made after consideration of comments received during the public 

13 scoping period and on the draft SEIS. 

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

15 

16 ● reviewed the information provided in the DEK ER; 

17 ● consulted with other Federal, State, and local agencies; 
Purpose and Need for Action 

Draft NUREG-1437, Supplement 40 1-6 February 2010 

New and significant information either: 

(1) identifies a significant environmental issue 

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

considered in the analysis in the GEIS and 

leads to an impact finding that is different from 

the finding presented in the GEIS. 

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

2 ● considered the public comments received during the scoping process 

3 and on the draft SEIS. 

5 New information can be identified from a 

7 number of sources, including the applicant, 

9 NRC, other agencies, or public comments. 

11 If a new issue is revealed, then it is first 

13 analyzed to determine whether or not it is 

15 within the scope of the license renewal 

17 evaluation. If it is not addressed in the 

19 GEIS, then the NRC determines its 

20 significance and documents its analysis in the SEIS. 

21 1.6 COOPERATING AGENCIES 

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

23 agencies in the preparation of the SEIS. 

24 1.7 CONSULTATIONS 

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

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

27 1966 require that Federal agencies consult with applicable State and Federal agencies and 

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

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

30 consulted. Consultation documents are included in Appendix E. 

31 Table 1-1. Consultation Correspondences. List of the consultation documents sent by the 

32 NRC to other agencies, based on NEPA requirements. 

Recipient Date of Letter 

U.S. Fish and Wildlife Service 

(L. Clemency) ML082610748 

September 30, 2008 

Advisory Council on Historic Preservation 

(D. Klima) ML082610168 

October 8, 2008 

Wisconsin Historical Society 

(S. Banker) ML082670685 

October 10, 2008 

Wisconsin Coastal Management Program 

(K. Angel) ML082680027 

October 10, 2008 

Wisconsin Department of Natural Resources 

(R. Kazmierczak) ML082661119 

October 10, 2008 

Menominee Indian Tribe of Wisconsin 

(T. Virden) ML082800098 

October 16, 2008(a)

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

February 2010 1-7 Draft NUREG-1437, Supplement 40 

1 1.8 CORRESPONDENCE 

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

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

4 documents sent and received during the environmental review. 

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

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

7 Bay Mills Indian Community, Brimley, Minnesota 

8 Bureau of Indian Affairs, Ft. Snelling, Minnesota 

9 Citizen Potawatomi Nation, Shawnee, Oklahoma 

10 Forest County Potawatomi Community of Wisconsin, Crandon, Wisconsin 

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

12 Hannahville Indian Community, Wilson, Minnesota 

13 Ho-Chuck Nation, Black River Falls, Wisconsin 

14 Huron Potawatomi, Inc., Fulton, Minnesota 

15 Keweenaw Bay Indian Community, Baraga, Minnesota 

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

17 Little River Band of Ottawa Indians, Manistee, Minnesota 

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

19 Minnesota 

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

21 Hayward, Wisconsin 

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

23 Lac du Flambeau, Wisconsin 

24 Menominee Indian Tribe of Wisconsin, Keshena, Wisconsin 

25 Oneida Tribe of Indians Wisconsin, Oneida, Wisconsin 

26 Pokagon Band of Potawatomi Indians, Dowagiac, Minnesota 

27 Prairie Band Potawatomi Nation, Mayetta, Kansas 

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

29 Wisconsin 

30 Stockbridge Munsee Community of Wisconsin, Bowler, Wisconsin 

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

32 Minnesota 
Purpose and Need for Action 

Draft NUREG-1437, Supplement 40 1-8 February 2010 

1 Sokagon Chippewa Community, Mole Lake Band of Lake Superior Chippewa 

2 Indians, Crandon, Wisconsin 

3 St. Croix Chippewa Indians of Wisconsin, Webster, Wisconsin 

4 U.S. Fish and Wildlife Service, Green Bay, Wisconsin 

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

6 Wisconsin Coastal Management Program, Madison, Wisconsin 

7 Wisconsin Historical Society, Madison, Wisconsin 

8 Wisconsin Department of Natural Resources, Green Bay, Wisconsin 

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

Chris L. Funderburk, Director, 

Nuclear Licensing and Operations 

Support Dominion Resources 

Services, Inc. 

William R. Matthews, Senior Vice 

President – Nuclear Operations 

Innsbrook Technical Center 

Alan J. Price 

Vice President – Nuclear 

Engineering Innsbrook Technical 

Center 

Michael J. Wilson, Director 

Nuclear Safety & Licensing 

Dominion Energy Kewaunee, Inc. 

William D. Corbin, Director – Nuclear 

Engineering Innsbrook Technical 

Center 

Kewaunee Resident Inspectors 

Office 

U.S. Nuclear Regulatory 

Commission 

Thomas L. Breene 

Dominion Energy Kewaunee, Inc., 

Kewaunee Power Station 

Paul C. Aitken 

Supervisor – License Renewal 

Project Innsbrook Technical Center 

Lillian M. Cuoco, Esq. 

Senior Counsel Dominion Resources 

Services, Inc. 

Stephen E. Scace, Site Vice 

President Dominion Energy 

Kewaunee, Inc. 

David R. Lewis, Pillsbury Winthrop 

Shaw Pittman 

Ken Paplham 

Board Supervisor, Town of Carlton 

Jeff Kitsembel, P.E. 

Public Service Commission of 

Wisconsin 

Richard Gallagher, Senior Scientist, 

License Renewal 

Dominion Resources Services, Inc 

Ronald Kazmierczak, 

Regional Director, Wisconsin 

Department of Natural Resources 

Kathleen Angel, Federal Consistency 

and Coastal Hazards Coordinator, 

Wisconsin Coastal Management 

Program 

Steven Ugoretz, Environmental 

Analyst, 

Wisconsin Department of Natural 

Resources 

David Siebert, Director 

Office of Energy Wisconsin 

Department of Natural Resources 

David A. Heacock, President and 

Chief Nuclear Officer 

Dominion Energy Kewaunee, Inc. 

 

10 1.9 STATUS OF COMPLIANCE 

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

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

13 Appendix E of the GEIS. 

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

15 activities at KPS, as shown in Table 1-2. 

16 
Purpose and Need for Action 

February 2010 1-9 Draft NUREG-1437, Supplement 40 

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

Permit and Applicable Statute Number Dates Responsible Agency 

License to Operate (Atomic Energy 

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

50.10) 

DPR-43 Issued: Not Listed 

Expires: 12/21/13 NRC 

Approval (10 CFR 20.2002 Disposal 

of Contaminated WWTF Sludge) N/A Issued: 11/13/95 

Expires: Not Listed NRC 

Registration (49 USC 5108, 

Hazardous materials shipments) 062706 552 0750Q Expires: 06/30/09 Department of Transportation (DOT) 

Notification of Regulated Waste 

Activity (Federal Resource 

Conservation and Recovery Act, 42 

USC 6912; Ch. 291 Wisconsin 

Statutes) 

EPA ID# 

WID00713016 

Issued: Not Listed 

Expires: Not Listed 

Environmental 

Protection Agency 

(EPA) 

Permit for construction of water 

intake and discharge structures in 

Lake Michigan (33 USC 403) 

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

Expires: Not Listed 

U.S. Army Corps of 

Engineers (USACE) 

Permit for construction of water 

intake and discharge structures in 

Lake Michigan (Ch. 283 Wisconsin 

Statutes) 

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

Expires: Not Listed 

Wisconsin 

Department of Natural 

Resources (WDNR) 

Permit to construct and operate 

(Ch. 281 Wisconsin Statutes) 

3430 (Note: Current 

WPDES permit 

authorizes discharges.) 

Issued: 11/26/85 

Expires: Not Listed WDNR 

Letter Approval (Note: Continued 

authorization via WPDES permit.) 

(Ch. 283 Wisconsin Statutes) 

N/A Issued: 08/05/92 

Expires: Not Listed WDNR 

Individual WPDES permit (Clean 

Water Act (33 USC Section 1251 

et seq.), Ch. 283 Wisconsin Statutes 

WI-00001571-06 Issued: Not Listed 

Expires: 06/30/10 WDNR 

General WPDES Industrial Storm 

Water Discharge Permit (Clean 

Water Act (33 USC Section 1251 et 

seq.), Ch. 283 Wisconsin Statutes) 

WI-S049158-2 

Issued: Not Listed 

Expires: 03/31/06 

(Authorization continues. 

Automatically reissued 

when new permit 

becomes available.) 

WDNR 

Air Pollution Control Operation 

Permit (Federal Clean Air Act (42 

USC 7401 et seq.), Ch. 285 

Wisconsin Statutes) 

431022790-F11 (Note: 

DEK is considering 

conversion of this 

permit to a “Type A 

Registration 

Operation Permit,” Air 

Pollution Control Permit 

Number ROP-A01, 

issued by the WDNR.) 

Issued: Not Listed 

Expires 06/19/07 

(Note: A timely renewal 

application was 

submitted. 

Authorization continues 

under “Application shield” 

clause of s.285.62(8), 

statutes) 

WDNR 

Registration (Ch. 280 and 281 

Wisconsin Statutes) ID# 43104061 Issued: Not Listed 

Expires: Not Listed WDNR 

High-Capacity Well Approval (Ch. 

281 Wisconsin Statutes) 

Approval #s 52802, 

52803 

Issued 01/26/68 

Expires: Not Listed WDNR 
Purpose and Need for Action 

Draft NUREG-1437, Supplement 40 1-10 February 2010 

Permit and Applicable Statute Number Dates Responsible Agency 

Aboveground Storage Tank 

Registration (Ch. 101.09 Wisconsin 

Statutes 

Owner ID: 83035, Site 

ID: 679179, Tank ID: 

463455 

Issued: Not Listed 

Expires: Not Listed 

Wisconsin 

Department of 

Commerce 

Underground Storage Tank 

Registration (Federal Resource 

Conservation and Recovery Act (42 

USC 6901 et seq.), Ch. 101.09 

Wisconsin Statutes) 

Owner ID: 383035 Site 

ID: 679179 Tank IDs: 

285236, 2852239, 

406492, 771175, 

978062 

Issued: Not Listed 

Expires 05/28/06 

(285236, 2852239, 

978062) (Timely renewal 

application was 

submitted.) 

Expires 10/28/08 

(406492, 771175) 

Wisconsin 

Department of 

Commerce 

Radioactive waste transport permit 

(South Carolina Radioactive Waste 

Transportation and Disposal Act 

(S.C. Code of Laws 13-7-110 et 

seq.) 

0044-48-08 Issued: Not Listed 

Expires: 12/31/08 

South Carolina 

Department of Health 

and Environmental 

Control 

License to ship radioactive material 

(Tennessee Code Annotated 68-

202-206) 

T-WI003-L08 Issued: Not Listed 

Expires: 12/31/08 

Tennessee 

Department of 

Environment and 

Conservation 

Site Access Permit (R313-26 of Utah 

Radiation Control Rules) 0704004220 Issued: Not Listed 

Expires: 6/28/08 

Utah Department of 

Environmental Quality 

1 1.10 REFERENCES 

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

3 Regulations for Domestic Licensing and Related Regulatory Functions.” 

4 73 FR 57154, October 1, 2008, U.S. Nuclear Regulatory Commission, Washington, D.C., 

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

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

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

8 191, pp. 57154-57156. Washington, D.C. 

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

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

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

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

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

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

15 Power Station,” Docket No. 50-305. August 2008. Agencywide Documents Access and 

16 Management System (ADAMS) Accession No. ML082341039. 

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

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

19 ML082341020, ML082341038, ML082420854. 

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

21 Endangered Species Act of 1973 (ESA), 16 USC 1531, et seq. 
Purpose and Need for Action 

February 2010 1-11 Draft NUREG-1437, Supplement 40 

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

2 Sustainable Fisheries Act of 1996, 16 USC 1855, et seq. 

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

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

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

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

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

8 Process Summary Report for Kewaunee Power Station,” dated April 6, 2009. ADAMS 

9 Accession No. ML090770880. 

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

11 22, 2008, Site Audit Summary.” ADAMS Accession No. ML092180137.

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

13 2009, Site Audit Summary.” ADAMS Accession No. ML092050144. 

February 2010 2-1 Draft NUREG-1437, Supplement 40 

1 2.0 AFFECTED ENVIRONMENT 

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

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

4 approximately 30 miles east-southeast of Green Bay and 8 miles south of the city of Kewaunee. 

5 The KPS site boundary encompasses approximately 908 acres. Structures, facilities, and 

6 parking lots occupy approximately 60 acres, and approximately 450 acres are used for 

7 agriculture. The balance remains in a mixture of woods, fields in various stages of succession, 

8 small wetlands and watercourses, and open areas. The site includes approximately 2 miles of 

9 continuous frontage on the western shore of Lake Michigan. For purposes of the evaluation in 

10 this report, the “affected environment” is the environment that currently exists at and around 

11 KPS and its associated transmission lines’ rights of way. Because existing conditions are at 

12 least partially the result of past construction and operation at the plant, the impacts of the past 

13 and ongoing actions and how they have shaped the environment are presented here. The 

14 facility and its operation are described in Section 2.1 and the affected environment is presented 

15 in Section 2.2. 

16 2.1 FACILITY DESCRIPTION

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

18 source of potential environmental effects. Figures 2.1 and 2.2 present the 50-mile and 

19 6-mile vicinity maps around KPS, respectively. With the exception of a highway traversing the 

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

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

22 operated by Dominion Energy Kewaunee, Inc. (DEK) as shown in Figure 2.3.
Affected Environment 

Draft NUREG-1437, Supplement 40 2-2 February 2010 

1 

2 

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

 

February 2010 2-3 Draft NUREG-1437, Supplement 40 

1 

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

Draft NUREG-1437, Supplement 40 2-4 February 2010 

1 

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

 

February 2010 2-5 Draft NUREG-1437, Supplement 40 

1 2.1.1 Reactor and Containment Systems 

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

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

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

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

6 shield building. 

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

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

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

10 535 megawatts-electric (MWe). In 2004, the plant received a license amendment that increased 

11 the thermal output to 1,722 MWt and a gross electrical output of 590 MWe (DEK, 2008). 

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

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

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

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

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

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

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

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

20 2.1.2 Radioactive Waste Management 

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

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

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

24 (principally metallic corrosion products) and fission products resulting from defective fuel 

25 cladding or uranium contamination within the reactor coolant system. Operating procedures for 

26 the radioactive waste system ensure that radioactive wastes are safely processed and 

27 discharged from the plant within the limits set forth in Title 10 of the Code of Federal 

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

29 (DEK, 2008). 

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

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

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

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

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

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

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

37 Reactor fuel that has exhausted a certain percentage of its fissile uranium content is referred to 

38 as spent fuel. Spent fuel assemblies are removed from the reactor core and replaced with fresh 

39 fuel assemblies during routine refueling outages. Spent fuel assemblies are stored in the spent 
Affected Environment 

Draft NUREG-1437, Supplement 40 2-6 February 2010 

1 fuel pool. In addition to the spent fuel pool, spent nuclear fuel is expected to be stored in dry 

2 casks, located onsite, during the license renewal term. 

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

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

5 gaseous and liquid effluent monitoring alarm and trip setpoints. The methodology is used to 

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

7 also contains the radioactive effluent controls and radiological environmental monitoring 

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

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

10 2.1.2.1 Radioactive Liquid Waste 

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

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

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

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

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

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

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

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

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

20 The U.S. Nuclear Regulatory Commission (NRC) staff reviewed the KPS annual radioactive 

21 effluent release reports for liquid effluents from 2004 through 2008 (DEK 2005, 2006, 2007, 

22 2008a, 2009). Based on the liquid waste processing system’s performance from 2004 through 

23 2007, the liquid discharges for 2008 are typical of previous years. Variations on the amount of 

24 radioactive effluents released from year to year are expected based on the overall performance 

25 of the plant and the number and scope of outages and maintenance activities. The radioactive 

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

27 2.1.2.2 Radioactive Gaseous Waste 

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

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

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

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

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

33 atmosphere (DEK, 2008). 

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

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

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

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

38 effluent release reports for gaseous effluents from 2004 through 2008 (DEK 2005, 2006, 2007, 

39 2008a, 2009). Based on the gaseous waste processing system’s performance from 2004 

40 through 2007, the gaseous discharges for 2008 are typical of previous years. Variations on the 

41 amount of radioactive effluents released from year to year are expected based on the overall 
Affected Environment 

 

February 2010 2-7 Draft NUREG-1437, Supplement 40 

1 performance of the plant and the number and scope of outages and maintenance activities. The 

2 radioactive gaseous wastes reported by KPS are reasonable and no unusual trends were noted. 

3 2.1.2.3 Radioactive Solid Waste 

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

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

6 processor or for disposal. 

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

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

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

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

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

12 site-specific regulations (DEK, 2008). 

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

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

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

16 Low-Level Waste Compact and this has had a minimal effect on KPS’s ability to handle its 

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

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

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

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

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

22 The NRC Staff reviewed the 2004 through 2008 KPS low-level radioactive waste reports 

23 (DEK 2005, 2006, 2007, 2008a, 2009). The solid waste volumes and radioactivity amounts 

24 generated in 2008 are typical of previous annual waste shipments made by KPS. Variations in 

25 the amount of radioactive solid waste generated and shipped from year to year are expected 

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

27 maintenance activities. The volume and activity of radioactive solid wastes reported by KPS are 

28 reasonable and no unusual trends were noted. 

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

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

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

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

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

34 license renewal term. 
Affected Environment 

Draft NUREG-1437, Supplement 40 2-8 February 2010 

1 2.1.3 Nonradioactive Waste Management

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

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

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

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

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

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

8 nonhazardous solid waste and mandates minimum technological standards for municipal solid 

9 waste landfills (EPA, 2007). 

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

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

12 Management Program has many administrative codes and state statutes that govern the 

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

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

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

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

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

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

19 wastes. 

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

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

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

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

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

25 (DEK, 2009e). 

26 2.1.3.1 Hazardous Waste 

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

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

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

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

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

32 Listing of Hazardous Waste”). 

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

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

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

36 than 2,205 pounds (1,000 kg) of hazardous waste in one month; no more than 13,228 lbs (6,000 

37 kg) of hazardous waste may be accumulated on site at any one time; and accumulated 

38 hazardous waste is stored in aboveground tanks or containers for no more than 180 or 270 

39 days, depending on the distance the waste is transported for disposal (EPA, 2007a). During the 

40 KPS site audit in May 2009, NRC staff toured the warehouse where hazardous and universal 

41 wastes are safely and properly collected, sorted, packaged, and temporarily stored until offsite 

42 disposal. NRC staff also reviewed the DEK hazardous waste procedures documented in the 
Affected Environment 

 

February 2010 2-9 Draft NUREG-1437, Supplement 40 

1 “Kewaunee Power Station Hazardous Waste Plan” (DEK, 2009e) and determined that they are 

2 consistent with applicable RCRA regulations. 

3 2.1.3.2 General Plant Trash 

4 As part of routine plant maintenance and operations, KPS generates solid waste, as defined by 

5 RCRA. General plant trash includes paper, garbage, and construction waste. In 2008 KPS 

6 generated approximately 256 tons (232 metric tons (MT)) of general plant trash, and over the 

7 past five years it has generated approximately 1,000 tons (907 MT) of trash (DEK, 2009e). The 

8 majority of KPS trash is collected in a compactor dumpster to minimize volume and trips to the 

9 Kewaunee County landfill in West Kewaunee (DEK, 2008). The recycling program at KPS is 

10 discussed below in Section 2.1.3.6. 

11 2.1.3.3 Universal Waste 

12 Universal waste is hazardous waste that is generated in a variety of settings and by a vast 

13 community and poses collection and management problems. Universal waste often is not 

14 appropriately managed under existing hazardous waste regulations. The Environmental 

15 Protection Agency (EPA) classifies several hazardous wastes as universal wastes including 

16 batteries, certain pesticides, mercury-containing devices, and fluorescent lamps (40 CFR Part 

17 273, “Standards for Universal Waste Management”). KPS is a small-quantity handler of 

18 universal waste (i.e., the facility cannot accumulate more than 11,000 pounds (5,000 kg) of 

19 universal waste at any one time). KPS generates common operational wastes such as lighting 

20 ballasts containing polychlorinated biphenyls (PCBs), lamps, and batteries. From 2006 through 

21 2008, KPS generated approximately 8 tons (16,000 lbs (7,257 kg)) of universal waste 

22 (DEK, 2009e). Common universal waste is packaged together and stored in the onsite 

23 warehouse until disposed of offsite by a licensed disposal company. 

24 2.1.3.4 Low-Level Mixed Waste 

25 As previously discussed in Section 2.1.2.3, LLMW contains both low-level radioactive waste and 

26 RCRA hazardous waste (40 CFR Part 266, “Storage, Treatment, Transportation, and Disposal 

27 of Mixed-Waste”). KPS generates very small quantities of LLMW. From 2006 through 2008, 

28 LLMW at KPS consisted of Agitene (a cleaning solvent), paint residue, and excess caustic from 

29 testing and repair of caustic standpipe pumps. KPS generated 23 pounds (10.4 kg) of mixed 

30 waste in 2006, 25 pounds (11.4 kg) in 2007, and 14 pounds (6.4 kg) in 2008. As permitted by 

31 WDNR regulations, Agitene was disposed of by diluting it in the used oil stream and sent to the 

32 boiler fuel oil tank, as approved by the WDNR air permit for KPS (DEK, 2009c). 

33 2.1.3.5 Permitted Discharges 

34 KPS generates two types of wastewater—industrial effluents and sanitary liquid wastes, both of 

35 which are discharged to Lake Michigan according to the KPS WPDES Permit No. WI-0001571-

36 07-0, as enforced by WDNR (radioactive liquid waste is addressed in Section 2.1.2.1 of this 

37 report). A hypochlorinating system intermittently injects sodium hypochlorite into the condenser 

38 inlet waterboxes to clean and defoul the condenser of biological organisms and prevent the 

39 build-up of zebra mussels (Dreissena polymorpha) within the cooling system (DEK, 2008). This 

40 normal operational process generates chemical and biocide liquid wastes that are combined 
Affected Environment 

Draft NUREG-1437, Supplement 40 2-10 February 2010 

1 with the plant cooling water discharge. KPS cooling water is discharged to Lake Michigan within 

2 the plant’s WPDES permit limitations. Section 2.1.7.3 of this report provides more information 

3 on KPS WPDES permit and effluent limitations. 

4 KPS operates a permitted (WDNR Permit No. 3430) onsite sewage treatment facility to treat 

5 sanitary wastewater generated by the plant. As stated above, the sewage treatment facility 

6 discharges through a WPDES-permitted outfall to an unnamed tributary that flows to Lake 

7 Michigan. The sewage treatment facility has a design capability of 20,000 gallons per day (gpd) 

8 (75,708 liters per day (Lpd)); however, routine sewage processing is approximately 11,000 gpd 

9 (41,640 Lpd). During outage periods when more workers are onsite, this number approaches 

10 the design capacity (DEK, 2009e). Digested sanitary sludge is periodically transferred to a 

11 sludge holding tank where it is concentrated and sent for disposal to a WDNR-approved sewage 

12 treatment facility in Green Bay (DEK, 2008). 

13 2.1.3.6 Pollution Prevention and Waste Minimization 

14 Currently, KPS implements a waste minimization program that consists of steps such as 

15 segregating hazardous and nonhazardous wastes, choosing nonhazardous substitutes when 

16 possible, recycling or reclaiming appropriate waste materials, monitoring expired chemicals to 

17 determine minimum stocking requirements to reduce recurring excess, finding alternate uses for 

18 excess materials, or returning unused materials to the manufacturer. KPS also implements a 

19 recycling program for common waste materials such as paper, plastic, and metal. From 2006 

20 through 2008, KPS recycled 289.4 tons (263 MT) of non-metal materials (i.e., paper, plastic, 

21 and cardboard) and 71.5 tons (65 MT) of metal. 

22 In support of nonradiological waste minimization efforts, the EPA Office of Pollution Prevention 

23 and Toxics established a clearinghouse that provides information regarding waste management 

24 and technical and operational approaches to pollution prevention. The EPA clearinghouse can 

25 be used as a source for additional opportunities for waste minimization and pollution prevention 

26 at KPS, as appropriate (EPA, 2008f). 

27 The EPA also encourages the use of environmental management systems (EMSs) for 

28 organizations to assess and manage the environmental impact associated with their activities, 

29 products, and services in an efficient and cost-effective manner. EPA defines an EMS as “a set 

30 of processes and practices that enable an organization to reduce its environmental impacts and 

31 increase its operating efficiency.” EMSs help organizations fully integrate a wide range of 

32 environmental initiatives, establish environmental goals, and create a continuous monitoring 

33 process to help meet those goals. The EPA Office of Solid Waste especially advocates the use 

34 of EMSs at RCRA-regulated facilities to improve environmental performance, compliance, and 

35 pollution prevention (EPA 2008f). 
Affected Environment 

 

February 2010 2-11 Draft NUREG-1437, Supplement 40 

1 2.1.4 Plant Operation and Maintenance 

2 Maintenance activities conducted at KPS include inspection, testing, and surveillance to 

3 maintain the current licensing basis of the facility and to ensure compliance with environmental 

4 and safety requirements. Various programs and activities currently exist at KPS to maintain, 

5 inspect, test, and monitor the performance of facility equipment. These maintenance activities 

6 include inspection requirements for reactor vessel materials, boiler and pressure vessel 

7 in-service inspection and testing, maintenance structures monitoring program, and maintenance 

8 of water chemistry. 

9 Additional programs include those implemented to meet technical specification surveillance 

10 requirements, those implemented in response to NRC generic communications, and various 

11 periodic maintenance, testing, and inspection procedures. Certain program activities are 

12 performed during the operation of the unit, while others are performed during scheduled 

13 refueling outages. Nuclear power plants must periodically discontinue the production of 

14 electricity for refueling, periodic in-service inspection, and scheduled maintenance. KPS refuels 

15 at 18-month intervals. 

16 2.1.5 Power Transmission Systems 

17 As stated in the Environmental Report for the license renewal of KPS (DEK, 2008): 

18 In 1999, the Wisconsin legislature passed Act 9, which encouraged utilities with 

19 service areas in Wisconsin to transfer ownership and operation of transmission 

20 assets to an independent transmission company. In response to the Act, WPSC 

21 [Wisconsin Public Service Corporation] and WP&L [Wisconsin Power and Light 

22 Company (owners of KPS at the time)] transferred ownership of their 

23 transmission lines to the American Transmission Company (ATC). 

24 ATC, DEK, and Midwest Independent Transmission System Operator (MISO) 

25 have a three-party Generator to Transmission Interconnection Agreement for 

26 KPS filed with the Federal Energy Regulatory Commission (FERC), whereby 

27 ATC transferred operation of its facilities to the MISO. In doing so, ATC acts in 

28 the capacity of the transmission system operator and MISO is the independent 

29 system operator. 

30 KPS is connected to the regional grid via two 138-kilovolt (kV) and two 345-kV transmission 

31 lines, which total 80.6 miles (129.7 km) in length. Transmission lines considered in scope for 

32 license renewal are those constructed to connect the facility to the transmission system 

33 (10 CFR 51.53(c)(3)(ii)(H)); therefore, the four lines (Line F-84, Line Y-51, Line R-304, and Line 

34 Q-303) are considered in scope and are discussed below in detail. 

35 All four transmission lines originate at the KPS switchyard and are shown in Figure 2.4. 

36 Line F-84, which is a 138-kV transmission line, connects from the KPS site substation to the 

37 East Krok Substation, and travels a total distance of 8.2 miles (13.2 km). Line Y-51, which is 

38 also a 138-kV transmission line, connects from the KPS site to the Shoto Substation, which is 

39 16.2 miles (26.1 km) in total length. Line R-304, a 345-kV transmission line, is the longest 

40 transmission line associated with the KPS site, and connects from the KPS site to the North 
Affected Environment 

Draft NUREG-1437, Supplement 40 2-12 February 2010 

1 Appleton substation, traveling a total distance of 50.6 miles (81.4 km). Finally, line Q-303, also a 

2 345-kV transmission line, travels a total distance of 5.6 miles (9.0 km), connecting from the KPS 

3 site substation to the Point Beach Nuclear Plant substation 

4 (DEK, 2008). 

5 All transmission lines associated with the KPS site have rights of way (ROWs) with an average 

6 width of 150 feet (45.7 m). Additionally, there is a 50-foot (15-m) minimum buffer between the 

7 ROWs and any waterways and wetlands; however, buffers can vary up to 200 feet (61 m), 

8 based on agreements with the landowners or the State. These transmission lines ROWs total 

9 75 miles (121 km) of corridor, and account for an area of approximately 1270 acres (514 ha). 

10 The substation on the KPS site, the switchyards off site, and transmission towers (poles) occupy 

11 approximately 10 acres (4 ha). Ecosystem land types along the transmission line ROWs are 

12 comprised of approximately 84 percent farmland, 7 percent woodland, 2 percent wetlands, and 

13 7 percent scrubland (DEK, 2008). 
Affected Environment 

 

February 2010 2-13 Draft NUREG-1437, Supplement 40 

1 

2 Figure 2-4. Kewaunee Power Station Transmission Line System 
Affected Environment 

Draft NUREG-1437, Supplement 40 2-14 February 2010 

1 2.1.6 Cooling and Auxiliary Water Systems 

2 KPS uses a once-through heat dissipation system that withdraws water from, and discharges it 

3 to, Lake Michigan. Unless otherwise noted, the discussion of the cooling-water system is 

4 adapted from the environmental report (ER) (DEK, 2008), or information gathered by the NRC 

5 at the site audit. 

6 Water is withdrawn from Lake Michigan via an intake structure located approximately 1,600 feet 

7 (488 m) from the shore east-northeast of KPS. The circulating water intake structure consists of 

8 a cluster of three inlets that are submerged at a depth of 15 feet (4.6 m). Each inlet is 22 feet 

9 (6.7-m) in diameter and contains 2- by 2-foot (0.6- by 0.6-m) trash grills to prevent the intake of 

10 debris. Surface water velocity at the intake inlets is less than 1 foot per second (fps) or 0.3 

11 meters per second (m/s) when the plant is running at full power. The three intake inlets are each 

12 reduced to 6-foot (1.8-m) diameter steel pipes, which join to one 10-foot (3-m) diameter steel 

13 pipe buried approximately 3 feet (0.9 m) below the lake bottom. The buried intake pipe brings 

14 water to a 56.5- by 25-foot (17.2- by 7.6-m) onshore forebay, which contains a 38.5-foot (11.7-

15 m)-long weir for overflow. Water velocity within the forebay ranges from 0.22 to 0.88 m/s (0.72 

16 to 2.9 fps) at maximum flow and from 0.10 to 0.5 m/s (0.33 to 1.6 fps) at minimum flow (NES, 

17 1976b). From the forebay, water passes through four 10-foot (3-m)-wide by 36-foot 

18 (11-m)-long woven wire traveling screens with 3/8-inch (0.95-cm) mesh and automatic 

19 backwash that extend from the forebay bottom to 10 feet (3 m) above water level (NES, 1976b). 

20 During normal operation, the screens are automatically rotated every 4 hours for a 45-minute 

21 duration, or for a 10-minute duration during a 6-inch (15-cm) pressure drop (NES, 1976b). Any 

22 fish and debris that are automatically backwashed from the traveling screens are returned to the 

23 lake via the 10-foot (3-m) diameter discharge tunnel. 

24 Once taken in, water is pumped by two vertical dry-pit circulating water pumps, each designed 

25 to supply 210,000 gallons per minute (gpm) (468 cubic feet per second (cfs) or 13.2 cubic 

meters per second (m3 26 /s)). Normal flow rate throughout the cooling system is approximately 

400,000 gpm (891 cfs or 25.2 m3 27 /s). In the winter months, the reduced temperature of the lake 

28 requires less water for cooling, such that the flow rate is reduced to approximately 287,000 gpm 

(639 cfs or 18.1 m3 29 /s) (AEC, 1972). Generally, higher flow rates are employed from May through 

30 November, and lower flow rates are employed from December through April 

31 (NES, 1976b). 

32 Water is returned to Lake Michigan via a 10-foot (3-m) diameter concrete discharge tunnel after 

33 passing through the condenser. The discharge tunnel connects to a discharge structure located 

34 on the shoreline, just south of the forebay. During periods of sub-freezing weather, a 

35 recirculating pump routes water to the intake inlet grills and traveling screens to prevent icing. 

36 In addition to the circulating water intake, two auxiliary water intake tees are located 50 and 100 

37 feet (15 and 30 m) shoreward of the circulating water intake. Each tee has a 30-inch (76-cm), 

38 screened opening approximately 1 foot (0.3 m) above the lake bottom. The screen cover plates 

39 on the openings prevent entrainment of debris and aquatic organisms. Each auxiliary water 

intake can supply water in excess of 24,000 gpm (53.5 cfs or 1.5 m3 40 /s). 
Affected Environment 

 

February 2010 2-15 Draft NUREG-1437, Supplement 40 

1 Cooling water is intermittently treated with sodium hypochlorite to prevent micro- and macro2 fouling within the cooling system in accordance with limits specified in the KPS WPDES Permit 

3 (WDNR, 2005). 

4 2.1.7 Facility Water Use and Quality 

5 Both the KPS circulating water system and the service water system draw water from, and 

6 discharge to, Lake Michigan. Onsite ground water wells also supply water for cooling water 

7 makeup and for the plant equipment water system. The following sections detail water use at 

8 KPS. 

9 2.1.7.1 Ground Water Use 

10 Ground water use at KPS is relatively minor compared to the total amount of water used for 

11 operations. Specifically, KPS uses ground water for cooling, stand-by cooling, and for the plant 

12 equipment water system (DEK, 2008). The plant draws onsite groundwater from two wells 

13 installed at depths of 310 feet (94 m) and 320 feet (98 m). WDNR permits groundwater 

14 withdrawals from these wells, which averaged a total annual pump rate of 3,339,176 gallons per 

year (6.4 gpm or 4.0 x 10-4 m3 15 /s) from 1977 to 1989 (DEK, 2009a). In 1995, this withdrawal rate 

increased to an average total pump rate of 25 gpm (1.6 x 10-3 m3

/s) to 61 gpm (3.9 x 10-3 m3 16 /s) 

17 (DEK, 2009a). An additional 14 wells were installed in 2007 for ground water monitoring 

18 purposes (STS, 2007). 

19 2.1.7.2 Surface Water Use 

KPS withdraws 401,200 gpm (894 cfs or 25.3 m3 20 /s) from Lake Michigan when both pumps are 

21 operating. Because KPS uses a once-through cooling system, consumptive water losses are 

22 minimal and the majority of the cooling water withdrawn is discharged directly back to Lake 

23 Michigan in a manner complying with the plant’s WPDES Wastewater Discharge Permit No. WI24 00001571-06 issued by WDNR in 2005 (WPDES, 2005). 

25 The intake structure is designed to pump lake water into the system via a 10-foot diameter (3 m) 

26 pipe. Normal lake elevation at the intake is 577 feet (176 m). During summer operations, when 

27 two of the plant’s circulating water pumps are in service, the water level is approximately 571 

28 feet (174 m). During winter operations, when only one circulating water pump is in service, the 

29 water level is approximately 574 feet (175 m). Because the circulating water pump requires a 

30 level of at least 566 feet (172.5 m), low level procedures are activated for the plant if the water 

31 level decreases to 567.5 feet (173 m) (DEK, 2008d). 

32 2.1.7.3 Dredging 

33 KPS does not conduct any maintenance dredging activities and does not plan to initiate any 

34 during the license renewal term (DEK, 2008). 

35 2.2 AFFECTED ENVIRONMENT

36 KPS is located on approximately 908 acres of land owned and operated by DEK, on the west37 central shore of Lake Michigan in Kewaunee County, Wisconsin, as shown in Figure 2.1-2. Of 
Affected Environment 

Draft NUREG-1437, Supplement 40 2-16 February 2010 

1 the 908 acres, 450 acres are currently used for agriculture. The developed portion of the site 

2 consisting of the power plant structure, reactor containment, and associated buildings, 

3 maintenance facilities, parking lots, and roads occupies approximately 60 acres of the site. The 

4 balance of land remains in a mixture of woods, fields in various stages of succession, small 

5 wetlands and watercourses, and open areas (DEK, 2008). 

6 2.2.1 Land Use 

7 The immediate area around KPS is completely enclosed by a security fence, with access to the 

8 station controlled at a security gate. The exclusion area, as defined by 10 CFR 100.3, surrounds 

9 the plant site as shown in Figure 2.1-3. The plant site can be accessed by road on the west side 

10 or from Lake Michigan on the east. Road access to the plant site is from State Highway 42 

11 (DEK, 2008). The Two Creeks Buried Forest State Natural Area, a unit of the Ice Age National 

12 Scientific Reserve, is located approximately one mile south of the KPS property. The Reserve is 

13 a separate affiliated area of the National Park Service. 

14 2.2.2 Air Quality and Meteorology 

15 KPS is located in Carlton, Wisconsin, approximately 27 miles (44 km) southeast of Green Bay 

16 on the western shore of Lake Michigan, in the eastern part of Wisconsin. Slightly rolling 

17 topography of the region was formed by continental glaciers that slowly moved across 

18 Wisconsin for lengthy periods of time, leaving behind ground moraine of till, sand and gravel. 

19 The climate of Wisconsin is continental and belongs to “Dfb” type of the Köppen climate 

20 classification: hot summers with very cold winters and evenly distributed precipitation throughout 

21 the year. The growing season is significantly longer in the eastern part of Wisconsin (from late 

22 April–early May to late September–early October), due to the influence of Lake Michigan, than 

23 in central and northern parts of Wisconsin. The growing season in southwestern parts of the 

24 State has the same duration. The first fall freezes usually occur in mid-October, later than in 

25 northern and central parts of Wisconsin, because of the close proximity to Lake Michigan. 

26 The dominant wind direction throughout the State of Wisconsin is from the west. However, wind 

27 direction in the vicinity of the KPS is strongly influenced by Lake Michigan. There are onshore 

28 and offshore winds at the KPS location. Onshore winds are northeastern winds that blow from 

29 Lake Michigan toward the land, while southwestern winds that blow from the land to Lake 

30 Michigan are defined as offshore winds. There are seasonal wind direction variations such as 

31 northeast wind occurrences in the spring and northwestern winds in winter that comprise the 

32 majority of the winds at KPS. The average annual wind speed for the National Weather Service 

33 Station located in Green Bay, Wisconsin, (27 miles (44 km) northwest of KPS) is 9.9 miles per 

34 hour (mph) (8.9 knots). 

35 Wisconsin belongs to the Midwestern Regional Climate Center of the National Oceanic and 

36 Atmospheric Administration (NOAA). Historical data compiled by NOAA National Climatic Data 

37 Center (NCDC) from 1971 to 2000 30-year period indicates that mean annual temperature in 

38 Kewaunee County is 44.1°F (6.7°C) and ranges from 68.6°F (20.3°C) in July to 18°F (7.78°C) in 

39 January (NCDC, 2009a). According to the Center’s historic climate data for the Kewaunee 3 

40 NW, WI Station, which is located approximately 8 miles (approximately 13 km) from KPS, 

41 annual precipitation is 30.30 inches (approximately 77 cm), with June–September period being 
Affected Environment 

 

February 2010 2-17 Draft NUREG-1437, Supplement 40 

1 the wettest (NCDC, 2009). Precipitation is distributed according to the demands of the seasons 

2 with the majority of the precipitation occurring during the growing, freeze-free period; however, 

3 occasionally droughts do occur in the area. Severe weather is typical for Wisconsin. Floods 

4 have caused the most damage to the people and property in the State. According to the data 

5 recorded by NCDC, 935 floods occurred in the State of Wisconsin from 1950 to 2008 (NCDC, 

6 2009b). Two flood events were reported in Kewaunee County: the flood of June 1996, which 

7 affected several counties of Eastern Wisconsin and caused $56 million in property damages, 

8 and the flood of March 2007, caused by heavy snowfall, which did not cause any damages. 

9 Seven tornadoes hit Kewaunee County between 1950 and 2009 (NCDC, 2009c). 

10 2.2.2.1 Regional Air Quality Impacts 

11 Kewaunee County, where KPS is located, belongs to the Lake Michigan Intrastate Air Quality 

12 Control Region (Wisconsin) (AQCR) designated by the EPA and codified in 40 CFR 81.67 and 

13 Chapter 404.03 of the Wisconsin Administrative Code. Seventeen counties of the State of 

14 Wisconsin belong to the Lake Michigan Intrastate AQCR. Three counties among them, Door 

15 County, Manitowoc County and Sheboygan County, constitute subregion I and are located next 

16 to or in the close proximity to Kewaunee County and are currently designated by the EPA as 8-

17 hour ozone non-attainment areas (EPA, 2008). Kewaunee County is a maintenance county for 

18 8-hour ozone and is in attainment for all other criteria pollutants (EPA, 2009). 

19 WDNR implements the Air Management Program and coordinates the ambient air quality 

20 monitoring network in the State of Wisconsin. Kewaunee County is part of the Northeastern Air 

21 Region of the WDNR. The closest KPS WDNR ozone monitoring station within the Kewaunee 

22 County is located in the city of Kewaunee and has been in operation since 1994. In October 

23 2006, the EPA issued final amendments to the ambient air monitoring regulations for criteria 

24 pollutants (40 CFR Parts 53 and 58) containing the requirement to establish National Core 

25 (NCore) multi-pollutant higher-sensitivity monitoring stations throughout the country. The 

26 Mayville WDNR monitoring site, located approximately 78 miles (126 km) southwest of KPS, is 

27 proposed for this purpose. 

28 KPS stationary emission sources that do not require the facility to secure a Title V permit are: 

29 three standby emergency power supply diesel generators, one space heating boiler, and 

30 several insignificant emission units that are listed in the KPS Air Pollution Control Operation 

31 Permit. KPS is recognized as a Synthetic Minor facility, non-Part 70 by WDNR due to the 

32 quantities of emissions and restrictions on the hours of operation of its stationary sources of 

33 criteria pollutants (DEK, 2009d). The generators are tested periodically to ensure their continued 

34 ability to perform their intended function. There are procedures in place to ensure continuous 

35 monitoring, sampling, and filtering of the oil. 

36 KPS operates a meteorological system that consists of weather instruments mounted on a 

37 primary 197-foot (60-m) high tower and 33-foot (10-m) backup tower, which provides alternative 

38 measurements and serves as a secondary data source in the event of sensor failure on the 

39 primary tower. There are wind sensors mounted on the primary tower that allow for the 

40 calculation of horizontal wind direction standard deviation. The sensors are located at 10 and 

41 60 meters height. Vertical temperature differentials are measured with redundant sensor pairs 

42 between both levels. Ambient temperature sensors are located at the 10-meter level. 
Affected Environment 

Draft NUREG-1437, Supplement 40 2-18 February 2010 

1 Precipitation is measured at ground level. The backup tower measures ambient temperature, 

2 wind speed, direction, and standard deviation at the 33-foot (10-m) level in the event of primary 

3 tower failure. 

4 There is an established real time review and data quality assurance program for meteorological 

5 data. The quality control process involves routine daily inspection of the meteorological data and 

6 biweekly review, comparison and processing of the data by the meteorological staff of the 

7 Dominion Weather Center. The quality assured meteorological data is then incorporated into the 

8 Annual Radioactive Release Reports (DEK, 2009d). 

9 Sections 101(b)(1), 110, 169(a)(2) and 301(a) of the Clean Air Act as amended (42 USC 7410, 

10 7491(a)(2), 7601(a)) established Mandatory Class I Federal Areas where visibility is important. 

11 There are no Mandatory Class I Federal areas in the State of Wisconsin or in close proximity to 

12 KPS. The Mandatory Class I Federal Areas closest to KPS are Seney Wilderness Area, 

13 Michigan, located 149 miles northeast from KPS, and Isle Royale National Park, Michigan, 

14 located 255 miles northwest from KPS. Therefore, no adverse impacts on Class I areas are 

15 anticipated from the KPS operation. 

16 2.2.3 Ground Water Resources 

17 The soil profile at the KPS site consists of glacial drift made up primarily of silty clay, ranging 

18 from 60 to 150 feet (18 to 46 m) thick. Underlying the glacial material is a 350-foot (107-m) to 

19 600-foot (183-m) thick layer of sedimentary bedrock. The water table underneath the KPS site 

20 ranges from 10 to 30 feet (3 to 9 m) below land surface and slopes east toward Lake Michigan 

21 (STS, 2007). 

22 The three principal aquifers beneath the site are the Glacial Outwash Aquifer, the Niagara 

23 Dolomite Aquifer, and the Deep Sandstone Aquifer. An additional minor aquifer, the St. Peter 

24 Sandstone Aquifer, is of limited ground water use. About half of local wells are screened in the 

25 Glacial Outwash Aquifer, which is made up of sand and gravel layers, the largest of which is not 

26 continuous at the site (STS, 2007). Wells screened in this aquifer have a flow rate of 

approximately 17 gpm (1.1 x 10-3 m3 27 /s). The other half of local wells are screened in the 

28 Niagara Dolomite Aquifer, the uppermost bedrock aquifer along the Lake Michigan coastline. 

29 Wells screened in this aquifer typically have a depth between 30 and 60 feet (9 to 18 m) and 

have a flow rate of approximately 13 gpm (8.2 x 10-4 m3 30 /s). Wells pumped within this aquifer 

31 have been known to affect the water levels of nearby wells, and those near the shoreline of 

32 Lake Michigan may induce water flow from the lake into the aquifer (DEK, 2007b). The two 

33 groundwater wells used by KPS draw water from the Niagara Dolomite Aquifer at depths of 310 

34 feet (94 m) and 320 feet (98 m) (DEK, 1968). 

35 The third and deepest major aquifer, the Deep Sandstone Aquifer, is between 1,200 and 

36 1,700 feet (366 to 518 m) and includes the Dresbach, Franconia, and Trempealeu formations. 

37 This aquifer is separated from the Niagara Dolomite by 800 feet (244 m) of shale and dolomite 

38 strata. Water in the Deep Sandstone Aquifer is not potable because it is too saline (DEK, 

39 2007b). Figure 2.5 illustrates the primary aquifers beneath KPS. 
Affected Environment 

 

February 2010 2-19 Draft NUREG-1437, Supplement 40 

1 Figure 2-5. Primary aquifers beneath the Kewaunee Power Station Site 

2 

3 

4 

5 Glacial 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 Source: WDNR, 2009f 

22 2.2.3.1 Kewaunee Power Station Water Supply Wells 

23 KPS has two high capacity onsite wells screened in the Niagara Dolomite Aquifer (DEK, 1968). 

24 These wells are permitted for ground water withdrawal by WDNR. The first well (BE601) is 

25 310 feet (94 m) in depth and 10 inches (25.4 cm) in diameter. The second well (BE602) is 

26 320 feet (98 m) in depth and 10 inches (25.4 cm) in diameter (DEK, 2007a). 

Together, both wells yield an average total of 25 gpm (1.6 x 10-3 m3 27 /s) to 61 gpm 

(3.9 x 10-3 m3 28 /s). The highest recorded monthly average yield occurred in January 2008 at 

52.6 gpm (3.3 x 10-3 m3 29 /s). The KPS wells typically do not withdraw ground water during the 

30 summer months (See Table 2-1) (DEK, 2009a). 

Outwash Aquifer

Niagara Dolomite Aquifer

Deep Sandstone Aquifer
Affected Environment 

Draft NUREG-1437, Supplement 40 2-20 February 2010 

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

2 

Month Well Well Total Usage Average 

Usage 

Average 

Usage 

Average 

Usage 

1A 1B Per Day Per Hour Per Min 

Sep-07 2,109,465 284 2,109,749 72,750 3,031 50.5 

Oct-07 2,391,263 17,339 2,408,602 72,988 3,041 50.7 

Nov-07 2,139,279 0 2,139,279 71,309 2,971 49.5 

Dec-07 1,858,387 435 1,858,822 58,816 2,451 40.8 

Jan-08 2,247,797 0 2,247,797 72,558 3,023 50.4 

Feb-08 2,193,619 0 2,193,619 75,696 3,154 52.6 

Aug-08 0 0 0 0 0 0.0 

Sep-08 36,977 490,822 527,799 15,093 629 10.5 

Oct-08 29,988 0 29,988 968 40 0.7 

Nov-08 2 0 2 0 0 0.0 

Dec-08 72,999 60,415 133,414 3,814 159 2.6 

Jan-09 0 615 615 20 1 0.0 

Feb-09 11 0 11 0 0 0.0 

Mar-09 1,628,170 0 1,628,170 58,070 2,420 40.3 

Apr-09 624,874 1,135,966 1,760,840 58,776 2,449 40.8 

Source: DEK 2009a. 

3 2.2.3.2 Kewaunee Power Station Ground Water Monitoring 

4 KPS monitors groundwater for the possible infiltration of radionuclides such as tritium. As tritium 

5 decays, it emits a low-energy beta particle that cannot travel far into either tissue or air. Tritium 

6 is a product of manmade sources, as well as natural processes. 

7 The KPS Groundwater Monitoring Program includes 14 monitoring wells, including the two high 

8 capacity wells onsite (DEK, 2009b). The ground water monitoring wells were installed in 2007 

9 for use in tritium assessment at the plant site. This assessment concluded that the most likely 

10 potential tritium release to ground water is contained in the sand backfill beneath the site, and 

11 that the migration of this potential release would likely follow the water table east toward Lake 

12 Michigan (STS, 2007). 

13 2.2.4 Surface Water Resources 

14 In accordance with the Federal Water Pollution Control Act (or the Clean Water Act (CWA)), 

15 KPS effluent discharges are regulated by the Wisconsin Pollutant Discharge Elimination System 

16 (WPDES) Permit No. WI-00001571-06 issued and enforced by the WDNR. Section 402 of the 

17 CWA states that the NPDES (National Pollutant Discharge Elimination System) prohibits 

18 discharges of pollutants from any point source into the nation’s waters except as allowed under 

19 an NPDES permit. The purpose of this permit is to regulate wastewater discharge to preserve 

20 the water quality of the surrounding water bodies. As of the most recent permit issued, there 

21 have been no notices of violation for the KPS site. Information in this section is from the most 

22 recent KPS WPDES permit, a copy of which is included in the applicant’s license renewal 
Affected Environment 

 

February 2010 2-21 Draft NUREG-1437, Supplement 40 

1 environmental report. The most recent renewal of this permit became effective August 1, 2005, 

2 and expires June 30, 2010. 

3 Table 2-2 shows the quantitative effluent limitations regulated under the WPDES permit, or the 

4 residual concentrations of permitted chemical additives that may be discharged to Lake 

5 Michigan. In accordance with this permit, any new chemical additives introduced, or current 

6 dosages increased, must first be reviewed and approved by the WDNR. 

Table 2-2. Wisconsin Pollutant Discharge Elimination System Effluent 

Limitations for Kewaunee Power Station 

Sample Total Suspended Solids 

(mg/L) 

Total Residual 

Chlorine 

(lbs/day) 

Oil and Grease 

(Hexane or Freon) (mg/L) 

Discharge Flow

(MGD) 

Point No. Monthly Daily Weekly Daily Monthly Daily 

Average Max. Max. Max. Average Max. 

Outfall 001 30 100 NLR 180 10 15 494* 

 

Outfall 002 NLR NLR NLR NLR NLR NLR 3.96 

Outfall 003 30 NLR 45 NLR NLR NLR 0.01 

SP101 30 100 NLR NLR 15 20 0.01 

SP201 30 100 NLR NLR 15 20 0.06 

SP301 30 100 NLR NLR 15 20 0.03 

SP501 30 100 NLR NLR 15 20 0.14 

NLR: No Limit Required 

*580 MGD (summer); 380 MGD (winter) 

7 The permit outlines the effluent limitations and monitoring requirements of the three different 

8 discharge outfalls, as well as five additional sampling points. In addition to the effluent 

9 limitations shown in Table 2-2, the permit describes the minimum number of sampling events 

10 required for each outfall. Flow monitoring requirements are outlined for certain outfalls, as well 

11 as required pH monitoring, with pH levels expected to be between 6.0 and 9.0 year-round. 

12 Outfall 001 discharges condenser cooling water and process wastewater and is sampled prior to 

13 discharge to Lake Michigan. Daily temperature averages at this outfall are recorded. Outfall 002 

14 monitors recirculated water from Outfall 001 to prevent icing of the intake. Only flow rate is 

15 monitored at this outfall. Outfall 003 samples the sewage treatment plant effluent prior to its 

16 discharge to an unnamed tributary to Lake Michigan. Both Outfall 001 and 003 are required to 

17 undergo both acute and chronic Whole Effluent Toxicity (WET) testing two to three times per 
Affected Environment 

Draft NUREG-1437, Supplement 40 2-22 February 2010 

1 quarter. The permittee (DEK) is required to investigate any occurrences of serious or repeated 

2 toxicity found during these WET tests. 

3 Five additional sampling points are regulated by the WPDES permit. SP101 samples the steam 

4 generator blowdown to Outfall 001. SP201 samples the floor drains to Outfall 101. SP301 

5 samples the service water treatment lagoon overflow to Outfall 101. SP501 samples the reverse 

6 osmosis discharge wastewater to Outfall 101. SP601 monitors the flow of Lake Michigan water 

7 or water pumped from the turbine building basement in case of circulating water system failure 

8 near the Outfall 101 discharge structure. 

9 KPS implements a Storm Water Pollution Prevention Plan onsite to reduce the amount of 

10 pollution discharged through storm water runoff. The purpose of this plan is to eliminate any 

11 contact discharged storm water may have with potentially contaminating materials. There are 

12 seven designated storm water outfalls onsite. Discharge monitoring of these outfalls is regulated 

13 by a “Tier 2” WPDES permit (Permit No. WI-S067857-2) (DEK, 2009f). 

14 Sanitary wastewater is treated at the site’s sewage treatment plant, which was installed in 1986. 

15 Typical plant operations require the plant to treat approximately 11,000 gpd (7.6 gpm; 4.8 x 10-4 

m3

/s); however, the plant is capable of treating up to 20,000 gallons (75.7 m3 16 ) of sewage per 

day. The system discharges approximately 7.6 gpm (4.8 x 10-4 m3 17 /s). Solids are disposed of at 

18 an offsite facility after onsite treatment (DEK 2008). 

19 2.2.5 Aquatic Resources 

20 KPS is located on the west-central shore of Lake Michigan. Lake Michigan constitutes a total 

area of 67,900 mi2

 (175,800 km2) and a total volume of 1,180 mi3 (4,920 km3 21 ) and is the third 

22 largest of the Great Lakes by area and second largest by volume (EPA, 1992). The lake’s 

23 average depth is 279 feet (85 m) and maximum depth is 925 feet (282 m) (GLC, 2000). The 

24 lake surface lies at an average of 577 feet (176 m) above mean sea level (AEC 1972). The Lake 

Michigan drainage basin encompasses over 45,000 mi2

 (72,400 km2 25 ) and major tributaries 

26 include the Fox-Wolf, Grand, and Kalamazoo rivers (DEK, 2008; GLC, 2000). Lake Michigan 

27 flows through the Straits of Mackinac into Lake Huron at a recharge rate of once every 100 

28 years (GLC, 2000). Lake Michigan has a low salinity level of less than 0.1 parts per thousand 

29 (ppt) (DEK, 2008). 

30 Lake Michigan is used for a variety of purposes, including commercial and recreational boating, 

31 sport and commercial fishing, and tourism. The major changes and modifications that have had 

32 the greatest effect on aquatic resources of Lake Michigan include lakefront industrial, urban, 

33 and residential development; water quality impairment from industrial, municipal, agricultural, 

34 navigational, recreational water uses, overfishing, and invasion of exotic species (EPA, 2008e). 

35 The Lake Michigan ecosystem continues to experience profound changes because of 

36 development, impacts of invasive species, and pollution. In the 2008 Lakewide Management 

37 Plan (EPA, 2008d), Lake Michigan’s status was described as mixed with a slight, but continuing 

38 decline in water quality. 

39 There have been a series of milestones in the management of the Great Lakes. In 1955, the 

40 Canadian/U.S. Convention on Great Lakes Fisheries created the Great Lakes Fishery 

41 Commission (GLFC), which coordinates fisheries research and facilitates cooperative fishery 
Affected Environment 

 

February 2010 2-23 Draft NUREG-1437, Supplement 40 

1 management among the State, provincial, tribal, and Federal agencies. The GLFC is 

2 responsible for implementing the Joint Strategic Plan for Management of Great Lakes Fisheries 

3 (GLFC, 1997). Eight States bordering the Great Lakes, the Province of Ontario, two intertribal 

4 agencies, and several Federal agencies are signatory to this management plan and work 

5 together to rehabilitate native lake species, control exotic species, prevent and manage fishery 

6 disease, coordinate law enforcement, produce new research, publish state-of-the-lake reports, 

7 and determine total allowable catch and allocation agreements and fish stocking levels (GLFC, 

8 2009). 

9 In 1972, the first Great Lakes Water Quality Agreement (GLWQA) was signed between the 

10 International Joint Commission (IJC) of Canada and the United States. Both countries pledged 

11 to address the deterioration of Great Lakes water quality from point source and non-point 

12 source pollution. A new GLWQA was signed in 1978 that outlined additional commitments to 

13 restore and maintain the “chemical, physical, and biological integrity” of the Great Lakes by 

14 seeking to eliminate persistent toxic substances (IJC 2006). In 1987, the GLWQA established 

15 processes and basic commitments for developing and implementing remedial action programs 

16 (RAPs) in geographic areas of concern (AOCs) and within the context of existing Lakewide 

17 Management Plans (LaMPs) (EPA and Environment Canada, 1997). 

18 Forty-two AOCs have been identified across the Great Lakes basin, ten of which are in the Lake 

19 Michigan basin (EPA, 2008d). The closest AOC in relation to KPS is the Lower Green Bay and 

20 Fox-Wolf River AOC, which suffers from eutrophication, degradation of phytoplankton and 

21 zooplankton populations, and has consumption advisories for mallard ducks and 12 species of 

22 fish (EPA, 2008e). Water contaminants of concern in this area include phosphorus, suspended 

23 solids, PCBs, ammonia, and various pesticides. Sediment contaminants include PCBs, 

24 cadmium, mercury, lead, and pesticides (EPA, 2008d). The Great Lakes Binational Toxics 

25 Strategy was created in 1997 for the purpose of reducing the environmental threats posed by 

26 persistent toxic substances such as those mentioned above (EPA and Environment Canada, 

27 1997). By 2006, as a result of this effort, deliberate mercury use and mercury releases were 

28 reduced by 50 percent in the United States, dioxin/furan releases were reduced by 75 percent in 

29 the United States, and less PCB-containing equipment use was documented (EPA and 

30 Environment Canada, 2007). 

31 The EPA conducted a study from 1994 to 2000, called the Lake Michigan Mass Balance Study 

32 (LMMB), which focused on the pathways of four major chemicals: PCBs, representative of 

33 conservative organic compounds; atrazine, a widely-used herbicide representative of reactive, 

34 biodegradable compounds; trans-nonachlor, a component of the pesticide chlordane, 

35 representative of persistent, bioaccumulative compounds; and mercury, also a persistent, 

36 bioaccumulative compound in the atmosphere, tributaries, lake water, sediments, and food 

37 webs of Lake Michigan and its basin. The Great Lakes Binational Toxics Strategy was 

38 implemented within the last three years of the LMMB study. Because the Great Lakes Binational 

39 Toxics Strategy has reported successes at reducing levels of toxins in all categories the 

40 Strategy addresses, actual levels of toxins may now be further reduced than the LMMB 

41 indicates. Therefore, only general trends for toxin levels identified in the LMMB are discussed. 
Affected Environment 

Draft NUREG-1437, Supplement 40 2-24 February 2010 

1 PCBs are organochlorines that were once widely used for industrial purposes until the EPA 

2 banned them from use in 1979 in all but completely enclosed systems due to their 

3 environmental and health effects. PCBs have been linked to reproductive problems and 

4 deformities in fish and wildlife. Trans-nonachlor is a component of the pesticide chlordane that 

5 can rapidly bioaccumulate. During the LMMB, PCB and trans-nonachlor trends indicated that 

6 levels are declining overall. Levels of dissolved and particulate PCBs in the atmosphere, Lake 

7 Michigan tributaries, the Lake Michigan Water column, and sediments were generally highest in 

8 the southern portion of the Lake Michigan basin and near urbanized and industrialized areas 

9 (McCarty et al., 2004). However, trans-nonachlor concentrations were higher in rural, 

10 agricultural areas with decreasing concentrations northward (McCarty et al., 2004). This trend 

11 may be a result of historical application, since this chemical is no longer produced in the United 

12 States (McCarty et al., 2004). The WDNR advises against eating lake trout (larger than 27 

13 inches (69 cm)) within Lake Michigan due to the risk of high PCB levels (WDNR, 2009). The 

14 WDNR also advises against eating brown trout (larger than 25 inches (64 cm)), Chinook salmon 

15 (larger than 36 inches (91 cm)), and lake trout (23 to 27 inches (58 to 69 cm)) more than once 

16 every two months due to the potential for elevated PCB levels (WDNR, 2009). 

17 Atrazine is one of the most widely-used herbicides in the United States and is most commonly 

18 applied to corn crops in spring months within the Lake Michigan basin. The chemical does not 

19 bioaccumulate, but persists in the water column due to its slow decay rate. Atrazine 

20 concentrations were found to be highly seasonal, corresponding to agricultural application 

21 during the spring months, and regionally, were elevated in areas of high agricultural production. 

22 Tributaries were found to be the most prevalent source of atrazine, though levels in the Lake 

23 Michigan water column were generally persistent with a slow decay rate of one percent per 

24 year. Results suggested that lake-wide levels of atrazine in Lake Michigan may be increasing 

25 under present loads (Brent et al., 2001). 

26 Mercury is a persistent metal that can bioaccumulate and cause reproductive and growth effects 

27 in fish and wildlife. Vapor, particulate, and precipitate were all major contributors of mercury to 

28 Lake Michigan, with seasonal patterns—the highest concentrations were observed in summer 

29 months—and regional patterns, with Chicago having significantly higher concentration of 

30 mercury in both particulate and vapor phases. Mercury levels in Lake Michigan tributaries were 

31 comparable to previously recorded levels in other Midwestern rivers and well below the 

32 nationwide criteria for water quality. Levels were highest in the Fox River, which had 

33 concentrations averaging up to 2.7 times higher than other tributaries (McCarty et al., 2004a). 

34 Water column levels of mercury in Lake Michigan were lower than measured levels in tributaries 

35 and generally well mixed within the water column (McCarty et al., 2004a). Mercury levels in trout 

36 and coho salmon were found to exceed the EPA guidelines for unrestricted consumption and at 

37 levels that warrant consumption advisories for these species (McCarty et al., 2004a). As of 

38 2009, no consumption advisories exist for fish in Lake Michigan bordering Kewaunee or its 

39 neighboring counties (WDNR, 2009). 

40 In the near vicinity of KPS, Lake Michigan is shallow with depths of 15 to 20 feet (4.6 to 6.1 m) 

41 1,600 feet (488 m) offshore of the intake structure (DEK, 2008). Near shore substrate consists 

42 mainly of cobble and gravel, and bottom sediment consists mainly of hard red clay and fine to 

43 medium sand (AEC, 1972; EA Engineering, 2007). The depth reaches over 600 feet (82 m) in 

44 the central part of the lake, referred to as the Chippewa Basin (EA Engineering, 2007). 
Affected Environment 

 

February 2010 2-25 Draft NUREG-1437, Supplement 40 

1 The native fish community consists of deepwater species including the bloater (Coregonus 

2 hoyi), lake herring (Coregonus artedii), and lake whitefish (Coregonus clupeaformis), predators, 

3 including lake trout (Salvelinus namaycush) and walleye (Stizostedion vitreum), and 

4 intermediate predators, such as white bass (Morone chrysops) and yellow perch (Perca 

5 flavescens). Demersal species such as white sucker (Catostomus commersoni) and freshwater 

6 drum (Aplodinotus grunniens), small forage species such as the emerald shiner (Notropis 

7 atherinoides), and sunfish family species such as pumpkinseed (Lepomis gibbosus) and 

8 smallmouth bass (Micropterus dolomieui) are also characteristic of the native fish community 

9 near KPS (EA, Engineering 2007; UWSGI, 2002b). 

10 Preoperational monitoring indicated that the fish population in Lake Michigan near the KPS site 

11 was primarily composed of alewife (Alosa pseudoharengus), lake trout (Salvelinus namaycush), 

12 and rainbow smelt (Osmerus mordax) (AEC, 1972). Lake chub, yellow perch, white suckers, 

13 longnose dace, and slimy sculpin were also captured during 1971 fish collections (AEC, 1972). 

14 The most prevalent sport fish in the area was lake trout, most of which had been recently 

15 stocked in Wisconsin waters by Federal or State agencies (AEC, 1972). 

16 Catch data for the period of 1971 through 1975 for the KPS Clean Water Act Section 316(a) 

17 Demonstration (NES, 1976a) included both preoperational and operational data. Alewife was 

18 the most prevalent species, constituting 65 percent of total catch. Other recorded species 

19 included rainbow smelt, yellow perch, lake trout, lake chub, white sucker, longnose dace, and 

20 longnose sucker. Sport fishing species included lake trout, rainbow trout, brown trout, brook 

21 trout, coho salmon, and Chinook salmon, the abundance of which was attributed to the activity 

22 of stocking in the KPS area. The 316(a) Demonstration did not identify any significant increases 

23 or decreases in fish densities. (NES, 1976a) 

24 The Lake Michigan biological community has changed numerous times since the mid25 nineteenth century as a result of introduced fish and invertebrate species. Major introductions 

26 include the common carp (Cyprinus carpio) and brown trout (Salmo trutta) in the 1890s (EA 

27 Engineering, 2007), the rainbow smelt in the early 1900s (Crowder, 1980; UWSGI, 2002c), the 

28 sea lamprey (Petromyzon marinus) in the late 1930s (USGS, 2008), the alewife in the 1950s 

29 (EA Engineering, 2007; Crowder, 1980), and the round goby in the 1990s (EA Engineering, 

30 2007). Two dreissenid mussels, the zebra mussel (Dreissena polymorpha) and the quagga 

31 mussel (Dreissena bugensis), have also invaded Lake Michigan beginning in the 1990s (Brandt, 

32 2004; EA Engineering, 2007). 

33 Common carp were brought to North America as a farmed food source in the late 1800s, and 

34 spread to the Great Lakes beginning in 1983 (UWSGI, 2002a). Carp are particularly abundant 

35 near the southeastern shore of Lake Michigan and lower Green Bay and can reproduce quickly 

36 and outcompete native fish species due to their large size and voracious appetite (EPA, 2008c; 

37 UWSGI, 2002a). Brown trout were introduced to North America in 1883 and to Wisconsin, 

38 specifically, in 1887 (UWSGI, 2002). Brown trout have not negatively affected native species 

39 because brown trout adapt readily to degraded habitats and are regularly harvested as game 

40 fish (UWSGI, 2002). 
Affected Environment 

Draft NUREG-1437, Supplement 40 2-26 February 2010 

1 The sea lamprey entered the Great Lakes via ship canals and locks from the Atlantic Ocean in 

2 the 1930s (USGS, 2008). Sea lamprey is a primitive fish that feeds parasitically on the blood of 

3 host fish during part of its life cycle (USGS, 2008). Within Lake Michigan, common host fish 

4 include lake trout, whitefish, and other top predator species (EA Engineering, 2007). Prey 

5 species in the Great Lakes are smaller than natural prey species in the Atlantic Ocean, which 

6 makes Great Lakes prey species more likely to be killed from a sea lamprey attack or die of 

7 secondary infection from wounds (DEK, 2008; USGS, 2008). Approximately 40 to 60 percent of 

8 lake trout attacked by sea lamprey die from loss of blood (USGS, 2008). A combination of 

9 overfishing and sea lamprey predation are attributed to the lake trout’s (Salvelinus namaycush) 

10 extirpation from lakes Michigan, Ontario, Eerie, and Huron (USGS, 2008). Sea lamprey 

11 predation, in combination with overfishing and other factors, has led to the extinction of the 

12 longjaw cisco (Coregonus alpenae), the deepwater cisco (C. johannae), and the blackfin cisco 

13 (C. nigripinnis) (Fuller et al., 2007). Sea lamprey is also responsible for the whitefish and chub 

14 population collapses during the 1940s and 1950s (USGS, 2008). 

15 As a result of sea lamprey introductions, many top predator species’ populations were reduced, 

16 which allowed populations of their prey, rainbow smelt and alewife, to flourish. Rainbow smelt 

17 were initially released into Crystal River, Michigan, in 1912 as food for stocked salmon and soon 

18 after spread to the Great Lakes (Crowder, 1980; UWSGI, 2002c). The alewife was first 

19 observed in Lake Michigan in 1949 and was able to outcompete and prey on the young of 

20 dwindling populations of several native fish species (Crowder, 1980). During the period of time 

21 rainbow smelt and alewife were introduced to Lake Michigan, the numbers of numerous native 

22 species declined and some became extremely rare. These species include emerald shiner 

23 (Notropis atherinoides), lake herring (Coregonus artedi), kiyi (C. kiyi), and five other species of 

24 cisco (Coregonus spp.) (Crowder, 1980). Numerous hypotheses may explain native fish 

25 population declines, but the effects of invasive species are the most commonly put forth. 

26 Alewives may contribute to a decline in native fish populations because alewives are able to 

27 outcompete native species for planktonic and other smaller organisms, and alewives may also 

28 prey on the eggs and larvae of native fish species (Crowder, 1980; EA Engineering, 2007). 

29 Rainbow smelt are thought to prey on eggs and larvae of native fish, including lake trout, 

30 whitefish, walleye, and cisco and have a negative impact on the native fish population (Crowder, 

31 1980; WDNR, 2004). Native fish that consume smelt may have a decreased ability to 

32 successfully reproduce because smelt are rich in thiaminase, an enzyme that destroys thiamin, 

33 which is necessary for embryo development (WDNR, 2004). Rainbow smelt are harvested 

34 commercially and recreationally in Wisconsin, which serves as a controlling force on the 

35 population. In 2004, 155,000 pounds (70,300 kg) of smelt were harvested by commercial 

36 trawlers in Lake Michigan and Green Bay alone (WDNR, 2004). 

37 Annual die-offs of alewives became common in the 1950s and 1960s due to overcrowding 

38 (Crawford, 2001). Alewives prey on zooplankton, which decreases the population of 

39 zooplankton available to graze on phytoplankton, thereby decreasing the clarity of water 

40 (Crawford, 2001). Evidence also suggests that selective predation on zooplankton caused a 

41 shift in the size structure of zooplankton in Lake Michigan. Larger cladocerans (including 

42 Leptodora kindtii, Daphnia galeata, and D. retrocurva), three species of larger calanoid 

43 copepods, and the cyclopoid copepod Mesocyclops edax sharply declined between the 

44 introduction of the alewife and 1966, while medium and small-sized zooplankton species 

45 increased in numbers (Wells 1970). Some populations, such as D. retrocurva, experienced a 
Affected Environment 

 

February 2010 2-27 Draft NUREG-1437, Supplement 40 

1 decrease in average size and size at onset of maturity (Wells, 1970). In 1965, WDNR initiated a 

2 stocking program that included pacific salmon and other salmonids to control alewife 

3 populations (EA Engineering, 2007). By the mid-to-late 1980s, alewife numbers were visibly 

4 reduced as a result of salmon stocking (Crawford, 2001). Stocking of salmonids continues, in 

5 reduced numbers, which has created a better balance between alewife and salmonid predator 

6 populations and provides for sport fishing (EA Engineering, 2007). Currently, the only objective 

7 for salmonid stocking is to maintain the recreational fishery base as stream temperatures are 

8 too high for natural spawning along the Wisconsin shoreline of Lake Michigan (Crawford, 2001). 

9 Two dreissenid mussels, the zebra mussel and the quagga mussel, established populations in 

10 Lake Michigan in the 1990s as a result of ship ballast-water discharges (EA Engineering. 2007). 

11 Zebra mussels displace native clams and unionid mussels by interfering with their feeding, 

12 growth, and reproduction when they attach themselves to live clams and mussels (DEK. 2007a). 

13 The reduction of available phytoplankton mass as a result of these mussel species is attributed 

14 to the decline of Diporeia spp., which were dominant amphipods, by 90 percent between 1993 

15 and 2002, though the exact mechanism is uncertain (Brandt. 2004). Community alterations by 

16 the dreissenid mussels are also thought to contribute to the population decline and poorer 

17 observed body condition of whitefish species and yellow perch because of the decline of 

18 Diporeia as their food source (Platt, 2009). Though the cause-and-effect relationship between 

19 the quagga mussel increase and the loss of Diporeia is not completely understood, the Great 

20 Lakes Coalition and the Natural Resources Defense Council, among others, are pushing for 

21 stronger regulations regarding ship ballast water to limit additional spread of the mussel species 

22 (Platt, 2009). 

23 The Lake Michigan phytoplankton and zooplankton communities are highly variable and may be 

24 experiencing changes due to contaminant and nutrient levels, sedimentation, and invasive 

25 species (EPA, 2008d). Phytoplankton abundance and production in nearshore waters of Lake 

26 Michigan have been decreasing since 1970 and has been suggested to be caused by a 

27 reduction in phosphorus loadings (Madenjian et al., 2002). Makarewicz et al. (1994) examined 

28 trends in phytoplankton abundance in Lake Michigan from 1983 to 1992 and related them to 

29 “top-down mediated changes” observed in the fish and zooplankton communities. 

30 Bacillariophyta (diatoms) dominated spring samples in all but one year and accounted for 69 to 

31 95 percent of total algal biomass. Summer phytoplankton samples were dominated by diatoms, 

32 Chlorophyta (green algae), Chrysophyta (yellow-green or yellow-brown algae), and Pyrrhophyta 

33 (dinoflagellates). The presence of large-bodied zooplankton (e.g., Daphnia spp.) resulted in 

34 increasing abundance of colonial and filamentous algae; low numbers of Daphnia spp. were 

35 associated with an increasing abundance of small, unicellular phytoplankton. Makarewicz et al. 

36 (1994) also noted that large zooplankton became more abundant from 1983 through 1985 after 

37 a sharp decline in the abundance of alewife in 1982 and 1983. 

38 The introduction of the non-native spiny water flea (Bythotrephes cederstroemi), a cladoceran, 

39 caused a significant decline in three native species of Daphnia (Lehman 1991). Another non40 native cladoceran, the fishhook water flea (Cercopagis pengoi), has also invaded the Great 

41 Lakes (WDNR, 2004a). These species compete with planktivorous larval fish for food and have 

42 been implicated as a factor in the decline of alewives in Lake Erie, Lake Huron, Lake Michigan, 

43 and Lake Ontario (Liebig and Benson, 2007). 
Affected Environment 

Draft NUREG-1437, Supplement 40 2-28 February 2010 

1 2.2.6 Terrestrial Resources 

2 The KPS site and its associated transmission lines are located within the Lake Michigan 

3 watershed and drainage basin. The KPS site is located in the town of Carlton, Kewaunee 

4 County, Wisconsin, and is approximately 37 miles (59.5 km) southeast of Green Bay, 

5 Wisconsin. The KPS site is 908 acres (367 ha), of which 450 acres (182 ha) are leased for 

6 farmland (DEK, 2008). These farmlands would be allowed to return to forested or wetland areas 

7 if the leases ran out or were terminated. The KPS reactor buildings, other building facilities, 

8 parking lots, and switchyard cover 60 acres (24 ha) of the overall site (DEK, 2008). The 

9 remaining 398 acres (161 ha) is mixed use and is comprised of forested plots, fields, wetlands, 

10 and water courses (DEK, 2008). Site land use consists of about 53 percent agriculture, 16 

11 percent open fields/early successional, 18 percent forest communities, 1 percent shoreline, 7 

12 percent plant site facilities, and 3 percent mowed fields (DEK, 2009c). Figure 2.1-3 shows the 

13 KPS site boundary. Some open fields may be due to ROW maintenance, which keeps the 

14 forested areas in stages of early succession. 

15 Upland areas at the KPS site support a variety of trees including quaking aspen (Populus 

16 tremuloides), northern white cedar (Thuja occidentalis), eastern cottonwood (Populus deltoides), 

17 black willow (Salix nigra), green ash (Fraxinus pennsylvanica), American beech (Fagus 

18 grandifolia), and paper birch (Betula papyrifera) (DEK, 2008). Low-story trees and shrubs 

19 include red osier dogwood (Cornus stolonifera), hazelnuts (Corylus spp.), blueberry (Vaccinium 

20 spp.), and brambles (Rubus spp.) (WDNR, 2009c). Open field and grassland species include 

21 Bird’s-foot violet (Viola pedata), rosinweed (Silphium integrifolium), rattlesnake master 

22 (Eryngium yuccifolium), and blazing star (Liatris pycnostachya) (WDNR, 2009d). The farmland 

23 that DEK leases out produces common Wisconsin crops including soybeans. 

24 The Lake Michigan shoreline on the KPS site is comprised mostly of narrow (0- to 100-foot-wide 

25 (0- to 30.5-m-wide)) beaches with sparse vegetation. The beaches are bordered by bluffs or 

26 cliffs, which have been created over years of erosion induced by the fluctuating lake levels. In 

27 the late 1980s, DEK placed riprap along the edges of the bluffs of the southern end of the site 

28 shoreline to combat cliff erosion. The beach is at its narrowest at the south of KPS. North of the 

29 plant, the beaches are slightly wider, ranging from 20 to 80 feet (6 to 24 m) and also contain the 

30 most vegetation comprised of low-lying growth, shrubs, and trees. The beaches are the widest 

31 (more than 80 feet (24 m)) where the slope to the lake is more gradual (DEK, 2008). 

32 The U.S. Fish and Wildlife Service (USFWS) National Wetlands Inventory database shows 

33 wetlands, some of which are classified as significant habitats, on the KPS site, as well as the 

34 neighboring shorelines of Lake Michigan surrounding the site (USFWS, 2009). Two wetland 

35 areas have been delineated by DEK. The first is an area referred to by DEK staff as the 

36 “Independent Spent Fuel Storage Installation wetland”, which was delineated in 2005–2006 for 

37 purposes of pad construction and expansion. The second delineated wetland surrounds the 

38 KPS switchyard on three sides. Typical wetland species for the KPS site and surrounding area 

39 include tussock sedge (Carex stricta), northern white cedar (Thuja occidentalis), and wild rice 

40 (Zizania aquatica) (WDNR, 2009e). 

41 Invasive plant species common to the KPS site and surrounding areas may include Amur 

42 honeysuckle (Lonicera maackii), European alder (Alnus glutinosa), bull thistle (Cirsium vulgare), 

43 butter and eggs (Linarea vulgaris), Canada bluegrass (Poa compressa), Canada thistle (Cirsium 
Affected Environment 

 

February 2010 2-29 Draft NUREG-1437, Supplement 40 

1 arvense), common buckthorn (Rhamnus cathartica), crown vetch (Coronilla varia), cottonwood 

2 (Populus deltoides), Kentucky bluegrass (Poa pratensis), kudzu (Pueraria lobata syn Pueraria 

3 montana var lobata), multiflora rose (Rosa multiflora), tree-of-heaven (Ailanthus altissima), big 

4 tooth (or large tooth) aspen (Populus grandidentata), quaking aspen (Populus tremuloides), 

5 black locust (Robinia pseudoacacia), willows (Salix spp.), white sweet clover (Melilotus alba), 

6 Queen Anne’s lace (Daucus carota), and box elder (Acer negundo) (WDNR, 2009b). Invasive 

7 animal species common to the KPS site and surrounding area may include Asian longhorned 

8 beetle (Anoplophora glabripennis), emerald ash borer (Agrilus planipennis), mute swan (Cygnus 

9 olor), European gypsy moth (Lymantria dispar), and eastern tent caterpillar (Malacosoma 

10 americanum) (WDNR, 2009a). DEK does not manage any invasive species on the KPS site, 

11 and has not managed invasive species in the past. DEK is not required to keep records of 

12 known invasive species and does not have programs or procedures in place to control terrestrial 

13 plant or animal invasive populations on the KPS site. 

14 A variety of wildlife exists on and in the vicinity of the KPS site. Mammals common to the KPS 

15 site include white-tailed deer (Odocileus virginianus), eastern cottontail (Sylvilagus floridanus), 

16 raccoon (Procyon lotor), coyote (Canis latrans), fox squirrel (Sciurus niger), eastern chipmunk 

17 (Tamias striatus), and short-tailed shrew (Blarina brevicauda) (DEK, 2008). Reptiles and 

18 amphibians common to the KPS site include spring peepers (Pseudacris crucifer), green frogs 

19 (Rana clamitans), wood frogs (Rana sylvatica), American toads (Bufo americanus), chorus frogs 

20 (Pseudacris triserata) as well as numerous species of snakes, turtles, lizards, and salamanders 

21 (DEK, 2008). Additionally, several common amphibian species, including spring peepers 

22 (Pseudacris crucifer), green frogs (Rana clamitans), wood frogs (Rana sylvatica), American 

23 toads (Bufo americanus), and chorus frogs (Pseudacris triserata) were recorded during a recent 

24 KPS terrestrial survey (DEK, 2008a). 

25 The KPS site provides habitat to a variety of songbirds, upland game birds, waterfowl, and 

26 raptors. Birds common to the KPS site include red-winged blackbird (Agelaius phoeniceus), 

27 European starling (Sturnus vulgaris), American goldfinch (Carduelis tristis), clay-colored 

28 sparrow (Spizella pallida), American robin (Turdus migratorius), ring-billed gull (Larus 

29 delawarensis), Canada goose (Branta canadensis), and mallards (Anas platyrhynchos) (DEK, 

30 2008). Bank swallows (Riparia riparia) nest in the cliffs along the Lake Michigan shore (DEK, 

31 2008). A registered peregrine falcon (Falco peregrinus) breeding pair has nested on the KPS 

32 reactor building since 2001. An osprey (Pandion haliaetus) was seen flying over the KPS site in 

33 2006; however, there have been no recorded sightings since. 

34 DEK has several procedures for protecting the environment, including vegetation and wildlife, 

35 from impacts that could result from activities at KPS. Generally, procedures require KPS activity 

36 planners to complete an environmental review checklist to determine if a proposed activity 

37 requires further evaluation for environmental impacts and risk. If the environmental review 

38 checklist reveals that a planned activity could disturb vegetation or wildlife habitat, then an 

39 environmental evaluation must also be completed, and a qualified subject matter expert must 

40 evaluate the potential for adverse impacts on endangered or threatened wildlife and plant 

41 species or critical habitat. If the evaluation concludes that the proposed activity would result in 

42 an environmental impact, then the activity may not proceed until the impact has been resolved 

43 through avoidance, mitigation, or a compliance plan, when allowed by regulation. 
Affected Environment 

Draft NUREG-1437, Supplement 40 2-30 February 2010 

1 DEK actively manages the Joe Krofta Memorial Forest, named for a previous landowner. The 

2 forest is a 15-acre (6-ha) site with various planted trees and is located within the southern half of 

3 the KPS site. It was previously used as an outdoor classroom by local schools, but since 

4 September 11, 2001, access to this site has been restricted for security reasons (DEK, 2008). 

5 2.2.7 Threatened and Endangered Species 

6 2.2.7.1 Aquatic Threatened and Endangered Species 

7 Table 2-3 lists threatened, endangered, or candidate species known to occur in Kewaunee 

8 County, in which KPS is located, or Brown, Manitowoc, or Outagamie Counties, where 

9 transmission line ROWs associated with KPS traverse. 

10 No Federally-listed aquatic species are known to occur on or in the vicinity of KPS or its 

11 associated transmission line ROWs. Three fish species and six mussel species are State-listed 

12 as threatened or endangered and have the potential to occur in the vicinity of KPS. None of 

13 these species were identified during the February 2006 to February 2007 impingement and 

14 entrainment study conducted by EA Engineering, Science, and Technology, Inc. (EA 

15 Engineering, 2007). 
Affected Environment 

 

February 2010 2-31 Draft NUREG-1437, Supplement 40 

1 Table 2-3. Listed Aquatic Species. The species below are Federally-listed or Wisconsin-listed 

2 as threatened, endangered, or candidate species. These species may occur on the KPS site, 

3 within Lake Michigan, or within the transmission line ROWs. 

Scientific Name Common Name Federal 

Status(a) 

State 

Status(a) 

County of Occurrence(b) 

Fish

Acipenser fulvescens lake sturgeon - SSC Brown, Outagamie 

Anguilla rostrata American eel - SSC Brown 

Clinostomus elongates redside dace - SSC Brown, Manitowoc 

Erimyzon sucetta lake chubsucker - SSC Manitowoc 

Etheostoma clarum western sand 

darter - SSC Outagamie 

Fundulus diaphanous banded killifish - SSC Kewaunee, Manitowoc 

Lepomis megalotis longear sunfish - T Brown 

Moxostoma valenciennesi greater redhorse - T Brown, Kewaunee, 

Manitowoc 

Notropis anogenus pugnose shiner - T 

Notropis texanus weed shiner - SSC Outagamie 

Opsopoeodus emiliae pugnose 

minnow - SSC Outagamie 

Mussels

Tritogonia verrucosa buckhorn - T Outagamie 

Alasmidonta marginata elktoe - SSC Manitowoc; Outagamie 

Alasmidonta viridis slippershell 

mussel - T Manitowoc 

Epioblasma triquetra snuffbox - E Outagamie 

Pleurobema sintoxia round pigtoe - SSC Outagamie 

Quadrula metanevra monkeyface - T Manitowoc 

Simpsonaias ambigua salamander 

mussel - T Outagamie 

Venustaconcha 

ellipsiformis ellipse - T Manitowoc 

(a)C = Candidate; E = Federally endangered; SSC = species of special concern; T = Federally threatened; - = No 

listing 

(b)Species has recorded occurrence in the listed counties within the past 50 years according to the WDNR 
Affected Environment 

Draft NUREG-1437, Supplement 40 2-32 February 2010 

Scientific Name Common Name Federal 

Status(a) 

State 

Status(a) 

County of Occurrence(b) 

Sources: DEK 2008; FWS 2008; WDNR 2004a; WDNR 2008; WDNR 2008a; WDNR 2008b; WDNR 2008c; WNHP 

2006 

1 2.2.7.2 Terrestrial Threatened and Endangered Species 

2 There are five Federally-listed threatened or endangered terrestrial species that have potential 

3 habitat on the KPS site: the piping plover (Charadrius melodus), the Hine’s emerald dragonfly 

4 (Somatochlora hineana), the Karner blue butterfly (Lycaeides melissa samuelis), the dune or 

5 Pitcher’s thistle (Cirsium pitcheri), and the dwarf lake iris (Iris lacustris). The bald eagle 

6 (Haliaeetus leucocephalus) and the peregrine falcon (Falco peregrinus) were formerly listed as 

7 Federally threatened and may also be found in the vicinity of the KPS site. A peregrine falcon 

8 (Falco peregrinus) breeding pair, mentioned in Section 2.2.6 of this draft SEIS, has nested on 

9 the KPS reactor building since 2001. Four State-listed species were identified as species for 

10 consideration of the proposed license renewal of KPS, including the Caspian tern (Sterna 

11 caspia), the osprey (Pandion haliaetus), and the formerly listed bald eagle and peregrine falcon 

12 (USFWS, 2008; DEK, 2008). 

13 Federally Protected and Formerly Protected Terrestrial Species

14 The piping plover, a Federally- and State-listed endangered bird, is known to live on the 

15 shorelines in the vicinity of KPS. The USFWS has stated in a letter to the NRC that the habitat is 

16 not suitable for piping plovers on the KPS site (USFWS, 2008). The minimum piping plover 

17 nesting habitat requirements, as stated by the USFWS and outlined in the ER (DEK, 2008) 

18 include: 

19 Total shoreline length of at least 200 meters (660 feet) of gently sloping, sparsely 

20 vegetated (<50 percent herbaceous and low woody cover) sand beach with a total 

21 beach area of at least 2 hectares (5 acres); appropriately sized sites must have an area 

22 50 meters (160 feet) in length where the beach width is at least 7 meters (23 feet). 

23 The shoreline from the northern boundary of the KPS site to just below the reactor buildings are 

24 deemed to have “marginal” potential as plover nesting habitat while the southern end of the KPS 

25 site have no potential piping plover habitat (DEK, 2008). Recent surveys of KPS for piping 

26 plovers have not documented the species onsite (DEK, 2008). The piping plover is a small 

27 shorebird with long legs, brown feathered wings, and a white body (USFWS, 2009a). Piping 

28 plovers nest in the sand along the coastline. High human traffic to the beaches of the Atlantic 

29 coast and Great Lakes is considered to be the main reason for the decline of the species 

30 populations (USFWS, 2009a). Activity on beaches can destroy nests, eggs, and the young of 

31 the piping plover. 

32 The Hine’s emerald dragonfly, a Federally- and State-listed endangered species, has been 

33 listed by the USFWS mostly due to loss and fragmentation of habitat (DEK, 2008; USFWS, 

34 2009). The dragonfly inhabits calcareous, spring-fed marshes and sedge meadows (DEK, 2008; 

35 USFWS, 2009). The dragonfly has bright emerald-green eyes and yellow stripes on its side, and 

36 grows to about 2.5 inches (6.4 cm) in length and has a wingspan of about 3.3 inches (8.4 cm) 

37 (USFWS, 2009). The dragonfly has been reported in Kewaunee County, and the closest 

38 location to the KPS site was a small population of the dragonflies from the Black Ash swamp in 
Affected Environment 

 

February 2010 2-33 Draft NUREG-1437, Supplement 40 

1 northern Kewaunee County in 2001 (DEK, 2009b). Recent wildlife surveys on KPS lands did not 

2 detect the presence of Hine’s emerald dragonflies (DEK, 2008). 

3 The Karner blue butterfly is Federally-listed by the USFWS as endangered; however, the State 

4 of Wisconsin does not list the species as either threatened or endangered (DEK, 2008; USFWS, 

5 2009c). Of the counties that contain the KPS site and its associated transmission lines, 

6 Outagamie County is the only one with known populations of the butterfly (DEK, 2008). The 

7 butterfly has about a 1 inch (2.5 cm) wingspan and the males and females are different in 

8 appearance (USFWS, 2009c). The upper side of the male has shades of bright silver or dark 

9 blue with narrow black margins (USFWS, 2009c). Females are grayish brown, with very dark 

10 brown nodes on the outer portions of the wings, and the upper sides of the females are blue, 

11 with irregular bands of orange crescents inside the narrow black border. The underside of both 

12 the males and females are gray, and have a continuous band of orange crescents traveling the 

13 edges of both wings and the underside have scattered black spots circled with white (USFWS 

14 2009c). For habitat, the butterfly prefers pine and oak trees, as well as savannas and barrens, 

15 which contain wild lupine (Lupinus perennis) and other flowering plants (DEK, 2008). After the 

16 species hatches, the caterpillars will only feed on the wild lupine species leaves and are, 

17 therefore, limited to breed in habitats containing that plant species (DEK, 2008). Habitat 

18 fragmentation, development in Wisconsin, and protection against forest fires (wild lupine 

19 requires early stages of forest succession for maximum growth), have all reduced the 

20 populations of wild lupine and its ability to reproduce (DEK, 2008). Surveys of the KPS site and 

21 its associated transmission line ROWs did not show any presence of the Karner blue butterfly 

22 (DEK, 2008). 

23 The dune or Pitcher’s thistle, a Federally- and State-listed threatened species, is known to live 

24 in Manitowoc County, a county crossed by KPS-associated transmission lines (WNDR, 2008b). 

25 The thistle is native to Wisconsin and grows on the beaches and dunes associated with the 

26 Great Lakes (WDNR, 2008b). The thistle can grow to heights of up to 3 feet (1 m) tall, and is 

27 covered with hairs along the stem (USFWS, 2009d). Leaves of the thistle can be 1 foot (0.3 m) 

28 long each, and usually have deep lobes (USFWS, 2009d). The Pitcher’s thistle takes five to 

29 eight years of growing before it begins to flower (USFWS, 2009d). Its non-flowering form is a 

30 grouping or cluster of bright silvery leaves, while the flowering form of the thistle typically has a 

31 single stem with many branches that have cream or pink flowers at the ends (USFWS, 2009d). 

32 Pitcher’s thistle is most often found along the shoreline of the Great Lakes or in unforested 

33 fields, and always near other plant communities. Surveys performed by DEK for Pitcher’s thistle 

34 on the KPS site or in associated transmission lines have no documented occurrences (DEK, 

35 2008). 

36 The dwarf lake iris is Federally- and State-listed as threatened, and has been known to occur in 

37 Brown County, a county crossed by KPS-associated transmission lines (WDNR, 2008). Dwarf 

38 lake iris is a very small iris with dark, deep blue flowers, although sometimes flowers can be lilac 

39 or white (USFWS, 2009b). The flowers are about 1 to 1.5 inches (2.5 to 3.8 cm) wide and 1.5 to 

40 2.5 inches (3.8 to 6.4 cm) tall (USFWS, 2009b). The iris’s leaves can grow to 6 inches (15 cm) 

41 long and are sword-like in shape, and grow in clusters (USFWS, 2009b). The iris prefers 

42 habitats of shoreline, dunes, or cedar forest edge ecosystems, and grows in sandy soils or on 

43 beaches with little to no other vegetation present (USFWS, 2009b). Surveys for dwarf lake iris 
Affected Environment 

Draft NUREG-1437, Supplement 40 2-34 February 2010 

1 on the KPS site or its associated transmission lines did not document any occurrences of the 

2 plant species (DEK, 2008). 

3 On July 9, 2007, the USFWS issued a Federal Register notice announcing the delisting of the 

4 bald eagle from the Federal List of Endangered and Threatened Wildlife (72 FR 37346). Eagles 

5 continue to be protected at the national level by the Bald and Golden Eagle Protection Act, as 

6 well as the Migratory Bird Treaty Act, and at the State level as a Wisconsin-listed threatened 

7 species. The bald eagle is a large bird, even among raptor species, and can reach a weight of 

8 more than 13 pounds (6 kg). The eagle has a white head and tail, with brown body feathers. 

9 Bald eagles eat fish, small mammals, birds, and occasionally carrion. Bald eagles are known to 

10 occur throughout Wisconsin, and in every county associated with the KPS site or its associated 

11 transmission lines. They are seen regularly along the Lake Michigan shoreline. Eagles have 

12 been seen on the KPS site by employees and during the NRC staff audit; however, the KPS site 

13 does not have any eagle nests (DEK, 2008). 

14 The peregrine falcon was removed from the Federal listing in August 1999, but continues to be 

15 listed as endangered at the State level in Wisconsin. Adult birds have a bluish-black head and 

16 wings, are 14 to 19 inches (36 to 48 cm) tall, and have a 39- to 43-inch (99- to 109-cm) 

17 wingspan (Cornell, 2003). Peregrine falcons nest on high cliffs near river systems and in some 

18 cases, especially associated with breeding attempts, the falcon can nest on bridges and tall 

19 buildings. The KPS site has had a breeding pair nesting on its reactor building since 2001, and 

20 the pair has produced at least 14 fledglings (DEK, 2008). In an effort to protect the nesting pair 

21 and their young, DEK regularly communicates with USFWS and WDNR (DEK, 2008). 

22 State Protected Terrestrial Species

23 The Caspian tern, a State-listed endangered species, is potentially occurring on the KPS site 

24 and its associated transmission lines (WDNR, 2004a; WNHP, 2006). The Caspian tern is the 

25 largest known tern species in the world and is easily recognized by its red bill. The tern has grey 

26 feathers on its wings, an all white underbelly, and black feathers on its head. In the spring of 

27 2006, approximately 24 Caspian terns lived and were observed on the shoreline adjacent to the 

28 KPS site (DEK, 2008). 

29 The Wisconsin State-listed threatened osprey may potentially occur on the KPS site or its 

30 associated transmission lines. The osprey is a fairly large bird of prey with a body length of 

31 about 21 to 24 inches (53 to 61 cm) and a wingspan of 4.5 to 5.5 feet (1.4 to 1.7 m). Osprey 

32 feed exclusively on live fish (USFWS, 2008b). Individuals are brown with a white belly and have 

33 distinctive patches on their wings. The osprey has long, sharp talons, which are used for 

34 gripping fish. Females are larger than males, which is true for most birds of prey. The osprey's 

35 habitat includes rivers, lakes, and shallow water estuaries. Nesting often occurs on artificial 

36 structures such as flat-topped wooden platforms, metrological towers, channel markers, and 

37 radio towers, where such structures are near shallow waters that support plentiful fish. Osprey 

38 pairs tend to be solitary nesters, and may colonize secure areas such as islands (USGS, 

39 undated). In May of 2006, one osprey was sighted on the KPS site; however, no other ospreys 

40 have been seen on the KPS site, or its associated transmission lines since. 

41 2.2.8 Socioeconomic Factors 
Affected Environment 

 

February 2010 2-35 Draft NUREG-1437, Supplement 40 

1 This section describes current socioeconomic factors that have the potential to be directly or 

2 indirectly affected by changes in operations at the KPS. The KPS and the people and 

3 communities surrounding it can be described as a dynamic socioeconomic system. The nuclear 

4 power plant requires people, goods, and services from local communities to operate the plant. 

5 The communities, in turn, provide the people, goods, and services to run the plant. KPS 

6 employees residing in the community receive income from the plant in the form of wages, 

7 salaries, and benefits, and spend this income on goods and services within the community 

8 thereby creating additional opportunities for employment and income. People and businesses in 

9 the community also receive income for the goods and services sold to KPS. Payments for these 

10 goods and services create additional employment and income opportunities in the community. 

11 The measure of a communities’ ability to support the operational demands of KPS depends on 

12 the ability of the community to respond to changing socioeconomic conditions. 

13 The socioeconomics region of influence (ROI) is defined by the areas where KPS employees 

14 and their families reside, spend their income, and use their benefits, thereby affecting the 

15 economic conditions of the region. The KPS ROI consists of a three-county area (Kewaunee, 

16 Manitowoc, and Brown counties in Wisconsin). The following sections describe the housing, 

17 public services, offsite land use, visual aesthetics and noise, population demography, and the 

18 economy in the ROI surrounding the KPS. 

19 DEK employs a permanent workforce of approximately 705 workers (DEK, 2008). 

20 Approximately 95 percent live in Kewaunee County, Manitowoc County, and Brown County, 

21 Wisconsin (Table 2-4). Most of the remaining 5 percent of the workforce are divided among 9 

22 other counties in Wisconsin and a few employees living out of state with numbers ranging from 

23 1 to 11 employees per county. Given the residential locations of KPS employees, the most 

24 significant impacts of plant operations are likely to occur in Kewaunee, Manitowoc, and Brown 

25 counties. The focus of the socioeconomic impact analysis in this draft SEIS is based on the 

26 impacts of the KPS on these three counties. 

27 Table 2-4. Kewaunee Power Station Employee Residence by County (Wisconsin) 

County Number of Employees Percentage (%) 

of Total 

Manitowoc 280 39.7 

Brown 228 32.3 

Kewaunee 159 22.6 

Door 11 1.6 

Outagamie 4 0.6 

Sheboygan 4 0.6 

Other 19 2.6 

Total 705 100 

Source: DEK 2008 

28 Refueling outages at the KPS normally occur at 18-month intervals. During refueling outages, 

29 site employment increases by as many as 600 to 700 workers for approximately 30 days (DEK, 
Affected Environment 

Draft NUREG-1437, Supplement 40 2-36 February 2010 

1 2008). Most of these workers are assumed to be located in the same geographic areas as KPS 

2 employees. 

3 2.2.8.1 Housing 

4 Table 2-5 lists the total number of occupied and vacant housing units, vacancy rates, and 

5 median value in the three-county ROI. According to the 2000 Census, there were approximately 

6 133,000 housing units in the socioeconomic region, of which approximately 127,600 were 

7 occupied. The median value of owner-occupied housing units in the three Wisconsin counties 

8 ranged from $90,900 in Manitowoc County to $116,100 in Brown County. The vacancy rate was 

9 the lowest in Brown County (3.2 percent) and highest in Kewaunee County (7.3 percent). 

10 Kewaunee County has the smallest number of total and vacant housing units amongst the three 

11 counties (USCB, 2009a). 

12 By 2007, the estimated number of housing units grew in all three counties by approximately 10 

13 percent of their combined total inventories. In Kewaunee County, the number of housing units 

14 grew to an estimated total of 9,013 units in 2007, an increase of approximately 800 units. In 

15 Manitowoc County the number of housing units grew by more than 2,000 units to an estimated 

16 total of 36,661 units or approximately 6 percent (USCB, 2009a). 

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

Kewaunee Manitowoc Brown ROI 

2000 

Total 8,221 34,651 90,199 133,071 

Occupied housing units 7,623 32,721 87,295 127,639 

Vacant units 598 1,930 2,904 5,432 

Vacancy rate (percent) 7.3 5.6 3.2 4.1 

Median value (dollars) 92,100 90,900 116,100 99,700 

2005–2007, 3-Year Estimate 

Total 9,013 36,661 101,256 146,930 

Occupied housing units 8,272 33,704 95,165 137,141 

Vacant units 741 2,957 6,091 9,789 

Vacancy rate (percent) 8.2 8.1 6.0 6.7 

Median value (dollars) 134,100 118,300 155,400 135,933 

Source: USCB 2009a. 
Affected Environment 

 

February 2010 2-37 Draft NUREG-1437, Supplement 40 

1 2.2.8.2 Public Services 

2 This section presents a discussion of public services including water supply, education, and 

3 transportation. 

4 Water Supply

5 Since 95 percent of workers at the KPS reside in Kewaunee, Manitowoc, and Brown counties, 

6 Wisconsin, the discussion of public water supply systems is limited to these counties. In Table 

7 2-6, information about municipal water suppliers in these counties, their permitted capacities 

8 and maximum design yields, reported annual peak usage, and population served are presented. 

9 Lake Michigan is the source of potable water for the cities of Two Rivers, Manitowoc, and Green 

10 Bay and ground water provides potable water for smaller towns and rural residences in the 

11 vicinity of the KPS site. Two ground water wells at KPS are used for cooling, stand-by cooling, 

12 the plant equipment water system, and potable water. KPS pumps ground water for use as 

13 potable water and is not connected to a municipal system. At the present time, the water supply 

14 systems in Kewaunee, Manitowoc, and Brown counties are operating below their maximum 

15 capacities. The following are brief descriptions of the water supply systems in the three 

16 counties. 

17 Kewaunee County’s major public water systems serve the majority of residential, commercial, 

18 and industrial users and are located in the cities of Kewaunee and Algoma, and the village of 

19 Luxemburg. These three municipal water systems are supplied from groundwater through 

20 community wells. County planners state that these systems are considered adequate for the 

21 cities’ and village’s present and future growth. The village of Casco and ten towns within the 

22 county, not serviced by public systems, have individual or shared wells that are owned and 

23 maintained by the property owner(s). The city of Green Bay obtains drinking water supplies from 

24 Lake Michigan by means of the Green Bay water pipeline. Two raw water pipelines cross 

25 through the central portion of Kewaunee County to supply potable water to the city of Green Bay 

26 and several of its suburbs. At this time, none of the communities in Kewaunee County has any 

27 plans of utilizing this utility for their water needs (Bay-Lake Regional Planning Commission, 

28 2007). 

29 The cities of Manitowoc and Two Rivers are the two largest municipal water suppliers in 

30 Manitowoc County (Table 2-6). Both cities obtain their municipal water from Lake Michigan. All 

31 other water systems in the County rely on ground water as their source (Bay-Lake Regional 

32 Planning Commission, 2005). 

33 Local community infrastructures continue to be used and existing wells are used for backup 

34 purposes. Ground water is the source of all drinking water and other water uses within the 

35 remainder of Brown County (DEK, 2008). 
Affected Environment 

Draft NUREG-1437, Supplement 40 2-38 February 2010 

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

Water Supplier Water Source Average Daily 

Demand System Capacity Population Served 

Kewaunee County 

Algoma Waterworks GW 261 1,584 3,357 

Kewaunee Waterworks GW 362 2,592 2,887 

Luxemburg Waterworks GW 257 590 2,292 

Manitowoc County 

Cleveland Waterworks GW 75 1,500 1,410 

Kiel Waterworks GW 500 4,532 3,630 

Manitowoc Waterworks SW 8,000 31,000 34,500 

Mishicot Waterworks GW 1,404 1,440 1,422 

Reedsville Waterworks GW 100 500 1,200 

Two Rivers Waterworks SW 1,500 4,000 13,354 

Brown County 

Allouez Waterworks SW 1,100 4,000 14,443 

Ashwaubenon Waterworks SW 3,449 6,000 17,625 

Bellevue Waterworks SW 1,000 4,000 14,500 

De Pere Water Department SW 2,600 6,000 22,310 

Green Bay Waterworks SW 20,000 42,000 103,018 

Hobart Waterworks Service Area #1 GW 864 1,400 1,600 

Howard Waterworks SW 1,860 4,200 14,543 

Lawrence Utility District SW 1,050 4,320 1,200 

Wrightstown Waterworks GW 220 1,000 2,578 

2 GW = ground water; SW = surface water 

3 Source: DEK 2008. 

4 Education

5 The KPS is located in the Kewaunee School District, Kewaunee County, which had an 

6 enrollment of approximately 1,000 students in the 2008–2009 school year (DPI, 2009). 

7 Kewaunee County has three public school districts with over 1,900 enrolled students (DPI, 

8 2009). Manitowoc and Brown counties have six and eight public school districts, respectively 

9 (DPI, 2009). Total enrollment in Manitowoc and Brown counties’ schools in the 2008–2009 

10 school year was approximately 12,000 and 42,000 students, respectively (DPI, 2009; IES, 

11 2009). 

12 Transportation

13 Employees enter the KPS site gate after exiting State Highway 42 to the west. State Highway 

14 42 has a north-south orientation and runs near the Lake Michigan shoreline in Kewaunee 

15 County. KPS workers from Ahnapee and Pierce would likely travel south on State Highway 42; 

16 employees from Red River, Lincoln, Luxemburg, and Casco could travel along County Highway 
Affected Environment 

 

February 2010 2-39 Draft NUREG-1437, Supplement 40 

1 C to the intersection with State Highway 42 and then continue south; those in Montpelier and 

2 West Kewaunee, Franklin, and Carlton would likely choose one of the east-west roads, travel 

3 east to the State Highway 42 intersection and then continue south. KPS workers commuting 

4 from Manitowoc County would also travel north on State Highway 42. County Highway BB is 

5 just south of the station and the state-maintained Nuclear Road terminates on State Highway 42 

6 near the plant entrance. State and county roads in this part of Wisconsin were laid out in grids 

7 on true north-south axes with accommodations for naturally occurring geographical boundaries. 

8 Thus, Nuclear Road, County Highway BB, and many other east-west roads leading to KPS are 

9 perpendicular to State Highway 42. 

10 The annual average daily traffic volume along State Highway 42 in Kewaunee County, in 2006, 

11 ranged from 2,400 vehicles to 6,800 vehicles at the various intersections. The annual average 

12 daily traffic sampling location nearest the intersection of Nuclear Road and State Highway 42 

13 was 2,600 vehicles. In 2005, the annual average daily traffic volume along the State Highway 42 

14 in Manitowoc County ranged from 1,900 vehicles to 21,500 vehicles at the various intersections. 

15 The section of State Highway 42 where the 21,500 vehicles were recorded is the section where 

16 State Highway 42 and Interstate Highway 43 share the same road (just west of Manitowoc) 

17 (WDOT, 2009). 

18 Table 2-7 lists commuting routes to KPS and average annual daily traffic (AADT) volume 

19 values. The AADT values represent traffic volumes for a 24-hour period factored by both day of 

20 week and month of year. 

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

2006 Average Annual Daily Traffic Counts 

Roadway and Location Average Annual Daily Traffic (AADT) a

State Highway 42 

(between County Highway BB and Cherneyville Road) 2,600 

State Highway 42 

(between Cherneyville Road and Lakeshore Drive) 2,400 

State Highway 42 

(between State Highway 29 and Lakeshore Drive) 2,500 

State Highway 42 

(between Miller Street and State Highway 29) 5,400 

State Highway 42 north of Miller Street 3,700–4,800 

State Highway 29 west of Kewaunee 3,100–3,800 

State Highway 42 

(between Two Rivers and County Highway BB) 3,200 

Source: WDOT 2009. 

a

 All AADTs represent traffic volume during the average 24-hour day during 2005 and 2006. 

21 2.2.8.3 Offsite Land Use 

22 Offsite land use conditions in Kewaunee and Manitowoc counties are described in this section 

23 because Kewaunee and Manitowoc are the only counties in which KPS employees represent 

24 more than 0.1 percent of the county population. Kewaunee County also receives Wisconsin 
Affected Environment 

Draft NUREG-1437, Supplement 40 2-40 February 2010 

1 Shared Revenues Utility Program payments from the State of Wisconsin because of KPS 

2 presence in the County. In addition to shared revenue, Kewaunee and other counties in the 

3 vicinity of KPS receive revenue from sales taxes and fees paid by DEK and its employees 

4 residing in the region. Changes in the number of workers at the KPS and tax payments could 

5 affect land use conditions in these counties. 

6 The KPS is located in southeastern Kewaunee County. Manitowoc and Brown counties are 

7 located south and west of Kewaunee County respectively. Kewaunee County has experienced 

8 small increases in population and housing over the last 16 years (1990 to 2006). However, the 

9 number of housing units in Kewaunee County grew faster than the population. 

10 Kewaunee County occupies approximately 340 square miles (217,600 acres) (USCB, 2009c). 

11 Almost 93 percent of the county’s land is undeveloped. The majority (84 percent) of the 

12 undeveloped acreage consists of croplands or pastures and woodlands. Croplands or pastures 

13 comprise nearly 63 percent of the county’s total land area, while woodlands cover 21 percent of 

14 the total land area. Some of the larger woodland areas in the county include the Black Ash 

15 Swamp in the town of Lincoln, Duvall Swamp in Red River, and Lipsky Swamp in West 

16 Kewaunee (Bay-Lake Regional Planning Commission, 2007). 

17 Almost 80 percent of the county’s land is agricultural (USDA, 2009). Residential uses account 

18 for the largest developed land-use, covering 2.6 percent of the County’s total land area, while 

19 transportation and agricultural structures each account for approximately 1.6 percent. The 

20 largest concentrations of residential, commercial, and industrial land are found in and around 

21 the cities of Algoma and Kewaunee, the village of Casco, and the town and village of 

22 Luxemburg (Bay-Lake Regional Planning Commission, 2007). 

23 KPS is located in the town of Carlton in Kewaunee County. The town limits of Carlton 

24 encompass an area of 35.6 square miles. Carlton has experienced relatively little land-use 

25 change since KPS began operations. Approximately 97 percent of the land is agricultural or 

26 woodland and 3 percent is developed. Dairy farming is the primary economic activity. 

27 Manitowoc County occupies approximately 592 square miles (378,900 acres) (USCB, 2009c). 

28 Almost 66 percent of the county’s land is farmed (USDA, 2009). Manitowoc County experienced 

29 small increases in population and housing over the 16 years from 1990 to 2006, with the 

30 number of housing units growing faster than the population. However, from 2000 to 2006, the 

31 population in Manitowoc County declined by a small amount while the number of housing units 

32 increased. 
Affected Environment 

 

February 2010 2-41 Draft NUREG-1437, Supplement 40 

1 2.2.8.4 Visual Aesthetics and Noise 

2 The KPS can be seen from the lake, but is partly shielded by vegetation along the lake. The 

3 predominant feature of the KPS site is the reactor building, which is approximately 180-feet tall 

4 (AEC, 1972). On the lake side of the reactor building is the turbine building, which is 

5 approximately 100-feet tall (AEC, 1972). Other features include the auxiliary building (adjoining 

6 the reactor building), administration building, and meteorological tower. The turbine building and 

7 reactor containment structures dominate the landscape of the site. 

8 Noise from nuclear plant operations can be detected offsite. Sources of noise at KPS include 

9 the turbines and large pump motors. Given the industrial nature of the station, noise emissions 

10 from the station are generally nothing more than an intermittent minor nuisance. However, noise 

11 levels may sometimes exceed the 55 dBA level that the EPA uses as a threshold level to protect 

12 against excess noise during outdoor activities (EPA, 1974). However, according to the EPA this 

13 threshold does “not constitute a standard, specification, or regulation,” but was intended to 

14 provide a basis for state and local governments establishing noise standards. 

15 2.2.8.5 Demography 

16 According to the 2000 Census, approximately 86,224 people lived within 20 miles of KPS, which 

17 equates to a population density of 132 persons per square mile (DEK, 2008). This density 

18 translates to GEIS Category 4, least sparse (greater than or equal to 120 persons per square 

19 mile within 20 miles). Approximately 723,900 people live within 50 miles of KPS (DEK, 2008). 

20 This equates to a population density of 202 persons per square mile. Applying the GEIS 

21 proximity measures, KPS is classified as proximity Category 4 (greater than or equal to 190 

22 persons per square mile within 50 miles). Therefore, according to the sparseness and proximity 

23 matrix presented in the GEIS, rankings of sparseness Category 4 and proximity Category 4 

24 result in the conclusion that KPS is located in a high population area. 

25 Table 2-8 shows population projections and growth rates from 1970 to 2050 in Kewaunee, 

26 Manitowoc, and Brown counties, Wisconsin. The growth rate in Kewaunee County showed an 

27 increase of 6.9 percent for the period of 1990 to 2000. County populations are expected to 

28 continue to grow in Kewaunee, Manitowoc, and Brown counties through 2050. 

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

30 Wisconsin, from 1970 to 2000 and projected for 2008 to 2050 

Kewaunee Manitowoc Brown 

Year Population 

Percent 

Growth(a) Population 

Percent 

Growth(a) Population 

Percent 

Growth(a)

1970 18,961 — 82,294 — 158,244 — 

1980 19,539 3.0 82,918 0.8 175,280 10.8 

1990 18,878 -3.4 80,421 -3.0 194,594 11.0 

2000 20,187 6.9 82,887 3.1 226,778 16.5 

2008 20,388 1.0 80,641 -2.7 245,018 8.0 

2010 21,841 8.2 85,834 3.6 254,040 12.0 
Affected Environment 

Draft NUREG-1437, Supplement 40 2-42 February 2010 

2020 23,587 8.0 89,035 3.7 282,409 11.2 

2030 25,085 6.4 91,622 2.9 306,931 8.7 

2040 26,748 6.6 94,618 3.3 334,018 8.8 

2050 28,370 6.1 97,512 3.1 360,463 7.9 

— = No data available. 

(a)Percent growth rate is calculated over the previous decade. 

Sources: Population data for 1970 through estimated population data for 2008 (USCB, 

2009b); population projections for 2010– 2030 by State of Wisconsin Demographics 

Services Center, Division of Intergovernmental Relations, Department of 

Administration (5/30/2008); population projections for 2040 and 2050 (calculated). 

1 Demographic Profile

2 The 2000 and 2005–2007 American Community Survey 3-Year Estimates demographic profiles 

3 of the three-county region of influence population are presented in Table 2-9 and Table 2-10. In 

4 2000, minority individuals (both race and ethnicity) comprised 8.5 percent of the total three5 county population. The minority population was composed largely of Hispanic or Latino and 

6 Asian residents. 

7 Table 2-9. Demographic Profile of the Population in the Kewaunee Power Station Three8 County Socioeconomic Region of Influence (ROI) in 2000 

Kewaunee Manitowoc Brown ROI 

Total Population 20,187 82,887 226,778 329,852 

Race (percent of total population, Not-Hispanic or Latino) 

White 98.2 95.0 89.6 91.5 

Black or African American 0.1 0.3 1.1 0.9 

American Indian and Alaska Native 0.3 0.4 2.1 1.6 

Asian 0.1 2.0 2.2 2.0 

Native Hawaiian and Other Pacific Islander 0.0 0.0 0.0 0.0 

Some other race 0.0 0.0 0.0 0.0 

Two or more races 0.5 0.7 1.0 0.9 

Ethnicity 

Hispanic or Latino 153 1,343 8,698 10,194 

Percent of total population 0.8 1.6 3.8 3.1 

Minority Population (including Hispanic or Latino ethnicity) 

Total minority population 365 4,131 23,535 28,031 

Percent minority 1.8 5.0 10.4 8.5 

9 Source: USCB, 2009b 

10 According to the U.S. Census Bureau’s (USCB’s) 2005–2007 American Community Survey 

11 3-Year Estimates, minority populations in the three-county region were estimated to have 

12 increased by over 8,300 persons and comprised 10.6 percent of the total three county 

13 population (see Table 2-10). Most of this increase was due to an estimated increase in the 

14 Hispanic or Latino population (over 5,000 persons) of over 52 percent from 2000. This was the 

15 largest percentage increase of any minority population and a 1.4 percent increase in the 
Affected Environment 

 

February 2010 2-43 Draft NUREG-1437, Supplement 40 

1 Hispanic or Latino population when compared to the total increase in the three-county 

2 population. The next largest increase in minority population was in the Black or African 

3 American population, an increase of over 1,600 persons from 2000. However, this resulted in a 

4 0.5 increase in population as a percentage of the total increase in the three-county population. 

5 Table 2-10. Demographic Profile of the Population in the Kewaunee Power Station Three6 County Socioeconomic Region of Influence in 2005-2007, 3-Year Estimate 

Kewaunee Manitowoc Brown ROI 

Total Population 20,532 81,009 240,801 342,342 

Race (percent of total population, Not-Hispanic or Latino) 

White 97.0 94.0 87.2 89.4 

Black or African American 0.0 0.6 1.7 1.3 

American Indian and Alaska Native 0.2 0.3 1.9 1.4 

Asian 0.2 1.9 2.3 2.1 

Native Hawaiian and Other Pacific Islander 0.2 0.0 0.1 0.1 

Other 0.0 0.0 0.1 0.1 

Two or more races 0.8 0.9 1.2 1.1 

Ethnicity 

Hispanic or Latino 314 1,880 13,347 15,541 

Percent of total population 1.5 2.3 5.5 4.5 

Minority Population (including Hispanic or Latino ethnicity) 

Total minority population 624 4,895 30,826 36,345 

Percent minority 3.0 6.0 12.8 10.6 

7 Source: USCB, 2009b 

8 Transient Population

9 Within 50 miles (80 km) of the KPS, colleges and recreational opportunities attract daily and 

10 seasonal visitors who create demand for temporary housing and services. In 2009, there were 

11 approximately 11,794 students attending colleges and universities within 50 miles (80 km) of the 

12 KPS (IES, 2009). 

13 In 2000 in Kewaunee County, 45.2 percent of all housing units were considered temporary 

14 housing for seasonal, recreational, or occasional use. By comparison, seasonal housing 

15 accounted for 26.8 percent, 14.3 percent, and 60.1 percent of total housing units in Manitowoc 

16 and Brown counties and Wisconsin, respectively (USCB, 2009a). Table 2-11 provides 

17 information on seasonal housing for the 12 counties located all or partly within 50 miles of the 

18 KPS. 
Affected Environment 

Draft NUREG-1437, Supplement 40 2-44 February 2010 

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

2 Power Station 

Countya Housing units 

Vacant housing units: For 

seasonal, recreational, or 

occasional use 

Percent 

Wisconsin 236,600 142,313 60.1 

Brown 2,904 414 14.3 

Calumet 848 287 33.8 

Door 7,759 6,970 89.8 

Fond du Lac 2,340 573 24.5 

Kewaunee 598 270 45.2 

Manitowoc 1,930 518 26.8 

Marinette 8,675 7,586 87.4 

Oconto 5,833 4,837 82.9 

Outagamie 2,084 237 11.4 

Shawano 2,502 1,793 71.7 

Sheboygan 2,402 804 33.5 

Winnebago 3,564 1,032 29.0 

County Total 41,439 25,321 45.9 (avg.) 

Source: USCB 2009a 

a

 Counties within 50 miles of the KPS that are totally or partially located within the 50-mile radius. 

avg. = percent average for counties within the KPS 50-mile radius and excludes state percentage.

3 Migrant Farm Workers

4 Migrant farm workers are individuals whose employment requires travel to harvest agricultural 

5 crops. These workers may or may not have a permanent residence. Some migrant workers 

6 follow the harvesting of crops, particularly fruit, throughout rural areas of the United States. 

7 Others may be permanent residents near the KPS who travel from farm to farm harvesting 

8 crops. 

9 Migrant workers may be members of minority or low-income populations. Because they travel 

10 and can spend a significant amount of time in an area without being actual residents, migrant 

11 workers may be unavailable for counting by census takers. If uncounted, these workers would 

12 be “underrepresented” in USCB minority and low-income population counts. 

13 Information on migrant farm and temporary labor was collected in the 2007 Census of 

14 Agriculture. Table 2-12 provides information on migrant farm workers and temporary farm labor 

15 (less than 150 days) within 50 miles of the KPS. According to the 2007 Census of Agriculture, 

16 approximately 8,000 farm workers were hired to work for less than 150 days and were 

17 employed on 2,300 farms within 50 miles of the KPS. The county with the largest number of 

18 temporary farm workers (1,108 workers on 298 farms) was Fond du Lac County, Wisconsin 

19 (USDA, 2009). 

20 In the 2002 Census of Agriculture, farm operators were asked for the first time whether or not 

21 any of them hired migrant workers, defined as a farm worker whose employment required travel 
Affected Environment 

 

February 2010 2-45 Draft NUREG-1437, Supplement 40 

1 that prevented the migrant worker from returning to their permanent place of residence the 

2 same day. A total of 131 farms in the 50-mile radius of the KPS reported hiring migrant workers 

3 in the 2007 Census of Agriculture. Brown County, reported the most farms (20 farms) with hired 

4 migrant workers, followed by Fond du Lac County and Outagamie County with 16 farms (USDA, 

5 2009). 

6 According to the 2007 Census of Agriculture estimates, 675 temporary farm laborers (those 

7 working fewer than 150 days per year) were employed on 148 farms in Kewaunee County, and 

8 976 and 823 temporary farm workers were employed on 256 and 213 farms in Manitowoc and 

9 Brown counties, respectively (USDA, 2009). 

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

11 50 Miles of the Kewaunee Power Station 

County a

Number of farms 

with hired farm 

labor b

Number of farms 

hiring workers for 

less than 150 days b

Number of farm 

workers working for 

less than 150 days b

Number of farms 

reporting migrant 

farm labor b

Wisconsin 17,889 13,169 45,921 636 

Brown 318 213 823 20 

Calumet 244 163 471 12 

Door 201 167 564 6 

Fond du Lac 451 298 1,108 16 

Kewaunee 250 148 675 11 

Manitowoc 353 256 976 12 

Marinette 143 107 476 9 

Oconto 251 171 606 7 

Outagamie 350 230 755 16 

Shawano 417 246 872 8 

Sheboygan 290 201 664 5 

Winnebago 214 144 404 9 

County Total 3,482 2,344 8,394 131 

Source: 2007 Census of Agriculture–County Data (USDA, 2009) 

a

 Counties within 50 miles of the KPS that are totally or partially located within the 50-mile radius 

b

 Table 7. Hired Farm Labor - Workers and Payroll: 2007 
Affected Environment 

Draft NUREG-1437, Supplement 40 2-46 February 2010 

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 the U.S. Census Bureau’s 2005–2007 American Community Survey 3-Year 

6 Estimates, the civilian labor force in Kewaunee County increased 5.7 percent from 10,984 to 

7 11,609. During the same time period, the civilian labor force in Manitowoc County grew by 1.6 

8 percent. By 2007, the civilian labor force in Brown County increased by 6.1 percent 

9 (USCB, 2009). 

10 According to the U.S. Census Bureau’s 2005–2007 American Community Survey 3-Year 

11 Estimates, manufacturing represented the largest industrial sector of employment in the three12 county region followed by educational services, health care and social assistance, and retail 

13 trade industry. A list of some of the major employers in Kewaunee County is provided in Table 

14 2-13. 

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

Employer Service or Product Number of 

Employees 

Aurora Medical Center of Oshkosh General medical & surgical hospitals 500–999 

Wisconsin Label Corp. Commercial flexographic printing 500–999 

Algoma Hardwoods Inc. Wood window & door manufacturing 250–499 

Kewaunee Nuclear Power Plant Nuclear electric power generation 250–499 

Luxemburg-Casco Public Schools Elementary & secondary schools 250–499 

Kewaunee Fabrications LLC Miscellaneous gen. purpose machinery mfg. 250–499 

Kewaunee School District Elementary & secondary schools 100–249 

County of Kewaunee Highway, street, & bridge construction 100–249 

N E W Plastics Corp. Plastics bottle manufacturing 100–249 

The Vollrath Co. LLC Kitchen utensil, pot, & pan manufacturing 100–249 

Source: DWD, 2006 

16 Estimated income information for the KPS ROI is presented in Table 2-14. According to the 

17 USCB’s 2005–2007 American Community Survey 3-Year Estimates, Kewaunee and Brown 

18 counties each had median household incomes above the State average. Brown County had the 

19 highest median household income among the three counties. Per capita incomes in Kewaunee 

20 County and Manitowoc County were both below per capita income estimates for Brown County 

21 and the State. In Kewaunee and Manitowoc counties an estimated 5.8 and 8.6 percent of the 

22 population were living below the official poverty level, respectively, while the percentage for 

23 Brown County and the State of Wisconsin as a whole was over 10 percent. The percentage of 

24 families living below the poverty level in Kewaunee County and Manitowoc County (4.6 and 5.5 

25 percent, respectively) was lower than the percentage of families in Brown County and the State 

26 of Wisconsin as a whole (both over 7 percent) (USCB, 2009). 
Affected Environment 

 

February 2010 2-47 Draft NUREG-1437, Supplement 40 

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

2 Influence, 2005–2007 3-Year Estimates 

Kewaunee Manitowoc Brown Wisconsin 

Median household income (dollars) 51,734 47,075 51,624 50,309 

Per capita income (dollars) 23,771 23,592 25,741 25,742 

Percent of families living below the poverty level 4.6 5.5 7.6 7.1 

Percent of individuals living below the poverty level 5.8 8.6 10.4 10.8 

3 Source: USCB, 2009 

4 Unemployment

5 According to the U.S. Census Bureau’s 2005–2007 American Community Survey 3-Year 

6 Estimates, the unemployment rate in Kewaunee and Manitowoc counties was 4.5 and 5.5 

7 percent, respectively, which was lower than the unemployment rate of 5.8 percent for the State 

8 of Wisconsin (USCB, 2009). The unemployment rate in Brown County was 6.2 percent, which 

9 was higher than the state average (USCB, 2009). 

10 Taxes

11 Utilities and large electricity generators in Wisconsin are generally exempt from paying local 

12 property taxes. Instead, “gross revenue” taxes are collected from the utilities, which are then 

13 combined with other revenue collected statewide to become part of the state’s general purpose 

14 revenue fund. The general purpose revenue fund is disbursed in the form of aid payments to 

15 local governments. In general, utility aid payments are distributed to the county and municipality 

16 based on utility valuation or location. 

17 Utility aid payments consist of six components: the ad valorem payment, spent nuclear fuel 

18 storage payment, the minimum payment, the per capita limit, megawatt-based payment and 

19 incentive payments. Descriptions of the components applicable to KPS are provided below. 

20 Ad Valorem Payment

21 This component is based on the “net book value” of “qualifying property” for “eligible utilities”. 

22 The total value of “qualifying property” in a municipality may not exceed $125 million per utility 

23 company or, if the property is owned by two or more utilities, $125 million for that specific 

24 property. 

25 • “Net book value” is the original cost of the property minus depreciation. For deregulated 

26 companies, depreciation is generally reported on a straight-line basis. 

27 • “Qualifying property” includes (a) production plants that were in operation on January 1, 

28 2004, and not subsequently rebuilt or “repowered,” (b) substations, and (c) general 

29 structures. The land on which such property is located is excluded. Electric utility 

30 production plant consists of generating station structures and improvements and 

31 associated boilers, reactors, reservoirs, dams, waterways, fuel holders; engines, prime 

32 movers, and generators. Electric utility substations are facilities that connect the local 

33 distribution lines to the interstate electric transmission system. Gas utility substations are 
Affected Environment 

Draft NUREG-1437, Supplement 40 2-48 February 2010 

1 facilities that connect the local distribution lines to interstate gas transmission pipelines. 

2 For any utility, general structures included office buildings, garages, maintenance 

3 facilities, and related structures. 

4 • “Eligible utilities” include: (1) private companies that produce, transmit, or distribute 

5 electricity or gas in more than one municipality; (2) electric cooperatives; (3) municipal 

6 utilities (for the portion of their property located outside the municipality that owns the 

7 utility) (4) municipal electric association projects (multi-municipal entities that own 

8 electric plants and/or purchase and transmit electricity to their members); and (5) 

9 qualified wholesale electric companies (entities that sell 95 percent or more of their 

10 power at wholesale and have a total generating capacity of 50 megawatts (MW) or 

11 more). 

12 When calculating payments, the net book value in a municipality may not be less than the net 

13 book value as of December 31, 1989, minus the value of property removed since that date. This 

14 is called the “value guarantee.” 

15 Spent nuclear fuel storage

16 A payment of $50,000 is made to any municipality and county in which spent nuclear fuel is 

17 stored on December 31 of the prior year. If the nuclear fuel storage facility is located within one 

18 mile of another municipality or county, the municipality or county where the fuel is stored is paid 

19 $40,000 and the nearby municipality or county is paid $10,000. 

20 Minimum payment

21 This component applies only to electric generating plants with a rated capacity of 200 MW or 

22 more that were in operation on January 1, 2004, and not subsequently rebuilt or “repowered”. 

23 The minimum payment to a municipality or county with such a plant may not be less than 

24 $75,000. 

25 Per capita limit

26 The total payment from the ad valorem and minimum payments may not exceed $300 per 

27 capita for municipalities and $100 per capita for counties. Payments under the spent nuclear 

28 fuel storage component are exempt from this limit. 

29 Megawatt-based payment

30 Through 2008, this component only applies to electric generating plants that began operation or 

31 were “repowered” after December 31, 2003. Beginning in 2009, this component may apply to 

32 KPS in lieu of the ad valorem payment. The payment is $2,000 per MW of name-plate 

33 generating capacity. For a plant in a town, one-third ($666.67) is paid to the town and two-thirds 

34 ($1,333.33) is paid to the county. For a plant in a village or city, two-thirds ($1,333.33) is paid to 

35 the village or city and one-third ($666.67) is paid to the county. 
Affected Environment 

 

February 2010 2-49 Draft NUREG-1437, Supplement 40 

1 Pending Utility Tax Changes

2 Beginning in 2009, the Wisconsin Department of Revenue changed the methodology for 

3 computing the utility aid payment. For production plants that were in operation on January 1, 

4 2004, and not subsequently rebuilt or “repowered,” the payment is the greater of (a) the amount 

5 calculated under the current net book value based payment, or (b) the amount that would be 

6 paid under the $2,000 per MW payment plus incentive payments for plants that use a renewable 

7 energy source. Once a payment is made under alternative (b), all future payments will be 

8 calculated under alternative (b) (WDOR, 2007). 

9 In addition, the provision under which the net book value in a municipality may not be less than 

10 the net book value as of December 31, 1989, minus the value of property removed since that 

11 date, the “value guarantee,” was repealed effective with payments in 2009. Also, in 2009, the 

12 per capita limitation on payments increased over previous years for municipalities and counties 

13 (WDOR, 2007). 

14 Taxes Paid by DEK 

15 In lieu of property tax on its electrical generating plant and other facilities, DEK pays the State of 

16 Wisconsin a lump sum gross revenue tax. There is no direct correlation between the amount of 

17 taxes paid to the State of Wisconsin and the distribution of funds to local taxing jurisdictions. 

18 The allocation of tax revenue attributable to KPS to local taxing jurisdictions is not recorded. 

19 Wisconsin state law requires that utility aid funds be paid to the municipalities and counties 

20 where utility property is located. The utility aid payments to the town of Carlton and Kewaunee 

21 County from the state could be attributed to the presence of KPS in these jurisdictions. Tables 

22 2-15 through 2-19 present information about the town of Carlton’s and Kewaunee County’s total 

23 tax revenues and the utility aid payments to the town of Carlton and Kewaunee County from the 

24 State of Wisconsin (for all utility property located in the town of Carlton). 

25 As presented in Table 2-16, the utility aid payments represent approximately 58.0 to 

26 69.2 percent of the town of Carlton’s total tax revenues. The vast majority of the payments are 

27 attributed to KPS. In 2004 and 2005, the town of Carlton collected no general property tax from 

28 its residents (DEK, 2008). Additionally, as shown in Table 2-17, the utility aid payments to 

29 Kewaunee County represent approximately 2.3 to 3.8 percent of Kewaunee County’s total tax 

30 revenue. 
Affected Environment 

Draft NUREG-1437, Supplement 40 2-50 February 2010 

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

2 Property in the Town of Carlton, 2004 to 2008 

Item 2004 2005 2006 2007 2008 

Utility Property: Net Book Value: 

Wisconsin Power & 

Light 

48,276,451 44,689,234 6 6 6 

Wisconsin Public 

Service 

70,717,380 73,240,209 0 240,250 154,309 

Dominion Energy 

Kewaunee 

0 0 75,773,083 36,556,659 37,503,448 

American 

Transmission 

1,310,499 1,281,173 1,872,469 2,209,085 2,043,656 

Total 120,304,330 119,210,616 77,643,558 39,006,000 39,701,413 

Value Guarantee 1,093,714 0 17,062,594 55,702,152 55,006,739 

Total Value 121,398,044 119,210,616 94,708,152 94,708,152 94,708,152 

Payment: 

Payment Rate 0.003 0.003 0.003 0.003 0.003 

Payment – Rate X 

Total Value 

364,194.13 357,631.85 284,124.46 284,124.46 284,124.46 

Population 1,032 1,037 1,031 1,034 1,061 

Payment Limit – Per 

Capita 

300.00 300.00 300.00 300.00 300.00 

Maximum Payment 309,600.00 311,100.00 309,300.00 310,200.00 318,300.00 

Value-Based 

payment 

309,600.00 311,100.00 284,124.46 284,124.46 284,124.46 

Spent Nuclear Fuel 

payment 

50,000.00 50,000.00 50,000.00 50,000.00 50,000.00 

Total Utility Payment 359,600.00 361,100.00 334,124.46 334,124.46 334,124.46 

Source: DEK, 2008 

Note: The shared revenue payment is funded from general state revenues; it is not paid by the utilities in the town. It 

is a payment for the presence of the utilities in the town and county. 
Affected Environment 

 

February 2010 2-51 Draft NUREG-1437, Supplement 40 

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

2 Property in the Town of Carlton, 2004 to 2008 

Item 2004 2005 2006 2007 

(estimated) 

2008 

(estimated) 

Utility Property: Net Book Value: 

Wisconsin Power 

& Light 

48,276,451 44,689,234 6 6 6 

Wisconsin Public 

Service 

70,717,380 73,240,209 0 240,250 154,309 

Dominion Energy 

Kewaunee 

0 0 75,773,083 36,556,659 37,503,448 

American 

Transmission 

1,310,499 1,281,173 1,872,469 2,209,085 2,043,656 

Total 120,304,330 119,210,616 77,643,558 39,006,000 39,701,413 

Value Guarantee 1,093,714 0 17,062,594 55,702,152 55,006,739 

Total Value 121,398,044 119,210,616 94,708,152 94,708,152 94,708,152 

 

Payment: 

Payment Rate 0.006 0.006 0.006 0.006 0.006 

Payment – Rate X 

Total Value 

728,388.26 715,263.70 568,248.91 568,248.91 568,248.91 

Population 20,648 21,082 12,157 21,198 21,358 

Payment Limit – 

Per Capita 

100.00 100.00 100.00 100.00 100.00 

Maximum 

Payment 

2,064,800.00 2,108,200.00 2,115,700.00 2,119,800.00 2,135,800.00 

Value-Based 

payment 

728,388.26 715,263.70 568,248.91 568,248.91 568,248.91 

Spent Nuclear 

Fuel payment 

50,000.00 50,000.00 50,000.00 50,000.00 50,000.00 

Total Utility 

Payment 

778,388.26 765,263.70 618,248.91 618,248.91 618,248.91 

Source: DEK, 2008 

Note: The shared revenue payment is funded from general state revenues; it is not paid by the utilities in the town. It 

is a payment for the presence of the utilities in the town and county. 

3 
Affected Environment 

Draft NUREG-1437, Supplement 40 2-52 February 2010 

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

2 Kewaunee County for Utility Property in the Town of Carlton, Projected for 2009 

Item Town of Carlton Kewaunee County Combined Total 

Utility Property: Net Book Value: 

Wisconsin Public Service 148,137 148,137 148,137 

American Transmission 1,961,910 1,961,910 1,961,910 

Total 2,110,047 2,110,047 2,110,047 

 

Payment Rate 0.003 0.006 

Value-Based Payment 6,330.14 12,660.28 18,990.42 

 

Megawatt-Based Payment: 

$ per MW of Capacity 666.67 1,333.33 2,000.00 

MW Capacity 535 535 535 

Megawatt – Based Payment 356,666.67 713,333.32 1,070,000.00 

 

Maximum Payment: 

Population 1,061 21,494 

Payment Limit – Per capita 425.00 125.00 

Maximum Payment 450,925.00 2,686,750.00 3,137,675.00 

Utility Property – Value-Based 

Payment 

6,330.14 12,660.28 18,990.42 

Utility Property – Megawatt-Based 

Payment 

356,666.67 713,333.32 1,070,000.00 

Spent Nuclear Fuel Payment 50,000.00 50,000.00 50,000.00 

Total Utility Aid Payment 412,996.81 775,993.60 1,138,990.42 

Source: DEK, 2008 

Note: The shared revenue payment is funded from general state revenues; it is not paid by the utilities in the town. 

It is a payment for the presence of the utilities in the town and county.

3 
Affected Environment 

 

February 2010 2-53 Draft NUREG-1437, Supplement 40 

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

2 Town Revenues, 2004 to 2008 

Year 2004 2005 2006 2007 2008 

Total Revenues 522,200 522,100 515,200 576,400 NA 

Wisconsin Shared Revenue Utility 

Payments 

359,600 361,100 334,124 334,124 334,124 

Percent of Total Revenues 68.9 69.2 64.9 58.0 NA 

Source: DEK, 2008; WDOR, 2009. 

3 

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

5 Town Revenues, 2004 to 2008 

Year 2004 2005 2006 2007 2008 

Total Revenues 20,376,900 22,597,300 21,683,600 26,351,500 NA 

Wisconsin Shared Revenue 

Utility Payments 

778,388 765,264 618,249 618,249 618,249 

Percent of Total Revenues 3.8 3.4 2.9 2.3 NA 

Source: DEK, 2008; WDOR, 2009. 

6 2.2.9 Historic and Archaeological Resources 

7 This section discusses the cultural background and the known historic and archaeological 

8 resources at the KPS site and in the surrounding area. 

9 2.2.9.1 Cultural Background 

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

11 The landscape of Wisconsin is dominated by glacial and postglacial geological deposits. The 

12 Pleistocene Age glaciers reached their greatest extent 14,000 to 16,000 years ago, and the last 

13 glacial advance (the Two Rivers, or Valderan) dates to about 12,400 years ago. Approximately 

14 12,000 years ago the glaciers retreated and exposed most of the current area of Wisconsin. 

15 The region around the KPS site contains prehistoric and historic Native American and Euro16 American cultural resources. Twenty properties in Manitowoc County and eleven properties in 

17 Kewaunee County are listed in the National Register of Historic Places (NRHP). None of these 

18 properties fall within a 6-mile radius of KPS (NPS 2009a, 2009b). 

19 Prehistoric Periods

20 The climate during the Paleo-Indian period was much cooler and wetter than today. The 

21 distribution of Paleo-Indian artifacts in Wisconsin correlates with the last stages of glacial activity 
Affected Environment 

Draft NUREG-1437, Supplement 40 2-54 February 2010 

1 and fluctuating lake levels. Paleo-lndians exploited postglacial environments and organized in 

2 small mobile hunting groups and appear to have been more numerous in southern Wisconsin 

3 than in the north where glacial conditions persisted longer (R. Mason, 1997). 

4 Paleo-Indian populations were highly mobile. Most sites would have been short-term 

5 occupations (campsites). Paleo-Indian peoples hunted large, now extinct game, such as 

6 mastodon, mammoth, and caribou that lived on the lush vegetation that colonized postglacial 

7 soils (R. Mason, 1997). By the late Paleo-lndian period, the levels of the Great Lakes may have 

8 been significantly lower than present. Paleo-lndian sites of this period could be submerged 

9 several hundred feet below the current surface (R. Mason, 1997). Later Paleo-lndian sites show 

10 evidence of woodworking tools reflecting the increasing forestation of the previously glaciated 

11 land. Late Paleo-lndian sites are widespread and continue to reflect small mobile populations. 

12 Instead of large game, species hunted during the later period included deer, caribou, bison, 

13 turtle, beaver, and other small mammals (R. Mason, 1997). 

14 During the Archaic Period, subsistence hunting and gathering underwent changes to adapt to 

15 resource availability. As glaciers retreated northward and larger animals disappeared from the 

16 region, humans adapted to modern plants and smaller game animals. Between 10,000 and 

17 7,500 years ago, Archaic populations consisting of small groups of hunters and gatherers living 

18 in caves and rock shelters along rivers, around lakes and wetlands, replaced the older Paleo19 lndian culture. 

20 Archaic peoples may have been direct descendants of Paleo-lndians or may represent a 

21 migration of people from the south. These hunter-gatherers subsisted on fish, wild plants, nuts, 

22 acorns, and modern game animals such as elk and deer. Archaeological evidence indicates that 

23 settlement was sparse with small, mobile groups relying on diverse hunting and gathering 

24 strategies. At least one extensive Archaic local Wisconsin quarry site is known; however, stone 

25 tool materials from neighboring Illinois are also found at Archaic sites (Stoltman, 1997). By 

26 about 4,000 to 6,000 B.C., Archaic sites were more widely distributed throughout Wisconsin. 

27 Drier, warmer conditions with a rise in herbaceous species characterized this period. Archaic 

28 tool assemblages expanded to include fishing gear, ground stone plant processing tools, axes, 

29 and copper tools (Stoltman, 1997). Copper artifacts (such as harpoons, axes, adzes, chisels, 

30 knives, and drills) are widely found in eastern Wisconsin and in Manitowoc County (Stoltman, 

31 1997). 

32 The Red Ochre Complex, an elaborate ceremonial burial complex distributed widely across the 

33 Midwest and the Great Lakes areas, serves to mark the transition between the Archaic and the 

34 Woodland periods. Information about the complex is largely limited to burial sites, therefore the 

35 connections to the Archaic and Woodland period remains uncertain (Stevenson et al., 1997). 

36 Use of copper for ornaments increased; evidence of fishing and wild rice harvesting exists. 

37 Toward the end of this period, mounds and Woodland pottery are found at these sites. 

38 Approximately 2,500 years ago, the presence of pottery marks the beginning of the Woodland 

39 period in Wisconsin. In Wisconsin, the Archaic culture persists throughout the early Woodland 

40 period. The Woodland period is also defined by the introduction of horticulture to augment 

41 subsistence hunting and gathering. In the Great Lakes region, evidence of domestication of 

42 local plants appears, as well as the introduction of exotic species. Squash is the earliest known 

43 agricultural crop (R. Mason, 1981). A reliance on agriculture led to the establishment of more 
Affected Environment 

 

February 2010 2-55 Draft NUREG-1437, Supplement 40 

1 permanent settlements during this period. Use of bows and arrows and pottery and construction 

2 of effigy mounds all began during of the Woodland period. 

3 The middle Woodland occupation (roughly 1,500 to 2,200 years ago) has distinctive 

4 characteristics that include construction of conical burial mounds and evidence of widespread 

5 interaction throughout central and eastern North America. The characteristics of this network, 

6 called the Hopewell Interaction Sphere, include elaborate ceremonialism, extensive trade of 

7 exotic manufactured items and raw materials, and large mound construction. 

8 Late Woodland sites (occupied 700 to 1,600 years ago) show a decline in Hopewellian 

9 ceremonialism but continue the tradition of mound construction, primarily in the form of animal 

10 and human shapes, in the southern half of Wisconsin. Burials are associated with some, but not 

11 all, mounds (Stevenson et al., 1997). Cultivation of corn became increasingly prominent, and 

12 villages became more permanent (Stevenson et al., 1997). Late Woodland populations 

13 continued to increase and archaeological evidence from settlements shows a greater 

14 dependence on agriculture (R. Mason, 1981). 

15 An exception to the typical Woodland occupation is the intrusion of a few Middle Mississippian 

16 sites in Wisconsin about 1,000 years ago. These sites consist of permanent towns and 

17 ceremonial sites in Iowa, Minnesota, Missouri, and Illinois, particularly the site of Cahokia. 

18 Hierarchical structure, extensive trade networks, a focus on larger centralized villages, and 

19 intensive agriculture characterized these societies. Several sites in south-central Wisconsin 

20 represent a northern extension of Mississippian culture. Aztalan, a palisade village containing 

21 four platform mounds and a series of dwellings, is the best known of these sites in Wisconsin 

22 (Goldstein and Freeman, 1997). The relationship of such sites with the surrounding Woodland 

23 sites is unclear, and the influence of the Mississippian culture on Woodland culture in Wisconsin 

24 appears to have been transitory (Green, 1997). 

25 The transition from Woodland to later cultures is poorly understood. About 1,000 years ago, 

26 overlapping the late Woodland and Mississippian period, sites referred to as the Oneota culture, 

27 recognized by distinctive pottery styles, appear in the archaeological record. Permanent 

28 villages, some fortified, were established; subsistence was based on corn, beans, squash, 

29 aquatic resources, and a variety of wild plants and game. Hunting and gathering, probably on a 

30 seasonal basis, supplemented the basic agricultural economy (Overstreet, 1997). Following the 

31 collapse of Mississippian influence, Oneota communities returned to the abandoned areas, and 

32 by about 700 years ago, they were the predominant culture in most of southern Wisconsin 

33 (Overstreet, 1997). 

34 During the late Oneota culture, villages were concentrated in several areas, such as the Fox 

35 River valley in eastern Wisconsin. Subsistence patterns remained relatively constant throughout 

36 Oneota history until the arrival of Europeans (circa 1600 to 1650). Oneota settlements in 

37 eastern Wisconsin were abandoned by the time of French contact. Causes for this rapid 

38 depopulation could include disease, warfare, or out-migration (Overstreet, 1997). The Ho-Chunk 

39 (formerly Winnebago) Indians are commonly believed to be descendants of Oneota populations, 

40 but the archaeological evidence is inconclusive. 
Affected Environment 

Draft NUREG-1437, Supplement 40 2-56 February 2010 

1 Historic Period

2 At the time of the first European contact (1600 to 1650), eastern Wisconsin was occupied by 

3 several American Indian groups (Ho-Chunk (Winnebago), Potawatomi, Menominee, and 

4 Chippewa). American Indian communities in the east were forced west due to ecological shifts 

5 (Cronon, 1983), societal collapse, and disease. Encroaching European settlement created 

6 waves of population shifts as these tribal groups pushed north and westward (Bragdon, 2001). 

7 Wisconsin tribal groups, responding to these pressures, shifted their areas of use to around 

8 Wisconsin, Michigan, and other areas of the Midwest. 

9 The first European known to have visited the area was Jean Nicolet, a French explorer, who 

10 reached the Green Bay region in 1634 (AEC, 1972). Green Bay was subsequently established 

11 as the first French fur trading settlement, and a number of other trading posts were established 

12 throughout the late 1600s and 1700s. Father Marquette said his First Mass on All Saints Day, 

13 November 1, 1674, in Kewaunee County (Kewaunee County, 2009). French influence continued 

14 until the end of the French and Indian War. As the French withdrew from the western Great 

15 Lakes, items of British manufacture replaced French trade goods in Native American 

16 communities (C. Mason, 1997). Throughout the historic period, American Indian economies 

17 were supplanted or supplemented by an emphasis on hunting for the fur trade. European trade 

18 goods increasingly replaced traditional tools and utensils. 

19 The United States acquired ownership of the northern Midwest at the close of the American 

20 Revolution, but de facto control remained with the British until the War of 1812 (AEC, 1972). 

21 Wisconsin was sparsely settled by Europeans prior to becoming a U.S. territory. Lead mining 

22 drew the first wave of Euro-American immigrants to southwestern Wisconsin in the 1820s. In 

23 1834, Wisconsin was surveyed and opened to Euro-American settlers. The fur trade, which had 

24 been a lucrative enterprise for the French, declined rapidly in the 1830s. During this time, the 

25 region was heavily forested. Settlement began in earnest when the lumber industry was started 

26 and the streams were dammed for water power. The vast forests of pine and larchwood led to 

27 shipbuilding. In 1848, Wisconsin became a State. Toward the end of the 19th century, farm 

28 settlement in the region followed the lumber industry (AEC, 1972). 

29 The Potawatomi tribe lived in the area that is presently Door, Kewaunee, and Manitowoc 

30 counties for hundreds of years before Europeans began settling in Wisconsin. The Potawatomi 

31 are Algonquin speakers and are Neshnabek, a Potawatomi word that refers to “original people” 

32 (Forest County Potawatomi, 2009). A major village, Ma-kah-da-we-kah-mich-(cock), also known 

33 as Black Earth, was located 3.5 miles west of the plant site, on what is now the East Twin River 

34 (DEK, 2008). It was there that members of the tribe would plant crops of corn, beans, pumpkins, 

35 and squash. Each spring, the Potawatomi would establish a camp in Sandy Bay Creek, located 

36 on the northern edge of the KPS property (DEK, 2008). It was at this camp where the 

37 Potawatomi would fish during the annual spawning runs, primarily for suckers (Bach, 1933). 

38 This area was used for hunting and gathering purposes until 1862, when the tribe was forced 

39 from their land by the U.S. government for non-payment of taxes (AVD, 2007). The burial 

40 ground for the tribe was also located here. (KCHS, 2002) 

41 Kewaunee County was created in 1850s from Manitowoc County, and was divided into three 

42 towns, Sandy Bay, Wolf River, and Kewaunee (Kewaunee County undated). The southernmost 

43 town, Sandy Bay, was named for the little indenture in the shore of Lake Michigan. The town 
Affected Environment 

 

February 2010 2-57 Draft NUREG-1437, Supplement 40 

1 originally consisted of the present-day limits of Carlton and Franklin (Kewaunee County 

2 undated). During the mid to late 1800s, Sandy Bay was a thriving village, with a productive 

3 sawmill (using a dam erected on Fischer Creek), a general store, cheese factory, post office, 

4 and hotel (KCHS, 2002). The large pier at Sandy Bay served as the center for shipping in the 

5 area, where lumber, bark (for tanning), and farmers’ crops were shipped to Milwaukee and 

6 Chicago. St. John’s Lutheran Church and cemetery and the Sandy Bay School were also part of 

7 the Sandy Bay Community. St. John’s was founded in 1869 and disbanded in 1947. The church 

8 was located on Route 42, but no longer exists. The cemetery is a Wisconsin Historical Resource 

9 and is currently owned and maintained by the Town of Carlton. Sandy Bay School was located 

10 across Route 42 from the church, and was in use until the 1960s. The schoolhouse was torn 

11 down in the 1960s to make way for the construction of KPS. By 1891, the settlement had all but 

12 disappeared. The only remnants from the community are the cemetery and a number of rotting 

13 pilings from the pier, which are visible from the shore by the mouth of Sandy Bay Creek (DEK 

14 2008). 

15 2.2.9.2 Historic and Archaeological Resources at the Kewaunee Power Station Site 

16 Most of the land at KPS was used for agricultural purposes. During the 1960s, land was 

17 acquired from 12 families to build KPS. The only remnants onsite from the farms are stretches 

18 of old barbed wire scattered around the site, part of the back end of an old threshing machine, a 

19 farm bridge north of the plant, and a bridge of unknown origin southwest of the plant (DEK, 

20 2008). As noted earlier, the Sandy Bay school house was also located onsite, but was torn 

21 down due to the construction of KPS. 

22 During the early to mid-1900s, Joe Krofta owned land approximately one-quarter mile south of 

23 the KPS plant. He planted a grove of trees in the area, and in 1931, built a small cabin. When 

24 KPS went into operation, the previous owners established the Kewaunee School Forest, which 

25 was used as an outdoor classroom for the county’s schools (DEK, 2008). During the 1980s, the 

26 lake level rose to historic high levels resulting in severe erosion. The cabin was about to 

27 collapse into Lake Michigan, and the plant’s owner at the time salvaged the front facade of the 

28 cabin and moved it to its current location. In 1987, the forest was renamed Joe Krofta Memorial 

29 Forest (DEK, 2008). 

30 In 2007, DEK contracted with AVD Archaeological Services, Inc. (AVD) to conduct a Phase 1 

31 Archaeological Survey and literature review for the KPS site. Land disturbed during construction 

32 of KPS was not surveyed. A majority of the remaining land is leased agricultural cropland. A 

33 search of the Wisconsin records found only 141 historic and archaeological sites in Kewaunee 

34 County compared with more than 500 sites each for bordering Manitowoc, Brown, and Door 

35 counties (AVD, 2007). In addition, there are no eligible or listed NRHP properties located on the 

36 KPS site. 

37 2.3 RELATED FEDERAL AND STATE ACTIVITIES 

38 The NRC staff reviewed the possibility that activities of other Federal agencies might impact the 

39 renewal of the operating license for the KPS. Any such activity could result in cumulative 

40 environmental impacts and the possible need for a Federal agency to become a cooperating 

41 agency in the preparation of the KPS SEIS. 
Affected Environment 

Draft NUREG-1437, Supplement 40 2-58 February 2010 

1 The NRC has determined that there are no Federal projects that would make it desirable for 

2 another Federal agency to become a cooperating agency in the preparation of the SEIS. There 

3 are no federal lands, facilities, national wildlife refuges, forests, and parks within 50 miles of the 

4 KPS. However, Two Creeks Buried Forest State Natural Area, a unit of the Ice Age National 

5 Scientific Reserve, is located approximately one mile south of the KPS property. The Reserve is 

6 a separate affiliated area of the National Park Service. 

7 NRC is required under Section 102(2)(c) of the National Environmental Policy Act of 1969 to 

8 consult with and obtain the comments of any Federal agency that has jurisdiction by law or 

9 special expertise with respect to any environmental impact involved. NRC has consulted with 

10 the USFWS, Advisory Council on Historic Preservation, Wisconsin Historical Society, Wisconsin 

11 Coastal Management Program, WDNR, Menominee Indian Tribe of Wisconsin, and 23 other 

12 Native American Tribes listed in Section 1.8 and Appendix E. Federal Agency consultation 

13 correspondence and comments on the SEIS are presented in Appendix D. 

14 2.4 REFERENCES 

15 10 CFR Part 20. Code of Federal Regulations, Title 10, Energy, Part 20, “Standards for 

16 Protection Against Radiation.” 

17 10 CFR Part 50. Code of Federal Regulations, Title 10, Energy, Part 50, “Domestic Licensing of 

18 Production and Utilization Facilities.” 

19 10 CFR Part 61. Code of Federal Regulations, Title 10, Energy, Part 61, “Licensing 

20 Requirements for Land Disposal of Radioactive Waste.” 

21 U.S. Atomic Energy Commission (AEC). 1972. Final Environmental Statement Related to the 

22 Operation of Kewaunee Nuclear Power Plant. Wisconsin Public Service Corporation. Docket 

23 No. 50-305. Directorate of Licensing. Washington, D.C. December 1972. ADAMS Accession 

24 No. ML082820122. 

25 AVD Archaeological Services, Inc (AVD). 2007. Phase I Archaeological Survey at the 

26 Kewaunee Power Station in Kewaunee County, Wisconsin. Prepared for Dominion Energy 

27 Kewaunee, Kewaunee, Wisconsin. [Non-public document, withheld per 36 CFR 800.11(c)] 

28 Bach, W.H. 1933. “60 Years ago – Some Reminiscences by W.H. Bach, and Old Time 

29 Resident.” Available URL: 

30 http://www.wisconsinhistory.org/wlhba/articleView.asp?pg=1&id=7853&hdl=&np=Kewaunee+En

31 terprise&adv=yes&In=&fn=&q=&y1=&y2=&ci=&co=&mhd=&shd= (accessed July 2009). 

32 [Copyright protected] 

33 Bay-Lake Regional Planning Commission. 2005. “Bay-Lake Regional 2030 Regional 

34 Comprehensive Plan.” November 2005. Available URL: 

35 http://www.baylakerpc.org/REGIONALPLAN/Final/Bay36 Lake%20Regional%202030%20Comprehensive%20Plan.pdf (accessed July 2009). ADAMS 

37 Accession No. ML093250004. 

38 Bay-Lake Regional Planning Commission. 2007. “Kewaunee County 20-Year Comprehensive 

39 Plan.” November 2005. Available URL: 

40 http://www.baylakerpc.org/Documents/Kewaunee_County/Kewaunee_County_Comp_Plan_Nov

41 ember_2007.pdf (accessed July 2009). ADAMS Accession No. ML093250005. 
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February 2010 2-59 Draft NUREG-1437, Supplement 40 

1 Bragdon, K. J. 2001. The Columbia Guide to American Indians of the Northeast. New York: 

2 Columbia University Press. [Copyright protected] 

3 Brandt, S. 2004. Effects of Diporeia Declines on Fish Diet, Growth and Food Web Dynamics in 

4 Southeast Lake Michigan. Great Lakes Environmental Research Laboratory, National Oceanic 

5 and Atmospheric Administration. Available URL: 

6 http://www.glerl.noaa.gov/res/Task_rpts/1998/edybrandt09-3.html (accessed November 4, 

7 2008). ADAMS Accession No. ML093250006 

8 Brent, R., J. Schofield, and K. Miller. 2001. Results of the Lake Michigan Mass Balance Study: 

9 Atrazine Data Report. U.S. EPA Great Lakes National Program Office, EPA 905R-01-010. 

10 Available URL: http://www.epa.gov/glnpo/lmmb/results/atra_final.pdf (accessed May 18, 2009). 

11 ADAMS Accession No. ML093250007. 

12 Cornell Lab of Ornithology (Cornell). 2003. "Peregrine Falcon." Available URL: 

13 http://www.birds.cornell.edu/AllAboutBirds/BirdGuide/PeregrineFalcondtl.html (accessed June 6, 

14 2008). ADAMS Accession No. ML073300303. 

15 Crawford, S. S. 2001. Salmonine Introductions to the Laurentian Great Lakes: An Historical 

16 Review and Evaluation of Ecological Effects. Executive Summary. Canadian Special Publication 

17 of Fisheries and Aquatic Sciences. Available URL: 

18 http://www.uoguelph.ca/~scrawfor/research/research_greatlakes/research_greatlakes_fisheries/

19 research_greatlakes_fisheries_issues/research_greatlakes_fisheries_issues_salmon_monogra

20 ph.shtml (accessed July 15, 2009). ADAMS Accession No. ML093250009. 

21 Cronon, W. 1983. Changes in the Land: Indians, Colonists, and the Ecology of New England. 

22 New York: Hill and Wang. [Copyright protected] 

23 Crowder, L.B. 1980. Alewife, Rainbow Smelt, and Native Fishes in Lake Michigan: Competition 

24 or Predation? Environmental Biology of Fishes, 5(3): 225-233. 

25 Dominion Energy Kewaunee, Inc. (DEK). 1968. WDNR Well Installation Forms. Wisconsin 

26 Department of Natural Resources. ADAMS Accession No. ML091970509. 

27 Dominion Energy Kewaunee, Inc. (DEK). 2005. 2004 Annual Radioactive Effluent Release 

28 Report. Kewaunee, Wisconsin. ADAMS Accession No. ML051230416. 

29 Dominion Energy Kewaunee, Inc. (DEK). 2006. 2005 Annual Radioactive Effluent Release 

30 Report. Kewaunee, Wisconsin. ADAMS Accession No. ML061240156. 

31 Dominion Energy Kewaunee, Inc. (DEK). 2007. 2006 Annual Radioactive Effluent Release 

32 Report. Kewaunee, Wisconsin. ADAMS Accession No. ML071220274. 

33 Dominion Energy Kewaunee, Inc. (DEK). 2007a. DNR Drinking Water System: High Capacity 

34 Wells. ADAMS Accession No. ML091970509. 

35 Dominion Energy Kewaunee, Inc. (DEK). 2007b. Kewaunee Power Station Updated Safety 

36 Analysis Report, Revision 20. ADAMS Accession No. ML071150379.

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

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

39 Power Station. Docket No. 50-305. August 2008. ADAMS Accession No. ML082341039. 
Affected Environment 

Draft NUREG-1437, Supplement 40 2-60 February 2010 

1 Dominion Energy Kewaunee, Inc. (DEK). 2008a. 2007 Annual Radioactive Effluent Release 

2 Report. Kewaunee, Wisconsin. ADAMS Accession No. ML081230068. 

3 Dominion Energy Kewaunee, Inc. (DEK). 2008b. 2007 Annual Radioactive Effluent Release 

4 Report Offsite Dose Calculation Manual. Kewaunee, Wisconsin. ADAMS Accession No. 

5 ML082190067. 

6 Dominion Energy Kewaunee, Inc. (DEK). 2008c. Application for Renewed Operating License, 

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

8 ML082341020, ML082341038, ML082420854. 

9 Dominion Energy Kewaunee, Inc. (DEK). 2008d. KPS System Description: Circulating Water 

10 System (CW). March 2008. ADAMS Accession No. ML091970509. 

11 Dominion Energy Kewaunee, Inc. (DEK). 2009. 2008 Annual Radioactive Effluent Release 

12 Report. Kewaunee, Wisconsin. ADAMS Accession No. ML081230068. 

13 Dominion Energy Kewaunee, Inc. (DEK). 2009a. Kewaunee Power Station Potable Water Use 

14 Documentation. ADAMS Accession No. ML091970509. 

15 Dominion Energy Kewaunee, Inc. (DEK). 2009b. Kewaunee Power Station Radiological 

16 Environmental Monitoring Manual (REMM). May 2009. ADAMS Accession No. ML091970515. 

17 Dominion Energy Kewaunee, Inc. (DEK). 2009c. Response to Request to Docket Information 

18 Related to the Environmental Site Audit for Kewaunee Power Station. July 6, 2009. ADAMS 

19 Accession No. ML091970512. 

20 Dominion Energy Kewaunee, Inc. (DEK). 2009d. Response To Request to Docket Information 

21 Related To The Environmental Site Audit for Kewaunee Power Station. Enclosure A – 

22 Meteorology and Air Compliance. ADAMS Accession No. ML09190514. 

23 Dominion Energy Kewaunee, Inc. (DEK). 2009e. Response to Request to Docket Information 

24 Related to the Environmental Site Audit for Kewaunee Power Station – Enclosure E 

25 Nonradiological Waste. Richmond, VA. ADAMS Accession No. ML091970529. 

26 Dominion Energy Kewaunee, Inc.(DEK). 2009f. Stormwater Pollution Prevention Plan (SWPPP) 

27 for the Kewaunee Power Station. April 2009. ADAMS Accession No. ML091970509. 

28 EA Engineering, Science, and Technology, Inc. (EA Engineering). 2007. Impingement Mortality 

29 and Entrainment Characterization Report, Kewaunee Power Station, March 2006 – February 

30 2007. Prepared for Dominion Resources Services, Inc., Glen Allen, Virginia. ADAMS Accession 

31 No. ML083520612. 

32 Environmental Protection Agency (EPA). 1974. "Information on Levels of Environmental Noise 

33 Requisite to Protect Public Health and Welfare with an Adequate Margin of Safety." Report 

34 550/9-74-004, Washington, D.C. Available URL: 

35 http://www.nonoise.org/library/levels74/levels74.htm (accessed March 2, 2009). (See also "EPA 

36 Identifies Noise Levels Affecting Health and Welfare." September 21, 2007. Available URL: 

37 http://www.epa.gov/history/topics/noise/01.htm). ADAMS Accession No. ML093250012. 

38 Environmental Protection Agency (EPA). 1992. “Great Lakes Fact Sheet No. 1: Physical 

39 Features and Population.” Available URL: http://www.epa.gov/glnpo/atlas/gl-fact1.html

40 (accessed October 1, 2008). ADAMS Accession No. ML093250013. 
Affected Environment 

 

February 2010 2-61 Draft NUREG-1437, Supplement 40 

1 Environmental Protection Agency (EPA). 2007a. “Hazardous Waste Generators Regulations.” 

2 May. Available URL: http://www.epa.gov/osw/hazard/downloads/tool.pdf (accessed October 14, 

3 2008). ADAMS Accession No. ML082880301. 

4 Environmental Protection Agency (EPA). 2007b. “Wastes – Laws and Regulations.” Available 

5 URL: http://www.epa.gov/osw/laws-regs/index.htm (accessed August 20, 2009). ADAMS 

6 Accession No. ML082880301. 

7 Environmental Protection Agency (EPA). 2008. Approval and Promulgation of Implementation 

8 Plans and Designation of Areas for Air Quality Planning Purposes; Wisconsin; Redesignation of 

9 Kewaunee County to Attainment of Ozone; Final Rule. Federal Register, Vol. 73, No. 99, pp. 

10 29436-29444. 

11 Environmental Protection Agency (EPA). 2008a. “The Great Lakes: An Environmental Atlas and 

12 Resource Book. Factsheet 1.” Jointly produced by the Government of Canada and the U.S. 

13 Environmental Protection Agency. Available URL: http://www.epa.gov/glnpo/atlas/gl-fact1.html

14 (accessed July 2009). ADAMS Accession No. ML093250014. 

15 Environmental Protection Agency (EPA). 2008b. “The Great Lakes: An Environmental Atlas and 

16 Resource Book. The Great Lakes Today: Concerns.” Jointly produced by the Government of 

17 Canada and the U.S. Environmental Protection Agency. Available URL: 

18 http://www.epa.gov/glnpo/atlas/glat-ch4.html (accessed July 2009). ADAMS Accession No. 

19 ML093250015. 

20 Environmental Protection Agency (EPA). 2008c. “Invasive Species: Asian Carp and the Great 

21 Lakes.” Available URL: http://www.epa.gov/glnpo/invasive/asiancarp/ (accessed November 4, 

22 2008). ADAMS Accession No. ML093250016. 

23 Environmental Protection Agency (EPA). 2008d. “Lake Michigan Lake Wide Management Plan 

24 (LaMP) 2008.” Available URL: http://www.epa.gov/greatlakes/lamp/lm_2008/lm_2008.pdf

25 (accessed May 18, 2009). ADAMS Accession No. ML093250017. 

26 Environmental Protection Agency (EPA). 2008e. “Lower Fox River and Green Bay Area of 

27 Concern.” Available URL: http://www.epa.gov/glnpo/aoc/greenbay.html (accessed May 18, 

28 2009). ADAMS No. ML093250018. 

29 Environmental Protection Agency (EPA). 2008f. “Pollution Prevention Information 

30 Clearinghouse (PPIC).” Available URL: http://www.epa.gov./oppt/ppic/ (accessed August 20, 

31 2009). ADAMS Accession No. ML082880301. 

32 Environmental Protection Agency (EPA). 2009. “EPA Green Book Nonattainment Areas for 

33 Criteria Pollutants.” Available URL: http://www.epa.gov/air/oaqps/greenbk/index.html (accessed 

34 May, 2009). ADAMS No. ML093250019. 

35 Environmental Protection Agency and Environment Canada (EPA and Environment Canada). 

36 1997. “The Great Lakes Binational Toxics Strategy.” Available URL: 

37 http://binational.net/bns/2007/2007GLBTS_en.pdf (accessed July 20, 2009). ADAMS Accession 

38 No. ML093250020. 

39 Environmental Protection Agency and Environment Canada (EPA and Environment Canada). 

40 2007. “Great Lakes Binational Toxics Strategy: 2007 Annual Progress Report.” Available URL: 
Affected Environment 

Draft NUREG-1437, Supplement 40 2-62 February 2010 

1 http://binational.net/bns/strategy_en.pdf (accessed July 20, 2009). ADAMS Accession No. 

2 ML093250021. 

3 Forest County Potawatomi. 2009. “Forest County Potawatomi History.” Forest County 

4 Potawatomi, Crandon, Wisconsin. Available URL: 

5 http://www.fcpotawatomi.com/index.php/Treaties/history-overview.html [Copyright protected] 

6 Fuller, P., E. Maynard, and D. Raikow. 2007. “Alosa pseudoharengus.” USGS Nonindigenous 

7 Aquatic Species Database. Available URL: 

8 http://nas.er.usgs.gov/queries/FactSheet.asp?speciesID=490 (accessed January 6, 2009). 

9 ADAMS Accession No. ML093250022. 

10 Great Lakes Commission (GLC). 2000. “Assessment of the Lake Michigan Monitoring Inventory: 

11 A Report on the Lake Michigan Tributary Monitoring Project.” Available URL: 

12 http://www.glc.org/monitoring/lakemich/pdf/full_report.PDF (accessed October 1, 2008). ADAMS 

13 Accession No. ML093250029. 

14 Great Lakes Fishery Commission (GLFC). 1997. Joint Strategic Plan for Management of Great 

15 Lakes Fisheries. Miscellaneous Publication 2007-01. GLFC: Ann Arbor, Michigan. Available 

16 URL: http://www.glfc.org/fishmgmt/jsp97.pdf (accessed July 13, 2009). ADAMS Accession No. 

17 ML093250030. 

18 Great Lakes Fishery Commission (GLFC). 2009. “Great Lakes Fishery Commission.” Available 

19 URL: http://www.glfc.org/ (accessed July 13, 2009). ADAMS Accession No. ML093250031. 

20 Goldstein, L., and J. Freeman. 1997. "Aztalan - A Middle Mississippian Village." The Wisconsin 

21 Archaeologist, Vol. 78, Numbers 1 and 2, pp. 223-248. [Copyright protected] 

22 Green, W. 1997. “The Middle Mississippian Peoples.” Wisconsin Archaeology, Chapter 8. The 

23 Wisconsin Archaeological Society, The Wisconsin Archaeologist, Vol.78, Numbers 1 and 2, pp. 

24 202-222. [Copyright protected] 

25 Institute of Educational Science (IES). 2009. U.S. Department of Education, National Center for 

26 Educational Statistics. “College Opportunities Online Locator.” Zip Code 54216. Data release 

27 date March 6, 2009. Available URL: http://nces.ed.gov/ipeds/cool/RefineSearch.aspx (accessed 

28 July 2009). ADAMS Accession No. ML093250032. 

29 International Joint Commission (IJC). 2006. Thirteenth Biennial Report on Great Lakes Water 

30 Quality. Available URL: http://ijc.org:8080/glro/glro-web/resources/biennial31 reports/BRGLWQ_13.pdf (accessed July 13, 2009). ADAMS Accession No. ML093250033. 

32 Kewaunee County Historical Society (KCHS). 2002. Background for Historical Markers. 

33 Compiled information by Donna Urban. March 2002. [Copyright protected] 

34 Kewaunee County 2009. “Kewaunee County Genealogy and History.” Available URL: 

35 http://www.rootsweb.ancestry.com/~wikewaun/ (accessed July 2009). [Copyright protected] 

36 Lehman, J.T. 1991. Causes and Consequences of Cladoceran Dynamics in Lake Michigan: 

37 Implications of Species Invasion by Bythotrephes. J. Great Lakes Res., Vol. 17, pp. 437-445. 

38 Liebig, J., and A. Benson. 2007. Bythotrephes longimanus. Nonindigenous Aquatic Species 

39 Database, Gainesville, Florida. Available URL: 

40 http://nas.er.usgs.gov/queries/FactSheet.asp?speciesID=162 (accessed July 13, 2009). 

41 ADAMS Accession No. ML093250034. 
Affected Environment 

 

February 2010 2-63 Draft NUREG-1437, Supplement 40 

1 Madenjian, C.P., G.L. Fahnenstiel, T.H. Johengen, T.F. Nalepa, H.A. Vanderploeg, G.W. 

2 Fleischer, P.J. Schneeberger, D.M. Benjamin, E.B. Smith, J.R. Bence, E.S. Rutherford, D.S. 

3 Lavis, D.M. Robertson, D.J. Jude, and M.P. Ebener. 2002. Dynamics of the Lake Michigan Food 

4 Web, 1970-2000. Canadian Journal of Fisheries and Aquatic Sciences, Vol. 59, pp. 736-753. 

5 Makarewicz, J.C., T. Lewis, and P. Bertram. 1994. Epilimnetic Phytoplankton and Zooplankton 

6 Biomass and Species Composition in Lake Michigan, 1983 to 1992. U.S. Environmental 

7 Protection Agency, Great Lakes National Program, Chicago, Illinois. Available URL: 

8 http://www.epa.gov/glnpo/monitoring/plankton/mich83-92/index.html (accessed July 13, 2009). 

9 ADAMS Accession No. ML093250035. 

10 Mason, C. l. 1997. The Historic Period in Wisconsin Archaeology, Native Peoples. The 

11 Wisconsin Archaeologist, Vol. 78, Numbers 1 and 2, pp. 293-319. [Copyright protected] 

12 Mason, R. J. 1997. The Paleo-lndian Tradition. The Wisconsin Archaeologist, Vol. 78, Numbers 

13 1 and 2, pp. 78-i 10. [Copyright protected] 

14 Mason, R. J. 1981. Great Lakes Archaeology. New York: Academic Press, Inc. [Copyright 

15 protected] 

16 McCarty, H., K. Miller, R. Brent, J. Schofield, and R. Rossmann. 2004. Results of the Lake 

17 Michigan Mass Balance Study: Mercury Data Report. U.S. EPA Great Lakes National Program 

18 Office, EPA 905 R-01-012. February 2004. 

19 McCarty, H., J. Schofield, K. Miller, and R. Brent. 2004a. Results of the Lake Michigan Mass 

20 Balance Study: Polychlorinated Biphenyls and trans-Nonachlor Data Report. U.S. EPA Great 

21 Lakes National Program Office, EPA 905 R-01-011. Available URL: 

22 http://www.epa.gov/glnpo/lmmb/results/pcb/lmmbpcb.pdf (accessed May 18, 2009). ADAMS 

23 Accession No. ML093250036. 

24 National Climatic Data Center (NCDC). 2009. Historical climate data, 1971–2000 NCDC 

25 normals, Precipitation Summary, 474195 Kewaunee Station, Wisconsin. ADAMS Accession No. 

26 ML091960148. 

27 National Climatic Data Center (NCDC). 2009a. Historical climate data, 1971–2000 NCDC 

28 normals, Temperature Summary, 474195 Kewaunee Station, Wisconsin. ADAMS Accession 

29 No. ML091960128. 

30 National Climatic Data Center (NCDC). 2009b. Flood events in Wisconsin, 1950–2009. 

31 Available URL: http://www4.ncdc.noaa.gov/cgi-win/wwcgi.dll?wwevent~storms (accessed July, 

32 2009). ADAMS Accession No. ML091960114. 

33 National Climatic Data Center (NCDC). 2009c. Tornado activities in Kewaunee County, 

34 Wisconsin. Available URL: http://www4.ncdc.noaa.gov/cgi-win/wwcgi.dll?wwevent~storms

35 (accessed July, 2009). ADAMS Accession No. ML091960104 

36 Nalco Environmental Sciences (NES). 1976a. Kewaunee Nuclear Power Plant 316(a) 

37 Demonstration, Type 1: Absence of Prior Appreciable Harm. ADAMS Accession No. 

38 ML08520612. 
Affected Environment 

Draft NUREG-1437, Supplement 40 2-64 February 2010 

1 Nalco Environmental Sciences (NES). 1976b. Kewaunee Nuclear Power Plant 316(b) 

2 Demonstration: Environmental Effects of Existing Cooling Water Intake Structures. ADAMS 

3 Accession No. ML083520612. 

4 National Park Service (NPS). 2009a. “National Register of Historic Places Information System, 

5 Kewaunee County, Wisconsin.” Available URL: www.nr.nps.gov (accessed August 3, 2009). 

6 National Park Service (NPS). 2009b. “National Register of Historic Places Information System, 

7 Manitowoc County, Wisconsin.” Available URL: www.nr.nps.gov (accessed August 5, 2009). 

8 Overstreet, D. F. 1997. Oneota Prehistory and History. The Wisconsin Archaeologist, Vol. 78, 

9 Numbers 1 and 2, pp. 250-296. [Copyright protected] 

10 Platt, J. 2009. “Quagga Terror: Alien Mussels in U.S. Waters Cause Problems for Other 

11 Species.” Scientific American Online. March 16, 2009. Available URL: 

12 http://www.scientificamerican.com/blog/60-second-science/post.cfm?id=quagga-terror-alien13 mussels-in-us-w-2009-03-16 (accessed July 15, 2009). ADAMS Accession No. ML093250037. 

14 State of Wisconsin, Department of Workforce Development (DWD). 2006. “Kewaunee County 

15 Workforce Profile.” December 2006. Available URL: 

16 http://www.dwd.state.wi.us/oea/county_profiles/archived/2006/kewaunee_profile_2006.pdf 

17 (accessed July 2009). ADAMS Accession No. ML093250011. 

18 Stevenson, K. P., R. F. Boszhardt, C. R. Moffat, P. H. Salkin, T. C. Pleger, J. L. Theler, and C. 

19 M. Arzigian. 1997. The Woodland Tradition. The Wisconsin Archaeologist, Vol. 78, Numbers 1 

20 and 2, pp. 140-201. [Copyright protected] 

21 Stoltman, J. B. 1997. The Archaic Tradition. The Wisconsin Archaeologist, Vol. 78, Numbers 1 

22 and 2, pp. 112-139. [Copyright protected] 

23 STS Consultants, Ltd (STS). 2007. Report of Well Installation Services. Dominion Energy 

24 Kewaunee Power Station. August 2007. ADAMS Accession No. ML091970515. 

25 U.S. Census Bureau (USCB). 2009. “American Community Survey of Kewaunee County, 

26 Manitowoc County, and Brown County, Wisconsin, Data Profile Highlights. 2005-2007 American 

27 Community Survey 3-Year Estimates.” Available URL: http://factfinder.census.gov (accessed 

28 July 2009). 

29 U.S. Census Bureau (USCB). 2009a. “American FactFinder, Census 2000 and 2005-2007, 3-

30 Year Estimate, American Community Survey, QuickFacts on Kewaunee, Manitowoc, and Brown 

31 Counties. Housing Characteristics for 2000 and 2005-2007, 3-Year Estimate.” Available URL: 

32 http://factfinder.census.gov and http://quickfacts.census.gov (accessed July 2009). 

33 U.S. Census Bureau (USCB). 2009b. “Decennial Census 1900 to 1990 and 2000 Data and 

34 American FactFinder, American Community Survey of Kewaunee County, Manitowoc County, 

35 and Brown County, Wisconsin, Data Profile Highlights. 2005–2007 American Community 

36 Survey 3-Year Estimates.” Available URL: http://factfinder.census.gov (accessed July 2009). 

37 U.S. Census Bureau (USCB). 2009c. “State and County QuickFacts for Kewaunee County and 

38 Manitowoc County, Wisconsin.” Available URL: http://quickfacts.census.gov (accessed July 

39 2009). 

40 U.S. Department of Agriculture (USDA). 2009. “2007 Census of Agriculture. Iowa, Kansas, 

41 Missouri, Nebraska.” Released February 4, 2009. Available URL: 
Affected Environment 

 

February 2010 2-65 Draft NUREG-1437, Supplement 40 

1 http://www.agcensus.usda.gov/Publications/2007/Online_Highlights/County_Profiles/index.asp 

2 (accessed April 17, 2009). ADAMS Accession No. ML093250038. 

3 U.S. Fish and Wildlife Service (USFWS). 2008. “County Distribution of Wisconsin’s Federally 

4 Threatened, Endangered, Proposed, and Candidate Species.” November 2008. Available URL: 

5 http://www.fws.gov/Midwest/Endangered/lists/wisc08cty.pdf (accessed January 6, 2009). 

6 ADAMS No. ML093250023. 

7 US Fish and Wildlife Service (USFWS). 2008a. Letter to the NRC regarding the Renewal 

8 Application Review of Kewaunee Power Station, Kewaunee County, Wisconsin. October 28, 

9 2008. ADAMS Accession No. ML 083390643. 

10 U.S. Fish and Wildlife Service (USFWS). 2008b. "Osprey: Pandion haliaetus." Available URL: 

11 http://www.fws.gov/chesapeakebav/osprey.html (accessed May 15, 2009). ADAMS No. 

12 ML082880486. 

13 U.S. Fish and Wildlife Service (USFWS). 2009. “Hines Emerald Dragonfly. Factsheet.” Available 

14 URL: http://www.fws.gov/Midwest/endangered/insects/hed/hins_fct.html (accessed August 9, 

15 2009). ADAMS Accession No. ML093250024. 

16 U.S. Fish and Wildlife Service (USFWS). 2009a. “Piping Plover. Atlantic Coast Population.” 

17 Available URL: http://www.fws.gov/northeast/pipingplover/ (accessed August 9, 2009). ADAMS 

18 Accession No. ML093250025. 

19 U.S. Fish and Wildlife Service (USFWS). 2009b. “U.S. Fish and Wildlife Service. Threatened 

20 and Endangered Species. Dwarf lake iris. Factsheet.” Available URL: 

21 http://www.fws.gov/Midwest/Endangered/plants/pdf/dwarf-lake-iris.pdf (accessed August 9, 

22 2009). ADAMS Accession No. ML093250026. 

23 U.S. Fish and Wildlife Service (USFWS). 2009c. “U.S. Fish and Wildlife Service. Threatened 

24 and Endangered Species. Karner Blue Butterfly. Factsheet.” Available URL: 

25 http://www.fws.gov/Midwest/endangered/insects/kbb/kbbFactSheet.pdf (accessed August 9, 

26 2009). ADAMS Accession No. ML093250027. 

27 U.S. Fish and Wildlife Service (USFWS). 2009d. “U.S. Fish and Wildlife Service. Threatened 

28 and Endangered Species. Pitcher Thistle. Factsheet.” Available URL: 

29 http://www.fws.gov/Midwest/Endangered/plants/pdf/Pitchersthistle.pdf (accessed August 9, 

30 2009). ADAMS Accession No. ML093250028. 

31 U.S. Geological Survey (USGS). Undated. "Biological and Ecotoxicological Characteristics of 

32 Terrestrial Vertebrate Species Residing in Estuaries – Osprey." ADAMS Accession No. 

33 ML091350285. 

34 U.S. Geological Survey (USGS). 2008. “Sea Lamprey.” Available URL: 

35 http://www.glsc.usgs.gov/main.php?content=research_lamprey&title=Invasive%20Fish0&menu=

36 research_invasive_fish (accessed November 4, 2008). ADAMS Accession No. ML093250040. 

37 University of Wisconsin Sea Grant Institute (UWSGI). 2002. “Fish of the Great Lakes: Brown 

38 Trout.” Available URL: http://www.seagrant.wisc.edu/greatlakesfish/browntrout.html (accessed 

39 November 4, 2008). ADAMS Accession No. ML093250041. 
Affected Environment 

Draft NUREG-1437, Supplement 40 2-66 February 2010 

1 University of Wisconsin Sea Grant Institute (UWSGI). 2002a. “Fish of the Great Lakes: Carp.” 

2 Available URL: http://www.seagrant.wisc.edu/greatlakesfish/carp.html (accessed November 4, 

3 2008). ADAMS Accession No. ML093250042. 

4 University of Wisconsin Sea Grant Institute (UWSGI). 2002b. “Fish of the Great Lakes: Fish of 

5 Lake Michigan.” Available URL: 

6 http://www.seagrant.wisc.edu/greatlakesfish/LakeMichFishIndex.html (accessed November 4, 

7 2008). ADAMS Accession No. ML093250043. 

8 University of Wisconsin Sea Grant Institute (UWSGI). 2002c. “Fish of the Great Lakes: Rainbow 

9 Smelt.” Available URL: http://www.seagrant.wisc.edu/greatlakesfish/rainbowsmelt.html

10 (accessed November 4, 2008). ADAMS Accession No. ML093250044. 

11 Wells, L. 1970. Effects of Alewife Predation on Zooplankton Populations in Lake Michigan. 

12 Limnology and Oceanography, Vol. 15, 4:565-574. 

13 Wisconsin Department of Public Instruction (DPI). 2009. “Public School Enrollment Data 2009: 

14 Public Enrollment by District by School by Gender.” Available URL: 

15 http://dpi.wi.gov/lbstat/xls/pecog09.xls (accessed July 2009). ADAMS Accession No. 

16 ML093250010. 

17 Wisconsin Department of Natural Resources (WDNR). 2004. “Rainbow Smelt (Osmerus 

18 mordax).” Available URL: http://dnr.wi.gov/invasives/fact/rainbow_smelt.htm (accessed 

19 November 7, 2008). ADAMS Accession No. ML093250045. 

20 Wisconsin Department of Natural Resources (WDNR). 2004a. “Wisconsin Endangered and 

21 Threatened Species Laws & List.” February 2004. Available URL: 

22 http://dnr.wi.gov/ORG/LAND/ER/wlist/WI_ET_Laws_List.pdf (accessed January 6, 2009). 

23 ADAMS Accession No. ML093250046. 

24 Wisconsin Department of Natural Resources (WDNR). 2005. State of Wisconsin Department of 

25 Natural Resources Permit to Discharge Under the Wisconsin Pollutant Discharge Elimination 

26 System, Permit No. WI-0001571-07-0, Kewaunee Power Station, July 2005. ADAMS Accession 

27 No. ML083520612. 

28 Wisconsin Department of Natural Resources (WDNR). 2008. “Natural Heritage Inventory 

29 County Maps: Brown County.” Available URL: 

30 http://dnr.wi.gov/org/land/er/nhi/CountyMaps/pdfs/Brown_County.pdf (accessed January 6, 

31 2009). ADAMS Accession No. ML093250047. 

32 Wisconsin Department of Natural Resources (WDNR). 2008a. “Natural Heritage Inventory 

33 County Maps: Kewaunee County.” Available URL: 

34 http://dnr.wi.gov/org/land/er/nhi/CountyMaps/pdfs/Kewaunee_County.pdf (accessed January 6, 

35 2009). ADAMS Accession No. ML093250048. 

36 Wisconsin Department of Natural Resources (WDNR). 2008b. “Natural Heritage Inventory 

37 County Maps: Manitowoc County.” Available URL: 

38 http://dnr.wi.gov/org/land/er/nhi/CountyMaps/pdfs/Manitowoc_County.pdf (accessed January 6, 

39 2009). ADAMS Accession No. ML093250049. 

40 Wisconsin Department of Natural Resources (WDNR). 2008c. “Natural Heritage Inventory 

41 County Maps: Outagamie County.” Available URL: 
Affected Environment 

 

February 2010 2-67 Draft NUREG-1437, Supplement 40 

1 http://dnr.wi.gov/org/land/er/nhi/CountyMaps/pdfs/Outagamie_County.pdf (accessed January 6, 

2 2009). ADAMS Accession No. ML09325050. 

3 Wisconsin Department of Natural Resources (WDNR). 2009. “Choose Wisely: A Health Guide 

4 for Eating Fish in Wisconsin.” Available URL: 

5 http://dnr.wi.gov/fish/consumption/FishAdvweb09lo.pdf (accessed July 13, 2009). ADAMS 

6 Accession No. ML093250051. 

7 Wisconsin Department of Natural Resources (WDNR). 2009a. “Invasive Species. Animals.” 

8 Available URL: http://dnr.wi.gov/invasives/animals.asp (accessed August 9, 2009). ADAMS 

9 Accession No. ML093250052. 

10 Wisconsin Department of Natural Resources (WDNR). 2009b. “Invasive Species. Plants.” 

11 Available URL: http://dnr.wi.gov/invasives/plants.asp (accessed August 9, 2009). ADAMS 

12 Accession No. ML093250053. 

13 Wisconsin Department of Natural Resources (WDNR). 2009c. “Natural Communities of 

14 Wisconsin.” Available URL: http://www.dnr.wi.gov/org/land/er/communities/ (accessed August 9, 

15 2009). ADAMS Accession No. ML093250054. 

16 Wisconsin Department of Natural Resources (WDNR). 2009d. “Wisconsin Ecological 

17 Landscape Handbook. Grassland Communities.” Available URL: 

18 http://www.dnr.wi.gov/landscapes/pdfs/Grass.pdf (accessed August 9, 2009). ADAMS 

19 Accession No. ML093250055. 

20 Wisconsin Department of Natural Resources (WDNR). 2009e. “Wisconsin Ecological 

21 Landscape Handbook. Wetland Communities.” Available URL: 

22 http://www.dnr.wi.gov/landscapes/pdfs/Wet.pdf (accessed August 9, 2009). ADAMS Accession 

23 No. ML093250056. 

24 Wisconsin Department of Natural Resources (WDNR). 2009f. “Wisconsin’s Major Aquifers.” 

25 Available URL: http://www.dnr.state.wi.us/org/caer/ce/eek/teacher/groundwaterguide/P1213.pdf

26 (accessed August 2009). ADAMS Accession No. ML093250057. 

27 Wisconsin Department of Revenue (WDOR). 2007. “Shared Revenue Utility Payments.” 

28 Available URL: http://www.revenue.wi.gov/ (accessed on July 2009). 

29 Wisconsin Department of Revenue (WDOR). 2009. “County and Municipal Revenues and 

30 Expenditures – 2004 through 2007.” Available URL: http://www.revenue.wi.gov/report/r.html

31 (accessed July 2009). ADAMS Accession No. ML093250058. 

32 Wisconsin Department of Transportation (WDOT). 2009. “Travel Information – Traffic Count 

33 Maps by County.” Available URL: http://www.dot.wisconsin.gov/travel/counts/index.htm

34 (accessed July 2009). ADAMS Accession No. ML093250059. 

35 Wisconsin Natural Heritage Program (WNHP). 2006. “Wisconsin Natural Heritage Working List.” 

36 December 2006. Available URL: http://dnr.wi.gov/ORG/LAND/ER/wlist/Working_List_2006.pdf

37 (accessed January 6, 2009). 

 

February 2010 3-1 Draft NUREG-1437, Supplement 40 

1 3.0 ENVIRONMENTAL IMPACTS OF REFURBISHMENT

2 Facility owners or operators may need to undertake or, for economic or safety reasons, may 

3 choose to perform refurbishment activities in anticipation of license renewal or during the license 

4 renewal term. The major refurbishment class of activities characterized in the Generic 

5 Environmental Impact Statement (GEIS) (NRC 1996, 1999) is intended to encompass actions 

6 which typically take place only once in the life of a nuclear plant, if at all. Examples of these 

7 activities include, but are not limited to, replacement of boiling water reactor recirculation piping 

8 and pressurized water reactor steam generators. As noted in the GEIS, refurbishment activities 

9 could result in environmental impacts beyond those that occur during normal plant operations. 

10 Refurbishment activities may affect a variety of environmental issues as listed in 

11 Table 3-1. 
Environmental Impacts of Refurbishment 

Draft NUREG-1437, Supplement 40 3-2 February 2010 

1 Table 3-1. Issues Related to Refurbishment. Kewaunee Power Station (KPS) does not have 

2 any plans for refurbishment activities. 

3 Dominium Energy Kewaunee, Inc. (DEK) submitted to the U.S. Nuclear Regulatory Commission 

4 (NRC) an environmental report (ER) as part of its license renewal application for the Kewaunee 

5 Power Station (KPS) in August 2008. DEK addressed refurbishment activities in the ER (DEK, 

6 2008a), which is Attachment E of the license renewal application (DEK, 2008b). DEK states in 

7 the ER that the refurbishing assessment for KPS was done according to the regulations in 

Issues Category 

Surface Water Quality, Hydrology, and Use 

Impacts of refurbishment on surface water quality 1 

Impacts of refurbishment on surface water use 1 

Aquatic Ecology 

Refurbishment 1 

Terrestrial Resources 

Refurbishment impacts 2 

Threatened or Endangered Species 

Threatened or endangered species 2 

Ground Water Use and Quality 

Impacts of refurbishment on ground water use and quality 1 

Air Quality 

Air quality during refurbishment (nonattainment and maintenance areas) 2 

Land Use 

Onsite land use 1 

Human Health 

Radiation exposures to the public during refurbishment 1 

Occupational radiation exposures during refurbishment 1 

Socioeconomics 

Public services: public safety, social services, and tourism and recreation 1 

Aesthetic impacts (refurbishment) 1 

Housing impacts 2 

Public services: education (refurbishment) 2 

Public services: public utilities 2 

Public services: transportation 2 

Offsite land use (refurbishment) 2 

Historic and Archaeological resources 2 

Environmental Justice 

Environmental justice Uncategorized 
Environmental Impacts of Refurbishment 

February 2010 3-3 Draft NUREG-1437, Supplement 40 

1 10 CFR Parts 51 and 54 and complementary information in the GEIS, NUREG-1437 (NRC 

2 1996, 1999). 

3 The requirements for the assessment of refurbishing in a license renewal of operating nuclear 

4 power plants include the preparation of an integrated plant assessment (IPA) under 

5 10 CFR 54.21. The IPA must identify and list systems, structures, and components subject to an 

6 aging management review. Items that are subject to aging and might require refurbishment 

7 include, for example, the reactor vessel, piping, supports, and pump casings, as well as those 

8 that are not subject to periodic replacement. 

9 In the case of KPS, the IPA did not identify the need for major refurbishment or replacement 

10 actions to maintain the functionality of important systems, structures, and components during 

11 the KPS license renewal period. Also, the IPA did not identify the need for modifications to any 

12 of the KPS facilities associated with the license renewal. 

13 The NRC staff reviewed the information presented in the KPS ER, support documentation, and 

14 gathered during the site audits and interviews. During the review, the NRC staff did not identify 

15 any new and significant information that would affect the conclusion presented in the ER. 

16 Therefore, based on the review, the NRC staff concluded that no refurbishing activities are 

17 necessary in anticipation of the license renewal or during the license renewal term. The NRC 

18 staff does not expect that the environmental impacts caused by KPS during the renewal term 

19 will be beyond those that occur during the normal plant operations. 

20 3.1 REFERENCES 

21 10 CFR 51. Code of Federal Regulations, Title 10 Energy, Part 51 “Environmental Protection 

22 Regulations for Domestic Licensing and Related Regulatory Functions.” 

23 10 CFR 54. Code of Federal Regulations, Title 10 Energy, Part 54, “Requirements for Renewal 

24 of Operating Licenses for Nuclear Power Plants.” 

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

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

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

28 for License Renewal of Nuclear Plants, Main Report, “Section 6.3-Transportation, Table 9.1, 

29 Summary of Findings on NEPA Issues for License Renewal of Nuclear Power Plants, Final 

30 Report.” NUREG-1437, Volume 1, Addendum 1, Washington, D.C. 

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

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

33 Power Station.” Docket No. 50-305. August 2008. Agencywide Documents Access and 

34 Management System (ADAMS) Accession No. ML082341039. 

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

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

37 ML082341020, ML082341038, ML082420854. 

 

February 2010 4-1 Draft NUREG-1437, Supplement 40 

1 4.0 ENVIRONMENTAL IMPACTS OF OPERATION 

2 This chapter addresses potential environmental impacts related to the period of extended 

3 operation of Kewaunee Power Station (KPS). These impacts are grouped and presented 

4 according to resource. Generic issues (Category 1) rely on the analysis provided in the generic 

5 environmental impact statement (GEIS), prepared by the U.S Nuclear Regulatory Commission 

6 (NRC 1996, 1999) and are discussed briefly. Site-specific issues (Category 2) have been 

7 analyzed for KPS and assigned a significance level of SMALL, MODERATE, or LARGE, 

8 accordingly. Some remaining issues are not applicable to KPS because of site characteristics or 

9 plant features. Section 1.4 of this report explains the criteria for Category 1 and Category 2 

10 issues, and defines the impact designations of SMALL, MODERATE, and LARGE. 

11 4.1 LAND USE 

12 Table 4.1 lists the Category 1 issues (from 10 CFR Part 51, Subpart A, Appendix B, Table B–1) 

13 which are applicable to onsite land use and power line right of way (ROW) impacts during the 

14 renewal term. As stated in the GEIS, the impacts associated with these Category 1 issues were 

15 determined to be SMALL, and plant-specific mitigation measures would not be sufficiently 

16 beneficial to be warranted. 

17 NRC reviewed and evaluated the applicant’s environmental report (ER), Dominion Energy 

18 Kewaunee, Inc. (DEK, 2008), scoping comments, other available information, and visited the 

19 KPS in search of new and significant information that would change the conclusions presented 

20 in the GEIS. No new and significant information was identified during this review and evaluation. 

21 Therefore, it is expected that there would be no impacts related to these Category 1 issues 

22 during the renewal term beyond those discussed in the GEIS. 

23 Table 4-1. Land Use Issues. Section 2.2.1 of this draft supplemental environmental impact 

24 statement (SEIS) describes the land use around KPS. 

Issues GEIS Section Category 

Onsite land use 4.5.3 1 

Power line ROW 4.5.3 1 

25 4.2 AIR QUALITY 

26 The air quality issue applicable to KPS is listed in Table 4-2. No Category 2 issues have been 

27 identified for air quality. The NRC staff did not identify any new and significant information 

28 during the review of the applicant’s ER (DEK, 2008), the site audit, or during the scoping 

29 process. No major facility construction or refurbishments are planned to occur during the license 

30 renewal period. Therefore, there are no impacts related to this issue beyond those discussed in 

31 the GEIS. For these issues, the GEIS concluded that the impacts are SMALL.
Environmental Impacts of Operation 

Draft NUREG-1437, Supplement 40 4-2 February 2010 

1 Table 4-2. Air Quality Issue. Section 2.2.2 of this document provides a description of air quality 

2 at Kewaunee Power Station. 

Issue GEIS Section Category 

Air quality effects of transmission lines 4.5.2 1 

3 4.3 GENERIC GROUNDWATER ISSUES 

4 There were no Category 1 groundwater impacts identified for the KPS license renewal term and 

5 no Category 2 issues were found applicable to the continued operation of the facility. KPS 

6 withdraws less than 100 gallons per minute of groundwater, and its once-through cooling 

7 system does not utilize cooling towers or cooling ponds, therefore, none of the NRC specified 

8 Category 2 issues for groundwater issues are applicable to KPS. 

9 4.4 GENERIC SURFACE WATER ISSUES 

10 The following sections discuss the surface water quality issues applicable to KPS. The issues 

11 are also listed in Table 4-3. NRC did not identify any new and significant information during the 

12 environmental review for the KPS license renewal, the site visit, or the scoping process. 

13 Therefore, no impacts are related to these issues beyond those discussed in the GEIS. For 

14 these issues, the GEIS concludes that the impacts are SMALL and additional site-specific 

15 mitigation measures are not likely to be warranted. 

16 Table 4-3. Category 1 Surface Water Issues. Applicable to the operation of the KPS cooling 

17 system during the renewal term. 

ISSUE—10 CFR Part 51, Subpart A, Appendix B, Table B-1 GEIS Sections 

Surface Water Quality, Hydrology, and Use 

Altered current patterns at intake and discharge structures 4.2.1.2.1 

Temperature effects on sediment transport capacity 4.2.1.2.3 

Scouring caused by discharged cooling water 4.2.1.2.3 

Discharge of chlorine or other biocides 4.2.1.2.4 

Discharge of sanitary wastes and minor chemical spills 4.2.1.2.4 

Discharge of other metals in wastewater 4.2.1.2.4 

Water use conflicts – plants with once-through cooling systems 4.2.1.3 

18 

19 4.4.1 Water Use Conflicts 

20 There were no Category 2 surface water issues identified for the KPS license renewal term. 

21 4.5 AQUATIC RESOURCES 

22 The Category 1 and Category 2 issues related to aquatic resources applicable to KPS are 

23 discussed below and listed in Table 4-4. 
Environmental Impacts of Operation 

February 2010 4-3 Draft NUREG-1437, Supplement 40 

1 Table 4-4. Aquatic Resources Issues. Section 2.1.6 of this document describes KPS’s cooling 

2 water system and Section 2.2.5 of this document describes the aquatic resources. 

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 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 

3 4.5.1 Generic Aquatic Ecology Issues 

4 The NRC staff did not identify any new or significant information during the review of the 

5 applicant’s ER (DEK, 2008), the staff’s site audit, the scoping process, or the evaluation of other 

6 available information. Therefore, the NRC staff found no impacts related to the generic, 

7 Category 1 issues beyond those discussed in the GEIS. For these issues, the GEIS concluded 

8 that the impacts are SMALL, and additional site-specific mitigation measures are not likely to be 

9 sufficiently beneficial to be warranted. 

10 4.5.2 Entrainment of Fish and Shellfish in Early Life Stages 

11 Entrainment occurs when aquatic organisms (usually eggs, larvae, and other small organisms) 

12 are drawn into the cooling water system and are subjected to thermal, physical, and chemical 

13 stress. For nuclear power plants with once-through cooling systems, the NRC considers the 

14 entrainment of fish and shellfish in early life stages into cooling water systems to be a Category 

15 2 issue, which requires a site-specific assessment during the license renewal application review 

16 process. KPS operates a once-through heat dissipation system that withdraws water from and 

17 discharges it back to Lake Michigan. A detailed description of the KPS cooling system is 

18 presented in Section 2.1.6 of this draft SEIS. Flow rates and discharge volumes are given in 

19 Section 4.2.5 of this draft SEIS. 

20 For the site-specific assessment of the KPS cooling system, the NRC staff reviewed the 

21 applicant’s ER (DEK, 2008) and related documents, including the Clean Water Act (CWA) 

22 Section 316(a) Demonstration (NES, 1976), CWA Section 316(b) Demonstration (NES, 1976), 

23 the KPS Impingement Mortality and Entrainment Characterization Report and the Kewaunee 
Environmental Impacts of Operation 

Draft NUREG-1437, Supplement 40 4-4 February 2010 

1 Power Station WPDES WI-0001571-07, “Cooling Water Intake Structure Information Submittal” 

2 (Dominion, 2008), and visited the KPS site. The NRC staff also reviewed the applicant’s State of 

3 Wisconsin WPDES Permit No. WI-0001571-07-0, issued on July 18, 2005, and in force until 

4 June 30, 2010 (WDNR 2005; 2005a). 

5 Section 316(b) of the CWA requires that the location, design, construction, and capacity of the 

6 cooling water intake structures reflect the best technology available (BTA) in order to minimize 

7 adverse environmental impacts, specifically impingement and entrainment, to protect fish, 

8 shellfish, and other forms of aquatic life (33 USC 1326). Phase II of Section 316(b)’s 

9 implementing regulations applies to large existing electric generating plants, such as KPS, that 

10 withdraw more than 50 million gallons of water per day (gpd; 6.7 million cubic feet per day (cfd)). 

11 The Environmental Protection Agency (EPA) implemented Phase II on July 9, 2004 

12 (69 FR 41575). The new Phase II performance standards were designed to significantly reduce 

13 impingement mortality due to water withdrawals associated with cooling water intake structures 

14 used for power production and were to be implemented through the NPDES permitting process. 

15 The rule would require licensees to demonstrate compliance with Phase II performance 

16 standards upon renewal of their NPDES permit. 

17 However, the EPA suspended the Phase II rule on July 9, 2007 (72 FR 37107), in response to 

18 the Second Circuit Court of Appeals decision in Riverkeeper, Inc. v. EPA, 475 F.3d 83 (2d Cir. 

19 2009). As a result, the EPA directed NPDES permit writers for Phase II facilities to develop 

20 technology-based permit conditions on a case-by-case basis using all reasonably available and 

21 relevant data and best professional judgment (BPJ) regarding the BTA. Some of the changes 

22 that the licensees may be required to implement by the EPA could include altering their intake 

23 structure, redesigning the cooling system, modifying station operation, or taking other mitigative 

24 measures. 

25 Before suspension of the Phase II rule, DEK submitted a Proposal for Information Collection 

26 (PIC) to the Wisconsin Department of Natural Resources (WDNR) in October 2005 to 

27 demonstrate KPS’s compliance with the Phase II requirements. The PIC included options for 

28 achieving compliance with the rule and proposals for biological studies. The WDNR provided 

29 comments modifying the PIC, and DEK began collecting data in accordance with the modified 

30 PIC in March 2006. As a result of the July 9, 2007, suspension of the Phase II rule, KPS was no 

31 longer required to comply with the modified PIC; however, the WDNR modified the requirements 

32 contained in the KPS WPDES permit so that the one-year impingement and entrainment field 

33 study detailed in the modified PIC remained a requirement (WDNR, 2007). On January 4, 2008, 

34 DEK submitted a letter to the WDNR (Dominion, 2008) containing the one-year impingement 

35 and entrainment field study from March 2006 through February 2007 prepared by EA 

36 Engineering Science and Technology, Inc. (EAE, 2007). 

37 Prior to this study, as a condition of the original WPDES permit for KPS, Nalco Environmental 

38 Sciences (NES) performed a one-year entrainment and impingement study (NES 1976) for 

39 Wisconsin Public Service Corporation (WPSC) from April 1, 1975, through March 31, 1976. The 

40 results of this study were summarized in a 316(b) Demonstration. At that time, WDNR did not 

41 require any additional modifications of the cooling system or mitigation for compliance with the 

42 KPS WPDES permit as a result of the study. 
Environmental Impacts of Operation 

February 2010 4-5 Draft NUREG-1437, Supplement 40 

1 4.5.2.1 Nalco Environmental Sciences, 1975-1976 

2 The original KPS WPDES Permit required a one-year study on the environmental impacts of the 

3 cooling water intake structure, which NES (1976) conducted from April 1, 1975 through 

4 March 31, 1976; the results were summarized in a 316(b) Demonstration. NES gathered 

5 entrainment samples from the forebay once per week from April through August 1975 and twice 

6 per month from September 1975 through March 1976. Two zero-mesh (335 μm) plankton nets 

7 with digital flow monitors were used to gather entrainment samples three times (12:00 a.m., 8 

8 a.m., and 4 p.m.) during each 24-hour period of sampling. Two replicates were collected for 

9 each net at each time period. Collected fish eggs, larvae, and debris were then sorted, counted, 

10 and recorded. Larvae were measured to the nearest 0.1 mm (0.004 in.) and identified by 

11 species, as possible. Some juveniles were collected, though NES combined juveniles and 

12 larvae for purposes of analysis. Intake and discharge temperatures, water flow, and turbidity 

13 were also collected at the time of each sample. Impingement sampling methods for this study 

14 are discussed in Section 4.5.3 (NES, 1976). 

15 Alewife was the most prevalent species of eggs collected from entrainment sampling, followed 

16 by rainbow smelt and white or longnose sucker (the study groups these together by family, 

17 Catostomidae) (See Table 4-5). Alewife eggs were collected in June, July, and August, while 

18 catostomid and rainbow smelt eggs were only collected in April and May. A total of 3,224 fish 

19 eggs were collected during the study with a peak collection of 1777 eggs in July. NES (1976) 

20 estimated that a total of 52.6 million eggs were entrained through the KPS cooling system 

21 during the study year with peak numbers in July and August and a combined estimated total of 

22 43.9 million eggs (NES, 1976).

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

Common Name Taxa Total Number 

Collected 

Percentage 

of Total 

Eggs 

Alewife Alosa pseudoharengus 2208 68.5 

Rainbow smelt Osmerus mordax 976 30.3 

White or longnose sucker Catostomidae spp. 26 0.8 

Unidentified taxa 14 0.4 

Total 3224 100 

Larvae and Juveniles 

Rainbow smelt Osmerus mordax 411 89.7 

Alewife Alosa pseudoharengus 20 4.4 

Carp Cyprinus carpio 12 2.6 

Burbot Lota lota 6 1.3 

Whitefish Coregonidae spp. 5 1.1 

Slimy sculpin Cottus cognatus 3 0.7 

White or longnose sucker Catostomidae spp. 1 0.2 

Total 458 100 

Source: adapted from NES 1976 
Environmental Impacts of Operation 

Draft NUREG-1437, Supplement 40 4-6 February 2010 

1 Rainbow smelt was the most prevalent species of larvae and juveniles collected from 

2 entrainment sampling, and accounted for almost 90 percent of the total collected. Alewife and 

3 catostomid larvae and juveniles were also identified in the samples. Additionally, carp (Cyprinus 

4 carpio), burbot (Lota lota), whitefish (Coregonidae spp.), and slimy sculpin (Cottus cognatus) 

5 were present, none of which were identified in egg samples. NES (1976) estimated that KPS 

6 entrained a total of 13.6 million larvae and juveniles through the KPS cooling system during the 

7 study year with the majority entrained during summer months (6.4 million), followed by autumn 

8 (5.2 million), and then spring (2.0 million). 

9 When all life stages are considered (eggs, larvae, and juveniles), alewife accounted for 

10 61 percent and rainbow smelt accounted for 38 percent of the total entrained. The study 

11 estimates that the number of alewife and rainbow smelt eggs lost to entrainment over the study 

12 year would be comparable to the potential production of 4,286 alewife females and 200 smelt 

13 females (NES 1976). The estimated loss of larval and juvenile individuals for each species 

14 would be equivalent to the larval production of 105,400 alewife, 4,630 smelt, 323 slimy sculpin, 

15 1 burbot, 10 whitefish, and 1 Catostomid female (NES, 1976). The loss of carp juveniles was 

16 noted to be small compared to the large number of larvae produced by an average carp female, 

17 though no equivalent was provided. Froese and Pauly (2009) estimate that a 19-inch (47-cm) 

18 carp female can produce 300,000 eggs; therefore the loss of carp larvae and juveniles due to 

19 entrainment is equivalent to the egg production of less than one adult female. NES (1976) 

20 considered these losses to be small for all species. 

21 The NES (1976) study shows that the alewife population is adversely affected the most from 

22 entrainment. As discussed in Section 2.2.5 of this draft SEIS, the alewife is invasive to the Great 

23 Lakes and was first introduced to Lake Michigan in 1949. From the mid-1950s through 1960s, 

24 the rapid decrease in abundance of certain native fish that the alewife preyed on led to large25 scale die-offs of alewives in the 1950s and 1960s (Crawford, 2001). In response, Wisconsin 

26 Department of Natural Resources (WDNR) began a salmonid stocking program in 1965 to 

27 control the overabundant alewife population (Madenjian et al., 2005). Though the number of 

28 entrained alewife seems high, this study took place within the time period that the previously 

29 overabundant population of alewife was showing decline due to salmonid predation. Therefore, 

30 the effect of entrainment on the total population of alewife may not have been significant. The 

31 National Marine Fisheries Service does not have annual commercial landing statistics available 

32 for 1976, the year that the impingement and entrainment study took place (NOAA, 2007). The 

33 closest years available for the state of Wisconsin are 1961 (2,113,200 lbs or 958,531 kg) and 

34 1985 (23,366,000 lbs or 10,598,639 kg) (NOAA, 2007). Because the decline of alewife in Lake 

35 Michigan occurred between the 1960s and 1980s, NRC will assume the average between 1961 

36 and 1985 as an estimate for 1976, which is 12,739,600 lbs (5,778,585 kg). Adult alewives might 

37 typically weigh 8 to 9 ounces (227 to 255 g) on average (Bigelow and Schroeder, 1953). 

38 Therefore, the 1976 estimated landings would account for an estimated 23,980,423 adult 

39 alewives. In comparison, the equivalent loss of production of 109,686 females from entrainment 

40 of eggs, larvae, and juveniles is small. 

41 4.5.2.2 EA Engineering, Science, and Technology, Inc., 2006–2007 

42 After the EPA suspended the CWA 316(b) Phase II rule (discussed above), the WDNR modified

43 the requirements of the KPS WPDES permit to include a one-year impingement and 

44 entrainment study. EAE performed this study from March 2006 through February 2007. EAE 
Environmental Impacts of Operation 

February 2010 4-7 Draft NUREG-1437, Supplement 40 

1 gathered entrainment samples from the discharge canal once per week from March through 

2 August 2006, once in September 2006 due to a planned plant outage, and twice per month from 

3 October 2006 through February 2007. One zero-mesh (335 μm) plankton net equipped with a 

4 mechanical flow meter was used to gather entrainment samples four times (generally at 4:00 

5 a.m., 10 a.m., 4 p.m., and 10 p.m.) during each 24-hour period of sampling. Two replicates were 

6 collected for each sampling time. Collected fish eggs, larvae, and debris were then sorted, 

7 counted, and recorded. Unlike the NES (1976) study, EAE (2007) based their findings on 

8 density of entrainment rather than total number of organisms of each taxon collected. 

9 Additionally, eggs were only counted and identified as fertilized or unfertilized, but were not 

10 identified by species. Up to 20 larvae of each taxon and life-stage were measured to the nearest 

11 0.004 inches (0.1mm). Impingement sampling methods for this study are discussed in Section 

12 4.5.3 (EAE, 2007). 

13 The amphipod crustacean genus Gammarus accounted for the vast majority (93 percent) of 

14 entrained organisms based on annual density. Burbot, alewife, and common carp were the most 

15 abundant fish species; however, these three species collectively accounted for only 1.08 

16 percent of the estimated total number of organisms entrained. A total of 15 fish species were 

17 identified in the entrainment samples. Density data as well as station cooling water flow data 

18 were used to estimate the total number of organisms entrained during the study year for each 

19 species (see Table 4-6) (EAE, 2007). 

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

Common Name Taxa Total Estimated 

Number (x 106) 

Percentage 

of Total 

Eggs 

Unidentified taxa 25.28 1.63 

Total 25.28 1.63 

Larvae 

Burbot Lota lota 7.82 0.50 

Carp Cyprinus carpio 5.40 0.35 

Alewife Alosa pseudoharengus 3.52 0.23 

Carp and minnow 

family Cyprinidae spp. 2.80 0.18 

Clupeid family Clupeidae spp. 1.96 0.13 

Rainbow smelt Osmerus mordax 1.25 0.08 

Whitefish family Coregoninae spp. 0.80 0.05 

Sickleback family Gasterosteidae spp. 0.66 0.04 

Perch family Percidae spp. 0.55 0.03 

Unidentified taxa 0.39 0.02 

Round goby Neogobius melanostomus 0.14 0.01 

Sucker spp. Catostomus spp. 0.12 <0.01 

Ninespine Stickleback Pungitius pungitius 0.07 <0.01 

White sucker Catostomus commersoni 0.05 <0.01 

Deepwater sculpin Myoxocephalus thompsoni 0.04 <0.01 

Juveniles 
Environmental Impacts of Operation 

Draft NUREG-1437, Supplement 40 4-8 February 2010 

Rainbow smelt Osmerus mordax 3.22 0.21 

Alewife Alosa pseudoharengus 0.29 0.02 

Ninespine Stickleback Pungitius pungitius 0.20 0.01 

Deepwater sculpin Myoxocephalus thompsoni 0.07 <0.01 

Total 29.35 1.88 

Invertebrates 

Scud spp. Gammarus spp. 1494.22 96.23 

Opossum shrimp Mysis relicta 3.22 0.21 

Bloody-red mysid Hemimysis anomala 0.74 0.05 

Total 1498.18 96.49 

Source: adapted from EAE, 2007 

1 Total estimated numbers entrained for each species of fish were generally small when 

2 compared to the potential production of reproducing females. Female burbot can produce 

3 between 500,000 and 1,500,000 eggs (USFWS, 2003). Using the average egg production of 

4 1,000,000 eggs per female, the total estimated number of entrained burbot larvae is equivalent 

5 to the egg production of about eight females. Female carp can produce up to 300,000 eggs 

6 (Froese and Pauly, 2009). Therefore, the total estimated number of entrained carp larvae is 

7 equivalent to the egg production of 18 females. Female alewife can produce 60,000 to 100,000 

8 eggs (Fay et al., 1983). Using the average egg production of 80,000 eggs per female, the total 

9 estimated number of entrained alewife larvae is equivalent to the production of 44 females. 

10 Because not all eggs are spawned, not all spawned eggs are fertilized, few fertilized eggs 

11 survive to become larvae in the wild, and mortality rates can be high within the larval stages, the 

12 estimated equivalent number of reproducing females for each species will likely be greater than 

13 the numbers calculated above. Though the specific mortality rate of alewives from egg to larval 

14 stage is unavailable, Edsall in 1970, (Fay et al., 1983) reported an alewife egg hatching rate of 

15 38 percent at an optimal incubation temperature of 64 °F (18 °C) in Lake Michigan. Using this 

16 hatching rate and the average production of 80,000 eggs per female (Fay et al., 1983), the total 

17 estimated number of entrained alewife larvae is equivalent to the production of 116 females. 

18 The NRC staff calculated the percent of the Lake Michigan alewife population that 116 females 

19 represents by using a 2007 estimate (Madenjian et al., 2008) of a lake-wide biomass of 

20 alewives (11,674 metric tons; 25,736,764.5 lbs) and the average weight of an adult alewife, 

21 which might typically be 8 to 9 ounces (227 to 255 g) (Bigelow and Schroeder, 1953). The staff 

22 found that alewife larval entrainment, calculated to be equivalent to the egg production of 116 

23 females, would represent only 0.0002 percent of the Lake Michigan population. Specific 

24 mortality rates for burbot and carp were unavailable; however, the equivalent loss of 

25 reproducing females from larval entrainment would likely remain small in comparison to the 

26 lake-wide population of each species. 

27 When results of the 1975–1976 NES (1976) study are compared to the 2006–2007 EAE (2007) 

28 study, some notable differences appear. Rainbow smelt were more abundant in 1975–1976 

29 samples than in 2006–2007 samples. Table 4-7 contains the total estimated numbers of 

30 entrained individuals for those species that appear in both studies. The total estimated number 

31 of eggs entrained was also much higher in the 1975–1976 study. Alewife, carp, burbot, and 

32 whitefish were more abundant in the 2006–2007 samples. EAE (2007) notes that these 
Environmental Impacts of Operation 

February 2010 4-9 Draft NUREG-1437, Supplement 40 

1 differences primarily reflect the changing population dynamics and species’ abundances in Lake 

2 Michigan during the 30-year interval between studies. Section 2.2.5 of this draft SEIS describes 

3 the changing aquatic communities within Lake Michigan as a result of numerous invasive 

4 species introductions, which supports this conclusion. 

5 Sampling differences may have occurred due to location of sampling; NES (1976) sampled in 

6 the forebay at the intake, while EAE (2007) sampled in the discharge canal. However, the total 

7 absence of certain species from the 1975–1976 study is unlikely if these species were within the 

8 vicinity of KPS at the time of the study. Burbot, ninespine stickleback, round goby, and white 

9 sucker, all of which appeared in the 2006–2007 study but not in the 1975–1976 study, spawn in 

10 relatively shallow water, which means that their larvae would have a greater likelihood of being 

11 entrained if these species were in the vicinity of KPS. Bunnell et al., 2007 reports a recovery of 

12 burbot numbers beginning in the 1980s, after the species had suffered a decline in the 1970s 

13 following the introduction of alewife, which may account for the appearance of this species in 

14 the 2006–2007 study, but not the 1975–1976 study. The ninespine stickleback population 

15 density in Lake Michigan was low from 1973–1995, increased dramatically in 1996–1997, and 

16 has remained variable since this time, which may account for the increased number of 

17 individuals recorded in the 2006–2007 study (Bunnel et al., 2007; EAE, 2007). Though species 

18 composition differs between the studies, both studies collected species representing the major 

19 trophic levels of fish: predator species, forage species, and bottom-dwellers; therefore the 

20 results of these studies do not indicate that the aquatic community within the vicinity of KPS has 

21 become destabilized. Additionally, neither study indicates that any one species is being affected 

22 enough to cause decline or destabilization of the species population in Lake Michigan. 

23 Table 4-7. Estimated Total Numbers of Entrained Fish. Total estimated numbers are 

24 compared between the 1975–1976 study (NES, 1976) and 2006–2007 (EAE, 2007) study for 

25 those species that appeared in both studies.

Species and/or 

Life Stage 

Total Estimated Number 

(x 106) 

1975–1976 

Total Estimated Number 

(x 106) 

2006–2007 

Fish eggs 52.672 25.28 

Rainbow smelt juveniles 9.715 3.22 

Rainbow smelt larvae 2.764 1.32 

Alewife juveniles 0.393 0.29 

Alewife larvae 0.271 3.52 

Carp larvae 0.237 5.40 

Burbot larvae 0.076 7.82 

Slimy sculpin larvae 0.085 0.00 

Whitefish larvae 0.076 0.80 

Source: adapted from EAE, 2007 

26 Based on the information presented in this section, the NRC staff determined that the potential 

27 impacts of entrainment of fish and shellfish by the KPS cooling system during the 20-year 

28 renewal period would be SMALL. The staff identified potential mitigation measures, including 

29 use of finer mesh screens, operating under reduced intake flow, and scheduling outages during 

30 historic periods of high fish density. However, the staff concludes that none of the mitigation 
Environmental Impacts of Operation 

Draft NUREG-1437, Supplement 40 4-10 February 2010 

1 measures considered would eliminate adverse entrainment impacts and would not reduce the 

2 significance level below SMALL. The NRC does not have the authority to mandate these 

3 measures; it is the responsibility of the WDNR to impose any restrictions or modifications to the 

4 cooling system to reduce the impact of entrainment under the WPDES permitting process. The 

5 staff did not identify any cost benefit studies applicable to these mitigation measures. 

6 4.5.3 Impingement 

7 Impingement occurs when aquatic organisms are pinned against intake screens or other parts 

8 of the cooling water system intake structure. For plants with once-through cooling systems, the 

9 impingement of fish and shellfish on screens associated with plant cooling systems is 

10 considered a Category 2 issue, which requires a site-specific assessment during the license 

11 renewal application review process. The NRC staff considered the information and documents 

12 described previously in Section 4.5.2 to perform a site-specific assessment of impingement 

13 resulting from the KPS cooling system. Impacts of existing cooling water systems, including 

14 impacts of impingement, are regulated under the provisions of the CWA as described in Section 

15 4.5.2. Section 4.5.2 also includes a discussion of Section 316(b) requirements, which are also 

16 relevant to impingement. A detailed description of the KPS cooling system is presented in 

17 Section 2.1.6. Flow rates and discharge volumes are given in Section 4.2.5. 

18 4.5.3.1 Nalco Environmental Sciences, 1975–1976 

19 As previously described in Section 4.5.2, NES (1976) conducted a one-year impingement and 

20 entrainment study from April 1, 1975 through March 31, 1976. NES sampled adult and juvenile 

21 fish impinged on the traveling screens from two to seven days per week during the study period. 

22 Impinged fish were washed into a discharge sluice and collected in a basket to be identified, 

23 measured, and weighed. Once the total number of alewives or smelt exceeded 50, only 10 

24 percent of the remaining alewives or smelt were removed to be weighed and measured, and 

25 these individuals served as a subsample from which to estimate the total number of alewives or 

26 rainbow smelt impinged (NES, 1976). 

27 A total of 31 species of fish were collected in entrainment samples during the study year (See 

28 Table 4-8). No Federally- or State-listed species were collected. Alewife accounted for the vast 

29 majority (83.2 percent) of the total individual fish impinged. Rainbow smelt, slimy sculpin, and 

30 longnose dace were also prevalent. A total of 215,108 fish were impinged with June having the 

31 highest number of fish (57,871) and March having the lowest number of fish (931). Alewives 

32 were collected in greatest numbers in the spring and summer, and few alewives were collected 

33 in winter, which corresponds to their seasonal patterns of migrating into shallower waters in the 

34 spring and inhabiting deeper portions of the lake in winter. NES (1976) estimated that only 

35 0.0003 percent of the total estimated biomass of alewife in Lake Michigan was impinged at KPS 

36 during the study year, which represents 0.02 percent of the total commercial catch in Wisconsin. 

37 Also, alewife die-offs were common during the late-1970s, which may account for the large 

38 number of alewives collected in impingement samples. The final SEIS for Point Beach Nuclear 

39 Station (NRC, 2005), which is located about 5 mi (8km) south of KPS, notes that a majority of 

40 “impinged alewives were assumed to be dead or dying individuals associated with the annual 

41 spring die-off.” Rainbow smelt was the second most abundant species collected in impingement 

42 samples and was most common in October and November. Impinged smelt only accounted for 

43 0.003 percent of the total estimated biomass of smelt in Lake Michigan and 0.3 percent of the 
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February 2010 4-11 Draft NUREG-1437, Supplement 40 

1 total commercial catch in Wisconsin. Similarly, impinged slimy sculpin accounted for only 0.002 

2 percent of the total estimated biomass of the species in Lake Michigan. All other species of fish 

3 impinged during the study year accounted for less than 0.002 percent of the total estimated 

4 biomass of that species. (NES, 1976). 

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

Common Name Taxa Total 

Number 

Percentage 

of Total 

Alewife Alosa pseudoharengus 178,883 83.2 

Rainbow smelt Osmerus mordax 19,206 8.9 

Slimy sculpin Cottus cognatus 8,640 4.0 

Longnose dace Rhinichthys cataractae 4,389 2.0 

Lake chub Couesius plumbeus 1,584 0.7 

Sucker groupa Catostomus catostomus, C. commersonii, and 

Moxostoma macrolepidotum 1,000 0.5 

Trout groupb Oncorhynchus mykiss, Salmo trutta, Salvelinus 

fontinalis, and Salvelinus namaycush 344 0.2 

Gizzard shad Dorosoma cepedianum 311 0.1 

Carp Cyprinus carpio 259 0.1 

Yellow perch Perca flavescens 245 0.1 

Bullhead groupc Ameiurus natalis and A. nebulosus 111 <0.1 

Ninespine stickleback Pungitius pungitius 55 <0.1 

Troutperch Percopsis omiscomaycus 39 <0.1 

Whitefish groupd Coregonus clupeaformis and Prosopium 

cylindraceum 13 <0.1 

Pumpkinseed Lepomis gibbosus 9 <0.1 

Burbot Lota lota 7 <0.1 

Common shiner Notropis cornutus 4 <0.1 

Salmon groupe Oncorhynchus tshawytscha and O. kisutch 3 <0.1 

Lamprey Petromyzontidae spp. 2 <0.1 

Northern pike Esox lucius 2 <0.1 

Bloater Coregonus hoyi 1 <0.1 

Blacknose dace Rhinichthys atratulus 1 <0.1 

Total 215108 100 

a

Sucker group consists of white sucker, longnose sucker, and shorthead redhorse. 

b

Trout group consists of rainbow trout, brown trout, brook trout, and lake trout. 

c

Bullhead group consists of yellow bullhead and brown bullhead. 

d

Whitefish group consists of lake whitefish and round whitefish. e

Salmon group consists of Chinook salmon and coho salmon. 

Source: adapted from NES, 1976 

6 4.5.3.2 EA Engineering, Science and Technology, Inc., 2006–2007 

7 As previously described in Section 4.5.2, EAE (2007), conducted a one-year impingement and 

8 entrainment study from March 2006 through February 2007. Impingement samples were 
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Draft NUREG-1437, Supplement 40 4-12 February 2010 

1 collected once per week from March through August 2006 and twice per month October 2006 

2 through February 2007. No samples were collected in September 2006 due to a planned plant 

3 outage. Impingement samples were gathered in a collection basket downstream of the traveling 

4 screens over 24-hour periods from 9 a.m. to 9 a.m. As in the 1975–1976 NES (1976) study, fish 

5 were then removed, identified, weighed, and counted. Up to 50 individual fish per species per 

6 24-hour period were individually measured and weighed, and the excess individuals were 

7 counted and collectively weighed. (EAE, 2007) 

8 A total of 34 species of fish were collected in entrainment samples during the study year. Over 

9 90 percent of all impinged fish were collected in June and July. No Federally- or State-listed 

10 species were collected. Alewife accounted for the vast majority (99.7 percent) of the total 

11 individuals impinged (EAE, 2007). Alewife collection peaked in June and July 2006 and again, 

12 to a lesser extent, in October and November 2006 (EAE, 2007). The NRC staff estimated the 

13 percent of Lake Michigan alewives that were impinged in the KPS cooling system during the 

14 study year. EAE, 2007 recorded 690,402 individual alewives with a combined biomass of 

15 2,666,686.5 grams (5879 lbs) in impingement samples over the study year. Using the total 

16 number of collected alewife, the biomass of collected alewife, and the total estimated number of 

17 alewife impinged over the study year (5,592,692 individuals), the NRC staff extrapolated the 

18 total estimated biomass of alewife impinged over the study year to be 21,601,844 grams 

19 (47,624 lbs). Madenjian et al., (2008) estimates the 2007 lake-wide biomass of alewife was 

20 11,674 metric tons (25,736,764.5 lbs). Therefore, impinged alewife represented 0.002 percent 

21 of the total estimated alewife biomass in Lake Michigan in 2007. 

22 Ninespine stickleback, rainbow smelt, yellow perch, mottled sculpin, and spottail shiner were 

23 collected in excess of 100 individual fish over the study year, and less than 100 individual fish of 

24 all other species were collected (See Table 4-9) (EAE, 2007). Similar to the estimates above, 

25 the NRC staff used Madenjian et al.’s (2008) lake-wide biomass estimates, EAE 2007 total 

26 estimated number of individual fish impinged over the study year, and an extrapolated total 

27 estimated biomass based on the combined collected biomass during the study. The NRC staff 

28 found that ninespine stickleback, rainbow smelt, yellow perch, mottled sculpin, and spottail 

29 shiner each accounted for less than 0.001 percent of the total estimated biomass of their 

30 species in Lake Michigan. 
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February 2010 4-13 Draft NUREG-1437, Supplement 40 

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

Common Name Taxa Total 

Collected 

% of Total 

Collected 

Total 

Estimated 

% of Total 

Estimated 

Alewife Alosa 

pseudoharengus 690,402 99.741 5,592,692 99.624 

Ninespine 

stickleback Pungitius pungitius 572 0.083 4473 0.080 

Rainbow smelt Osmerus mordax 300 0.043 3279 0.058 

Yellow perch Perca flavescens 164 0.024 3080 0.055 

Mottled sculpin Cottus bairdii 145 0.021 2148 0.038 

Spottail shiner Notropis hudsonius 125 0.018 1615 0.029 

Northern clearwater 

crayfish 

Orconectes 

propinquus 123 0.018 1104 0.020 

Longnose sucker Catostomus 

catostomus 62 0.009 590 0.011 

Threespine 

stickleback 

Gasterosteus 

aculeatus 55 0.008 525 0.009 

White sucker Catostomus 

commersonii 52 0.008 597 0.011 

Longnose dace Rhinichthys 

cataractae 50 0.007 714 0.013 

Gizzard shad Dorosoma 

cepedianum 41 0.006 1216 0.022 

Burbot Lota lota 27 0.004 384 0.007 

Slimy sculpin Cottus cognatus 18 0.003 277 0.005 

Round goby Neogobius 

melanostomus 12 0.002 117 0.002 

Channel catfish Ictalurus punctatus 8 0.001 219 0.004 

Lake trout Salvelinus 

namaycush 7 0.001 49 <0.001 

Round whitefish Prosopium 

cylindraceum 7 0.001 169 0.003 

Black bullhead Ameiurus melas 3 <0.001 90 0.002 

Carp Cyprinus carpio 3 <0.001 70 0.001 

Smallmouth bass Micropterus dolomieui 3 <0.001 43 <0.001 

Brown trout Salmo trutta 2 <0.001 35 <0.001 

Chinook salmon Oncorhynchus 

tshawytscha 2 <0.001 36 <0.001 

Lake whitefish Coregonus 

clupeaformis 2 <0.001 38 <0.001 

Bloater Coregonus hoyi 1 <0.001 28 <0.001 

Bluegill Lepomis macrochirus 1 <0.001 28 <0.001 
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Draft NUREG-1437, Supplement 40 4-14 February 2010 

Common Name Taxa Total 

Collected 

% of Total 

Collected 

Total 

Estimated 

% of Total 

Estimated 

Sucker group Catostominae spp. 1 <0.001 22 <0.001 

Sculpin group Cottidae spp. 1 <0.001 38 <0.001 

Creek chub Semotilus 

atromaculatus 1 <0.001 29 <0.001 

Pumpkinseed Lepomis gibbosus 1 <0.001 29 <0.001 

Rock bass Ambloplites rupestris 1 <0.001 26 <0.001 

Shorthead redhorse Moxostoma 

macrolepidotum 1 <0.001 7 <0.001 

Silver lamprey Ichthyomyzon 

unicuspis 1 <0.001 10 <0.001 

White perch Morone americana 1 <0.001 22 <0.001 

Total 692,195 100 5,613,799 100 

Source: adapted from EAE, 2007 

1 When results of the 1975–1976 NES (1976) study are compared to the 2006–2007 EAE (2007) 

2 study, some notable differences appear. Alewife and rainbow smelt were among the most 

3 prevalent species impinged during both study years though the total number of alewife collected 

4 in the 2006–2007 study (690,402 individuals) was significantly higher than the total number 

5 collected in the 1975–1976 study (178,883 individuals). Impinged alewives in 2006–2007 

6 accounted for a slightly higher percentage of the total estimated biomass in Lake Michigan. 

7 However, both study years collected only a very small percentage of the total estimated 

8 biomass of alewives. 

9 Generally, the same family groups were present in both studies, though species composition 

10 and abundance vary. Lake chub, rainbow trout, brook trout, yellow bullhead, brown bullhead, 

11 troutperch, common shiner, coho salmon, lamprey, northern pike, and blacknose dace were 

12 present in the NES (1976) study, but did not appear in EAE 2007 impingement samples. 

13 Conversely, mottled sculpin, spottail shiner, northern Clearwater crayfish, threespine 

14 stickleback, round goby, channel catfish, black bullhead, smallmouth bass, bluegill, 

15 Catostominae spp., Cottidae spp., creek chub, rock bass, silver lamprey, and white perch were 

16 present in the EAE 2007 study, but did not appear in NES (1976) impingement samples. Slimy 

17 sculpin and longnose dace were the third (4.0 percent) and fourth (2.0 percent) most prevalent 

18 species, respectively, in the NES (1976) study, while the two species only accounted for 0.003 

19 and 0.007 percent, respectively, of total collected individuals in EAE 2007 impingement 

20 samples. EAE (2007) attributes the majority of these differences to the changes in the Lake 

21 Michigan aquatic community between study years. 

22 Bunnell et al. (2007) report a record class of yellow perch in 2005, which may explain the 

23 increase in this species numbers between the 1975–1976 study and the 2006–2007 study. As 

24 discussed in Section 4.5.2, Bunnell et al. (2007) also reports a recovery of burbot numbers 

25 beginning in the 1980s, after the species had suffered a decline in the 1970s following the 

26 introduction of alewife. Though ninespine stickleback accounted for less than 0.01 percent in 

27 both studies, about ten times as many individuals were collected in the 2006–2007 study. 

28 Threespine stickleback was not present in the 1975–1976 study, but appeared in the 2006–
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February 2010 4-15 Draft NUREG-1437, Supplement 40 

1 2007 study. These two species’ densities were low from 1973–1995, increased dramatically in 

2 1996–1997, and have remained variable since that time, which may account for the increased 

3 number of individuals recorded in the 2006–2007 study (Bunnell et al., 2007; EAE, 2007). 

4 Rainbow smelt, which represented 8.9 percent of impinged individuals in the 1975–1976 study, 

5 has shown decline since 1994, though the cause for this decline is unclear (Bunnell et al. 2007; 

6 EAE 2007). Rainbow smelt were present, but in much reduced numbers in the 2006–2007 

7 study. 

8 Section 2.2.5 of this draft SEIS describes the changing aquatic communities within Lake 

9 Michigan as a result of numerous invasive species introductions, which supports these 

10 conclusions. Because impinged fish represented such a small percentage of total estimated 

11 numbers in Lake Michigan, results of neither the NES (1976) study nor the EAE, 2007) study 

12 suggest that the impacts of the KPS cooling system on the aquatic community in the vicinity of 

13 KPS is negatively affecting any fish species or destabilizing the aquatic community as a whole. 

14 Based on the information presented in this section, the NRC staff determined that the potential 

15 impacts of impingement of fish and shellfish by the KPS cooling system during the 20-year 

16 renewal period would be SMALL. The NRC staff identified potential mitigation measures, 

17 including closed cycle cooling, and derating the facility and scheduling plant outages during 

18 historic peak impingement periods. However, the staff concludes that none of the mitigation 

19 measures considered would eliminate adverse entrainment impacts and would not reduce the 

20 significance level below SMALL. The NRC does not have the authority to mandate these 

21 measures. It is the WDNR’s jurisdiction to impose any restrictions or modifications to the cooling 

22 system to reduce the impact of impingement under the WPDES permitting process. The staff 

23 did not identify any cost benefit studies applicable to these mitigation measures. 

24 4.5.4 Heat Shock 

25 The NRC defines heat shock as acute thermal stress caused by exposure to a sudden elevation 

26 of water temperature that adversely affects the metabolism and behavior of fish and can lead to 

27 death. Heat shock is most likely to occur when an offline unit returns to service or when a 

28 station has a discharge canal effectively trapping fish in the flow of heated discharge from the 

29 plant. For plants with once-through cooling systems, the effects of heat shock are listed as a 

30 Category 2 issue and require a plant-specific assessment before license renewal. The NRC 

31 staff considered the information and documents described previously in Section 4.5.2 to perform 

32 a site-specific assessment of heat shock resulting from the KPS cooling system. The KPS 

33 cooling system is described in Section 2.1.6. Flow rates and discharge volumes are given in 

34 Section 4.2.5. 

35 Section 316(a) of the CWA establishes a process by which a discharger can demonstrate that 

36 the established thermal discharge limitations are more stringent than necessary to protect 

37 balanced, indigenous populations of fish and wildlife and obtain facility-specific thermal 

38 discharge limits (33 USC 1326). In May 1976, NES (1976) provided WDNR with a Section 

39 316(a) demonstration that addressed compliance with the thermal effluent limitations in the 

40 WPDES permit and environmental impacts of KPS’s thermal discharge. This demonstration 

41 supported a petition for relief from Wisconsin Administrative Code thermal standards and a 
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Draft NUREG-1437, Supplement 40 4-16 February 2010 

1 State statute that required all plants on Lake Michigan with cooling water-related thermal 

2 discharges to transition to a recirculating system by 1981 (DEK, 2008). 

3 For the demonstration, NES reviewed monthly reports of temperature, flow, chemical and 

4 biological data for the KPS thermal plume under average, ideal, and worst case conditions. NES 

5 (1976a) used thermal plume surveys conducted by Industrial BIO-TEST Laboratories, Inc. 

6 between June 1974 and July 1975 to assess thermal plume characteristics at KPS. NES 

7 determined that the data was highly variable and could not be used to adequately characterize 

8 ambient conditions to yield a reliable plume model. However, NES used the thermal plume data 

9 to determine a discharge zone for KPS. The discharge zone was based on the EPA’s 

10 September 1974 Draft Guidelines for a 316(a) Demonstration and included the maximum 

11 surface area and maximum bottom area of the 2 °C (34 °F) isotherm. The discharge zone was 

12 determined to have an area of 985.3 acres (398.7 hectare (ha)) at the surface and 94.5 acres 

13 (38.2 ha) at the bottom. NES (1976a) estimated the extent of the thermally-affected zones for 

14 extreme conditions in summer and winter. In the summer, an ambient lake temperature of 

15 21.1 °C (70 °F) and a plant discharge temperature of 30 °C (86 °F) were used to predict the 

16 area of the thermal plume with zero lake current and with a lake current of 0.8 feet per second 

17 (fps); 0.2 meters per second (m/s)). In the winter, an ambient lake temperature of 0 °C (32 °F) 

18 and a plant discharge temperature of 15.5 °C (59.9 °F) were used to predict the area of the 

19 thermal plume with zero lake current and a lake current of 1.2 fps (0.37 m/s). Table 4-10 and 4-

20 11 summarize these thermal plume estimates. 

Lake Michigan has a surface area of 22,300 mi2 21 (14.27 million ac; 5.78 million ha) (WDNR, 

22 2009a), and so, based on these thermal plume estimates, any thermal effects on aquatic 

23 species originating from the KPS cooling system would be very localized for those species with 

24 a lake-wide distribution. Additionally, KPS’s discharge is located on the shoreline, just south of 

25 the forebay. Because water is discharged directly to Lake Michigan rather than returning to the 

26 lake via a discharge canal, fish are less likely to become entrapped in areas of elevated 

27 temperatures. The final SEIS for Point Beach Nuclear Station (NRC, 2005), which is located 

28 about 5 miles (8 km) south of KPS, also concluded that thermal effects on aquatic species 

29 would be localized because the plant is located on a relatively featureless portion of Lake 

30 Michigan with sandy substrate and rapid plume dissipation, no bays or points nearby to act as 

31 fish nurseries or other attracting features, and no substantial unique spawning grounds in the 

32 vicinity of the plant. 
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February 2010 4-17 Draft NUREG-1437, Supplement 40 

1 Table 4-10. KPS Thermal Plume Characteristics in Summer Under Extreme Conditions 

Isotherm 

Temperature(a) 

Distance in ft (m) Width in ft (m) Area in ac (ha) 

No current 

29.0 °C (84.2 °F) 111.4 (34.0) 79.5 (24.2) 0.17 (0.07) 

28.0 °C (82.4 °F) 147.7 (45.0) 92.4 (28.2) 0.27 (0.11) 

27.0 °C (80.6 °F) 204.9 (62.5) 112.7 (34.4) 0.46 (0.19) 

26.0 °C (78.8 °F) 302.1 (92.1) 147.2 (44.9) 0.88 (0.36) 

25.0 °C (77.0 °F) 486.9 (148.4) 212.7 (64.8) 2.04 (0.83) 

24.0 °C (75.2 °F) 904.9 (275.8) 361.0 (110.0) 6.45 (2.61) 

23.0 °C (73.4 °F) 2194.1 (668.8) 818.3 (249.4) 35.45 (14.35) 

22.0 °C (71.6 °F) 4939.5 (1505.6) 1792.2 (546.3) 174.80 (70.74) 

0.8 fps (0.2 m/s) current 

29.0 °C (84.2 °F) 101.4 (30.9) 66.0 (20.1) 0.13 (0.05) 

28.0 °C (82.4 °F) 174.3 (53.1) 84.8 (25.8) 0.29 (0.12) 

27.0 °C (80.6 °F) 279.3 (85.1) 111.8 (34.1) 0.62 (0.25) 

26.0 °C (78.8 °F) 411.7 (125.5) 145.8 (44.4) 1.19 (0.48) 

25.0 °C (77.0 °F) 663.5 (202.2) 210.5 (64.2) 2.76 (1.12) 

24.0 °C (75.2 °F) 1233.2 (375.9) 356.8 (108.8) 8.69 (3.52) 

23.0 °C (73.4 °F) 2989.6 (911.2) 808.1 (246.3) 47.70 (19.30) 

22.0 °C (71.6 °F) 6727.2 (2050.5) 1768.4 (539.0) 234.90 (95.06) 

(a) The discharge temperature is 30 °C (86 °F), and the ambient summer temperature is assumed to be 

21.1 °C (70 °F). 

Source: Adapted from NES 1976 

2 
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Draft NUREG-1437, Supplement 40 4-18 February 2010 

1 Table 4-11. KPS Thermal Plume Characteristics in Winter under Extreme Conditions. 

Isotherm 

Temperature(a) 

Distance in ft (m) Width in ft (m) Area in ac (ha) 

No current 

15.0 °C (59.0 °F) 101.5 (30.9) 77.1 (23.5) 0.15 (0.06) 

10.0 °C (50.0 °F) 331.2 (100.9) 119.7 (36.5) 0.78 (0.32) 

5.0 °C (41.0 °F) 1411.0 (430.1) 486.4 (148.3) 13.55 (5.48) 

4.0 °C (39.2 °F) 2101.9 (366.3) 751.2 (229.0) 31.18 (12.62) 

3.0 °C (37.4 °F) 3337.1 (1017.1) 1224.7 (373.3) 80.70 (32.66) 

2.0 °C (35.6 °F) 4994.8 (1522.4) 1860.2 (567.0) 183.46 (74.24) 

1.0 °C (33.8 °F) 9920.4 (3023.7) 3748.4 (1142.5) 734.26 (297.14) 

1.2 fps (0.37 m/s) current 

15.0 °C (59.0 °F) 132.7 (40.4) 51.7 (15.8) 0.14 (0.06) 

10.0 °C (50.0 °F) 671.8 (204.8) 99.3 (30.3) 1.32 (0.53) 

5.0 °C (41.0 °F) 2274.3 (693.2) 462.3 (140.9) 20.76 (8.40) 

4.0 °C (39.2 °F) 3176.2 (968.1) 629.7 (191.9) 39.49 (15.98) 

3.0 °C (37.4 °F) 4800.2 (1463.1) 1147.3 (349.7) 108.74 (44.01) 

2.0 °C (35.6 °F) 7183.0 (2189.4) 1589.2 (484.4) 225.39 (91.21) 

1.0 °C (33.8 °F) 14257.0 (4345.5) 2900.9 (884.2) 816.63 (330.48) 

(a) The discharge temperature is 15.5 °C (59.9 °F), and the ambient winter temperature is assumed to be 

0 °C (32 °F). 

Source: Adapted from NES 1976 

2 NES (1976a) also considered biological studies conducted by Industrial BIO-TEST Laboratories, 

3 Inc., from 1971 through 1975, to determine any impacts that the KPS thermal discharge may 

4 have on the fish community. A comparison of pre-operational and operational data showed no 

5 noticeable changes in the aquatic community as a result of thermal changes near the KPS 

6 discharge. No major changes in species composition, seasonal abundance, spatial distribution, 

7 or use of affected area were observed. Densities of major macroinvertebrate taxa remained 

8 similar between preoperational and operational studies, and no changes to the benthic 

9 community were detected as a result of KPS thermal discharge. The demonstration concluded 

10 that “the thermal component of the [KPS] discharge has not disturbed the balanced indigenous 

11 communities of fish, shellfish, and wildlife in Lake Michigan” (NES, 1976). 

12 On September 13, 1976, the WDNR granted alternative effluent limitations for KPS and 

13 exempted the thermal component of the Wisconsin Administration Code (DEK, 2008). As a 

14 result of this exemption, the current WPDES permit for KPS does not contain thermal effluent 

15 limitations. Under Dominion’s license, Appendix B of the Environmental Protection Plan, 

16 Dominion is required to report fish kills as an “unusual or important event.” To date, Dominion 

17 has not reported any fish kills related to thermal effluent discharge from the KPS cooling 

18 system. 

19 The WDNR is currently in the process of revising Chapter NR 102 of the Wisconsin 

20 Administrative Code to include water quality standards for thermal discharges. The new 
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February 2010 4-19 Draft NUREG-1437, Supplement 40 

1 Subchapter II would be entitled “Water Quality Standards for Temperature” and would include 

2 water quality criteria as well as ambient temperatures for certain fish and aquatic species. As 

3 part of this rule proposal, the WDNR would also establish procedures for calculating thermal 

4 limitations for WPDES-permitted discharges. The rule package was most recently revised in 

5 May 2009 (WDNR, 2009b). If this rule package is passed, KPS may be subject to thermal 

6 discharge limitations in the future, such as an upper limit on the temperatures of discharged 

7 waters. In this case, KPS would have to monitor intake and discharge temperatures and report 

8 them to WDNR on an annual or semi-annual basis. These limitations would most likely be 

9 addressed at the time of the WPDES permit renewal, or a timeline specified in the final rule. The 

10 current WPDES permit expires June 30, 2010. The NRC does not have authority to regulate 

11 thermal conditions, and therefore, relies on the State to set appropriate guidelines for thermal 

12 discharge through the WPDES permitting process. 

13 The NRC staff has reviewed available information, including the applicant’s ER (DEK, 2008), the 

14 current WPDES permit (WDNR, 2005a), the CWA Section 316(a) Demonstration (NES, 1976), 

15 and other applicable sources of information on heat shock. Plant operating conditions have not 

16 changed significantly since the original 316(a) Demonstration. Therefore, it can be reasonably 

17 concluded that the extent and distribution of KPS’s thermal plume has remained relatively 

18 unchanged. The NRC staff evaluated the potential impacts to aquatic resources due to heat 

19 shock during continued operation and determined that thermal impacts are likely to be limited 

20 because of the design and location of the KPS discharge structure. Furthermore, the NRC staff 

21 concludes that the potential impacts to fish and shellfish due to heat shock during the renewal 

22 term are SMALL. The NRC staff identified potential mitigation measures, including closed cycle 

23 cooling, helper cooling towers, derating the plant, and operating under reduced intake flows. 

24 The staff did not identify any cost benefit studies applicable to these mitigation measures. 

25 However, the NRC does not have the authority to mandate these measures; it is the WDNR’s 

26 jurisdiction to impose any restrictions or modifications to the cooling system to reduce the 

27 impact of heat shock under the WPDES permitting process. 

28 4.5.5 Total Impacts on Aquatic Resources 

29 Impingement, entrainment and heat shock all act on the same populations of aquatic resources. 

30 The purpose of this section is to provide perspective on the total impact of cooling system 

31 operation on fish and other aquatic resources. The WDNR, not the NRC, is responsible for 

32 issuing and enforcing WPDES permits. Because the NRC level of impact associated with 

33 impingement and entrainment is SMALL and the level of impact associated with thermal impacts 

34 is SMALL, the NRC staff believes that the total impact from all of these sources together on 

35 aquatic resources would also be SMALL through the period of license renewal. 

36 4.6 TERRESTRIAL RESOURCES 

37 The issues related to terrestrial resources applicable to KPS site are discussed below and listed 

38 in Table 4-12. There are no Category 2 issues related to terrestrial resources for license 

39 renewal. The NRC staff did not identify any new and significant information during the review of 

40 the DEK ER (DEK, 2008), the site audit, the scoping process, or the evaluation of other 

41 available information. Therefore, the NRC staff concludes that there would be no impacts 

42 related to these issues beyond those discussed in the GEIS (NRC, 1996). The GEIS concludes 
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Draft NUREG-1437, Supplement 40 4-20 February 2010 

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

2 sufficiently beneficial to implement. 

3 Table 4-12. Terrestrial Resources Issues. Section 2.2.6 of this draft SEIS provides a 

4 description of the terrestrial resources at KPS and in the surrounding area. 

Issues GEIS Section Category 

Power line ROW management (cutting herbicide application) 4.5.6.1 1 

Bird collisions with power lines 4.5.6.1 1 

Impacts of electromagnetic fields on flora and fauna (plants, 

agricultural crops, honeybees, wildlife, livestock) 4.5.6.3 1 

Floodplains and wetland on power line right of way 4.5.7 1 

5 4.7 THREATENED AND ENDANGERED SPECIES 

6 Table 4-13. Threatened or Endangered Species. Section 2.2.7 of this document describes the 

7 threatened or endangered species on or near KPS. 

Issue GEIS Section Category 

Threatened or endangered species 4.1 2 

8 This site-specific, or Category 2 issue, requires consultation with the appropriate agencies to 

9 determine whether or not threatened or endangered species are present and whether or not 

10 they would be adversely affected by continued operation of KPS during the license renewal 

11 term. The characteristics and habitats of threatened and endangered species in the vicinity of 

12 the KPS site are discussed in Sections 2.2.6 and 2.2.7 of this draft SEIS. 

13 The NRC contacted the USFWS on September 20, 2008, regarding threatened and endangered 

14 species at the KPS site (NRC, 2008). A description of the site and the in-scope transmission 

15 lines and a preliminary assessment of the Federally-listed threatened and endangered species 

16 potentially occurring on or near the KPS site were provided in this letter. The USFWS provided 

17 its response on October 28, 2008, indicating that the Hine’s emerald dragonfly (Somatochlora 

18 hineana) and the piping plover (Charadrius melodus) have the potential to occur in the vicinity of 

19 KPS (USFWS, 2008a). 

20 4.7.1 Aquatic Species 

21 The NRC staff has reviewed information provided by the applicant and information publicly 

22 available and has contacted the Greenbay Field Office of USFWS (NRC, 2008). Currently, no 

23 threatened or endangered aquatic species are known to occur within Lake Michigan on or in the 

24 vicinity of the KPS site or within any streams crossed by in-scope transmission line ROWs. 

25 Therefore, license renewal of KPS would have no effect on any Federally- or State-listed 

26 aquatic species, and mitigation measures need not be considered. 
Environmental Impacts of Operation 

February 2010 4-21 Draft NUREG-1437, Supplement 40 

1 4.7.2 Terrestrial Species 

2 Sections 2.2.6 and 2.2.7 of this draft SEIS discuss the characteristics and habitat of threatened 

3 and endangered species in the vicinity of the KPS site. 

4 The NRC staff contacted the USFWS and the WDNR to request information that could assist in 

5 assessing the environmental impacts associated with license renewal. On October 28, 2008, the 

6 FWS indicated that no known Federally-listed threatened or endangered species occur within 

7 the project area; therefore, the proposed project would not likely adversely affect any Federally8 listed species (USFWS, 2008). 

9 There are five Federally-listed threatened or endangered terrestrial species that potentially 

10 occur on the KPS site, although these species have not been documented on the site: the 

11 piping plover (Charadrius melodus), the Hine’s emerald dragonfly (Somatochlora hineana), the 

12 Karner blue butterfly (Lycaeides melissa samuelis), the dune or Pitcher’s thistle (Cirsium 

13 pitcheri), and the dwarf lake iris (Iris lacustris). The bald eagle (Haliaeetus leucocephalus) and 

14 the peregrine falcon (Falco peregrinus) were formerly Federally-listed as threatened and may 

15 also be found in the vicinity of the KPS site. Four State-listed species were identified as species 

16 for consideration of the proposed license renewal of KPS, including the Caspian tern (Sterna 

17 caspia), the osprey (Pandion haliaetus), and the formerly listed bald eagle and peregrine falcon. 

18 Section 2.2.7 of this report describes these species in greater detail (USFWS, 2008a; DEK, 

19 2008). 

20 The NRC staff encourages DEK, as well as American Transmission Company (ATC), who own 

21 the transmission lines, to report the existence of any Federally- or State-listed endangered or 

22 threatened species within or near the transmission line ROWs to the WDNR and USFWS, or 

23 both, if any such species are identified during the license renewal term. In particular, if any 

24 evidence of injury to, or mortality of, migratory birds, piping plovers, or any other threatened or 

25 endangered species is observed within the corridor during the license renewal period, the NRC 

26 staff encourages DEK and ATC to promptly report this to the appropriate wildlife management 

27 agencies. Also, if a Caspian tern (or common tern, also State-listed) population revisits the 

28 shore of either the KPS site or the surrounding areas, the NRC staff encourages DEK to monitor 

29 the situation and the species. Finally, the NRC staff encourages DEK and ATC to continue 

30 providing information concerning the peregrine falcon nesting pair and any fledglings that nest 

31 on the reactor building or occur in the transmission line ROW’s to the FWS and the State of 

32 Wisconsin. 

33 Because no threatened or endangered species are known to occur on or in the vicinity of the 

34 KPS site, operation of the site and its associated transmission lines are not expected to 

35 adversely affect any threatened or endangered species during the license renewal term. 

36 Therefore, the NRC staff concludes that adverse impacts to threatened or endangered species 

37 during the period of extend operation would be SMALL. The NRC staff finds several mitigation 

38 measures currently in place at the KPS site, and with its associated transmission lines, the NRC 

39 staff finds them to be adequate. They include: nest construction and placement for the peregrine 

40 falcon, environmental review checklists, environmental evaluation forms, and best management 

41 practices. 
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Draft NUREG-1437, Supplement 40 4-22 February 2010 

1 4.8 HUMAN HEALTH 

2 The human health issues applicable to KPS are discussed below and listed in Table 4-14 for 

3 Category 1, Category 2, and uncategorized issues. 

4 Table 4-14. Human Health Issues. Table B-1 of Appendix B to Subpart A of 10 CFR Part 51 

5 contains more information on these issues. 

Issues GEIS Section Category 

Microbiological organisms (occupational health) 4.3.6 1 

Noise 4.3.7 1 

Radiation exposures to public (license renewal term) 4.6.1, 4.6.2 1 

Occupational radiation exposures (license renewal term) 4.6.3 1 

Electromagnetic fields – acute effects (electric shock) 4.5.4.1 2 

Electromagnetic fields – chronic effects 4.5.4.2 Uncategorized 

6 4.8.1 Generic Human Health Issues 

7 The NRC staff did not identify any new and significant information regarding generic human 

8 health issues during its review of the Environmental Report, the site audit, or the scoping 

9 process. Therefore, there are no impacts related to these issues beyond those discussed in the 

10 GEIS. For these issues, the GEIS concluded that the impacts are SMALL, and additional site11 specific mitigation measures are not likely to be sufficiently beneficial to be warranted. The 

12 information presented below is a discussion of selected radiological programs conducted at 

13 KPS which monitor the impacts of radioactive effluents on the environment and members of the 

14 public. 

15 4.8.1.1 Radiological Environmental Monitoring 

16 KPS conducts a Radiological Environmental Monitoring Program (REMP) in the environs 

17 around their site to assess the radiological impact, if any, to its employees, the public, and the 

18 environment. KPS issues an annual environmental monitoring report which contains a 

19 discussion of the environmental data, and includes graphs which trend the data from prior 

20 years. The objectives of the REMP are to include the following: 

21 ● Measure and evaluate the levels of radiation and radioactive material in the environs 

22 around the KPS site to assess the radiological impacts, if any, of plant operation on the 

23 environment. 

24 ● Supplement the results of the radiological effluent monitoring program by verifying that 

25 the measurable concentrations of radioactive material and levels of radiation are not 

26 higher than expected based on the measurement of radioactive effluents and modeling 

27 for the applicable exposure pathways. 

28 ● Provide data on the radiation dose to the public by direct or indirect pathways of 

29 exposure. 
Environmental Impacts of Operation 

February 2010 4-23 Draft NUREG-1437, Supplement 40 

1 ● Demonstrate compliance with applicable Federal regulatory requirements. 

2 The KPS REMP collects samples of environmental media in the environs around the site for 

3 analysis to measure the amount of radioactivity, if any, in the samples. The media samples are 

4 representative of the radiation exposure pathways to the public from all plant radioactive 

5 effluents. The REMP measures the aquatic, terrestrial, and atmospheric environment for 

6 radioactivity, as well as ambient gamma radiation. Ambient gamma radiation pathways include 

7 radiation from buildings, plant structures, and airborne material that may be released from the 

8 plant. In addition, the REMP also measures background radiation (i.e., cosmic sources, global 

9 fallout, and naturally occurring radioactive material, including radon). Thermoluminescent 

10 dosimeters are used to measure direct radiation. The atmospheric environmental monitoring 

11 consists of sampling the air for particulates and radioiodine. Terrestrial environmental 

12 monitoring consists of analyzing samples of milk and food products. The aquatic environmental 

13 monitoring consists of analyzing samples of surface water, drinking water ground water, fish, 

14 and sediment from Lake Michigan. There is also an onsite ground water protection program 

15 designed to monitor the onsite plant environment for indication of leaks from plant systems and 

16 pipes carrying radioactive liquid. 

17 The NRC staff reviewed the KPS radioactive environmental monitoring reports from 2004 

18 through 2008 to look for any significant impacts to the environment or any unusual trends in the 

19 data (DEK 2005, 2006, 2007, 2008a, 2009). The NRC staff’s review of the KPS REMP reports 

20 showed no unusual trends in the data and showed no measurable impact from the operations at 

21 KPS on the environment. 

22 The Wisconsin Department of Health Services (WDHS) conducts a yearly independent 

23 comprehensive environmental radioactivity survey program around the two nuclear power plant 

24 sites, KPS and Point Beach Nuclear Plant (PBNP), in Wisconsin. The program collects various 

25 types of samples of environmental media, similar to that obtained by KPS, from the environs 

26 around the KPS site. The sampling program includes samples of air, precipitation, ambient 

27 gamma radiation, surface water, fish, shoreline sediment, soil, milk, well water, and vegetation. 

28 The NRC staff reviewed the WDHS 2007 environmental survey program report for the KPS and 

29 PBNP sites. The state reported that it observed radioactivity levels associated with natural 

30 background and fallout from atmospheric weapons testing. No radioactivity attributable to the 

31 operation of the KPS and PBNP was observed (WDHS, 2008). 

32 Based on the review of the radiological environmental monitoring data from KPS and the 

33 WDHS, the NRC staff concludes that there are no measurable radiological impacts from the 

34 operations at KPS on the environment. 

35 4.8.1.2 Radioactive Effluent and Dose Information 

36 The NRC staff reviewed KPS historical data on radioactive releases and the calculated dose to 

37 a hypothetical maximally exposed individual to verify that the doses are within the dose limits 

38 specified in 10 CFR Part 20 and are as low as reasonably achievable (ALARA) per the dose 

39 design objectives in Appendix I to 10 CFR Part 50. 
Environmental Impacts of Operation 

Draft NUREG-1437, Supplement 40 4-24 February 2010 

1 Dose estimates for members of the public are calculated based on liquid and gaseous effluent 

2 release data and atmospheric and aquatic transport models. The KPS 2008 annual radioactive 

3 effluent release report (DEK, 2009) contains a detailed presentation of radioactive discharges 

4 and the resultant calculated doses. The following summarizes the calculated hypothetical 

5 maximum dose to an individual located at the KPS site boundary from radioactive liquid and 

6 gaseous effluents released during 2008: 

7 ● The maximum whole-body dose to an offsite member of the public from liquid effluents 

8 was 1.04 E-03 milliroentgen equivalent man (mrem) (1.04 E-05 millisievert (mSv), 

9 which is below the 3 mrem (0.03 mSv) dose criterion in Appendix I to 10 CFR Part 50. 

10 ● The maximum organ (gastro-intestinal tract) dose to an offsite member of the public 

11 from liquid effluents was 4.19 E-03 mrem (4.19 E-05 mSv), which is below the 10 

12 mrem (0.1 mSv) dose criterion in Appendix I to 10 CFR Part 50. 

13 ● The maximum air dose at the site boundary from gamma radiation in gaseous effluents 

14 was 4.21 E-06 mrad (4.21 E-08 mGy which is below the 10 mrad (0.1 mGy) dose 

15 criterion in Appendix I to 10 CFR Part 50. 

16 ● The maximum air dose at the site boundary from beta radiation in gaseous effluents 

17 was 1.07 E-05 mrad (1.07 E-07 mGy), which is below the 20 mrad (0.2 mGy) dose 

18 criterion in Appendix I to 10 CFR Part 50. 

19 ● The maximum organ (liver) dose to an offsite member of the public from radioactive 

20 iodine and radioactive particulate material in gaseous effluents was 5.55 E-04 mrem 

21 (5.55 E-06 mSv), which is below the 15 mrem (0.15 mSv) dose criterion in Appendix I 

22 to 10 CFR Part 50. 

23 Based on the NRC staff review and assessment of the KPS radioactive waste system 

24 performance in controlling radioactive effluents and the resultant doses to members of the 

25 public in conformance with the ALARA criteria, the NRC staff found that the 2008 radiological 

26 effluent data for KPS are consistent, with reasonable variation attributable to operating 

27 conditions and outages and with the 5-year historical radiological effluent releases and resultant 

28 doses. These results demonstrate that KPS is operating in compliance with Federal radiation 

29 protection standards contained in 10 CFR Part 20 and Appendix I to 10 CFR Part 50. 

30 The applicant has no plans to conduct refurbishment activities during the license renewal term, 

31 thus, no change to radiological conditions is expected. Continued compliance with regulatory 

32 requirements is expected during the license renewal term. Thus, the radiological impacts are not 

33 expected to change during the license renewal term and there are no impacts beyond those 

34 discussed in the GEIS. Therefore, the NRC staff concludes that the radiological impacts to 

35 human health from the continued operation of KPS during the license renewal term would be 

36 SMALL. 

37 4.8.2 Electromagnetic Fields – Acute Shock 

38 Based on the GEIS, the NRC found that electric shock resulting from direct access to energized 

39 conductors or from induced charges in metallic structures has not been a problem at most 

40 operating plants and generally is not expected to be a problem during the period of extended 
Environmental Impacts of Operation 

February 2010 4-25 Draft NUREG-1437, Supplement 40 

1 operation. However, a site-specific review is required to determine the significance of the 

2 electric shock potential along the portions of the transmission lines within the scope of the SEIS. 

3 The GEIS states that it is not possible to determine the significance of the electric shock 

4 potential without a review of the conformance of each nuclear plant transmission line with 

5 National Electrical Safety Code (NESC) and Institute of Electrical and Electronics Engineers 

6 (IEEE) 2007 criteria. Evaluation of individual plant transmission lines is necessary because the 

7 issue of electric shock safety was not addressed in the licensing process for some plants. For 

8 other plants, land use in the vicinity of transmission lines may have changed, or power 

9 distribution companies may have chosen to upgrade line voltage. To comply with 10 CFR, Part 

10 51.53(c)(3)(ii)(H), the applicant must provide an assessment of the potential shock hazard if the 

11 transmission lines that were constructed for the specific purpose of connecting the plant to the 

12 transmission system do not meet the recommendations of the NESC for preventing electric 

13 shock from induced currents. 

14 As a result of the Wisconsin Legislature Act 9 of 1999, Wisconsin Public Service Corporation 

15 and Wisconsin Power and Light Company (owners of KPS at the time) transferred ownership of 

16 their transmission lines to ATC. The transmission Interconnection Agreement for KPS between 

17 ATC, DEK, and Midwest Independent Transmission System Operator (MISO) constitutes that 

18 ATC is the transmission system operator and MISO is the independent system operator. 

19 All transmission lines associated with KPS were constructed in accordance with National 

20 Electric Safety Code (NESC) and industry guidance in effect at that time (AEC, 1972). Since the 

21 lines were constructed, a new criterion has been added to the NESC for power lines with 

22 voltages exceeding 98 Kilovolt (kV). This criterion states that the minimum clearance for a line 

23 must limit induced currents due to static effects to 5 milliamperes (mA). ATC has reviewed the 

24 transmission lines for compliance with this criterion (DEK, 2008) and indicated that all 

25 transmission lines within the scope of this review have been restudied. The results show there 

26 are no locations under the transmission lines that have the capacity to induce more than 5 mA 

27 in a vehicle parked beneath them. No induced shock hazard to the public should occur, since 

28 the lines are operating within original design specifications and meet current NESC clearance 

29 standards. 

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

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

32 for electric shock resulting from operation of KPS and its associated transmission lines. The 

33 NRC staff concludes that the potential impacts from electric shock during the renewal period 

34 would be SMALL. 

35 The NRC staff identified a variety of measures that could mitigate potential acute 

36 electromagnetic fields (EMF) impacts resulting from continued operation of the KPS 

37 transmission lines. These mitigation measures would include erecting barriers along the length 

38 of the transmission line to prevent unauthorized access to the ground beneath the conductors 

39 and installing road signs at road crossings. These mitigation measures could reduce human 

40 health impacts by minimizing public exposures to electric shock hazards. The NRC staff did not 

41 identify any cost benefit studies applicable to the mitigation measures mentioned above. 
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Draft NUREG-1437, Supplement 40 4-26 February 2010 

1 4.8.3 Electromagnetic Fields – Chronic Effects 

2 In the GEIS, the chronic effects of 60-Hz EMFs from power lines were not designated as 

3 Category 1 or 2, and will not be, until a scientific consensus is reached on the health 

4 implications of these fields. 

5 The potential for chronic effects from these fields continues to be studied and is not known at 

6 this time. The National Institute of Environmental Health Sciences (NIEHS) directs related 

7 research through the U.S. Department of Energy (DOE). The report by NIEHS (1999) contains 

8 the following conclusion which is supported by recently published Environmental Health Criteria 

9 Monograph No. 238: 

10 The NIEHS concludes that ELF-EMF [extremely low frequency-electromagnetic 

11 field] exposure cannot be recognized as entirely safe because of weak scientific 

12 evidence that exposure may pose a leukemia hazard. In our opinion, this finding 

13 is insufficient to warrant aggressive regulatory concern. However, because 

14 virtually everyone in the United States uses electricity and therefore is routinely 

15 exposed to ELF-EMF, passive regulatory action is warranted such as a continued 

16 emphasis on educating both the public and the regulated community on means 

17 aimed at reducing exposures. The NIEHS does not believe that other cancers or 

18 non-cancer health outcomes provide sufficient evidence of a risk to currently 

19 warrant concern. 

20 This statement was not sufficient to cause the NRC staff to change its position with respect to 

21 the chronic effects of electromagnetic fields. This position is expressed in footnote 5 of Table B22 1 of Appendix B to Subpart A of 10 CFR Part 51: 

23 If, in the future, the Commission finds that, contrary to current indications, a 

24 consensus has been reached by appropriate Federal health agencies that there 

25 are adverse health effects from electromagnetic fields, the Commission will 

26 require applicants to submit plant-specific reviews of these health effects as part 

27 of their license renewal applications. Until such time, applicants for license 

28 renewal are not required to submit information on this issue. 

29 The NRC staff considers the GEIS finding of “uncertain” still appropriate and will continue to 

30 follow developments on this issue. 

31 4.9 SOCIOECONOMICS 

32 Category 1 issues in 10 CFR Part 51, Subpart A, Appendix B, Table B–1, which are applicable 

33 to socioeconomic impacts during the renewal term are listed in Table 4-15. As stated in the 

34 GEIS, the impacts associated with these Category 1 issues were determined to be SMALL, and 

35 plant-specific mitigation measures would not be sufficiently beneficial to be warranted. 

36 The NRC staff reviewed and evaluated the KPS Environmental Report, scoping comments, 

37 other available information, and visited KPS in search of new and significant information that 

38 would change the conclusions presented in the GEIS. No new and significant information was 

39 identified during this review and evaluation. Therefore, it is expected that there would be no 
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February 2010 4-27 Draft NUREG-1437, Supplement 40 

1 impacts related to these Category 1 issues during the renewal term beyond those discussed in 

2 the GEIS. 

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

ISSUE—10 CFR Part 51, Subpart A, Appendix B, Table B-1 GEIS Section 

Socioeconomics 

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 

Public services: education (license renewal term) 4.7.3.1 

Aesthetic impacts (license renewal term) 4.7.6 

Aesthetic impacts of transmission lines (license renewal term) 4.5.8 

4 4.9.1 Generic Socioeconomic Issues 

5 The results of the review and brief statement of GEIS conclusions, as codified in Table B-1 of 

6 10 CFR Part 51, Subpart A, Appendix B, for each of the socioeconomic Category 1 issues are 

7 provided below. 

8 Public services: public safety, social services, and tourism and recreation. Based on 

9 information in the GEIS, the NRC found that: 

10 Impacts to public safety, social services, and tourism and recreation are 

11 expected to be of small significance at all sites. 

12 Public services: education (license renewal term). Based on information in the GEIS, the 

13 NRC found that: 

14 Only impacts of small significance are expected. 

15 Aesthetic impacts (license renewal term). Based on information in the GEIS, the NRC found 

16 that: 

17 No significant impacts are expected during the license renewal term. 

18 Aesthetic impacts of transmission lines (license renewal term). Based on information in the 

19 GEIS, the NRC found that: 

20 No significant impacts are expected during the license renewal term. 

21 No new and significant information was identified for these issues during the review. Therefore, 

22 it is expected that there would be no impacts during the renewal term beyond those discussed 

23 in the GEIS. 

24 Table 4.16 lists the Category 2 socioeconomic issues, which require plant-specific analysis, and 

25 an environmental justice impact analysis that was not addressed in the GEIS. 
Environmental Impacts of Operation 

Draft NUREG-1437, Supplement 40 4-28 February 2010 

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

2 During the Renewal Term 

ISSUE—10 CFR Part 51, Subpart A, 

Appendix B, Table B-1 GEIS Section 

10 CFR 51.53(c)(3)(ii) 

Subparagraph SEIS Section

Socioeconomics 

Housing impacts 4.7.1 I 4.4.1 

Public services: public utilities 4.7.3.5 I 4.4.2 

Offsite land use (license renewal term) 4.7.4 I 4.4.3 

Public services: transportation 4.7.3.2 J 4.4.4 

Historic and archaeological resources 4.7.7 K 4.4.5 

Environmental justice Not addressed(a) Not addressed(a) 4.4.6 

(a) Guidance related to environmental justice was not in place at the time the GEIS and the associated 

revision to 10 CFR Part 51 were prepared. Therefore, environmental justice must be addressed in plantspecific reviews. 

3 4.9.2 Housing Impacts 

4 Appendix C of the GEIS presents a population characterization method based on two factors, 

5 sparseness and proximity (GEIS, Section C.1.4). Sparseness measures population density 

6 within 20 miles (32 km) of the site, and proximity measures population density and city size 

7 within 50 miles (80 km). Each factor has categories of density and size (GEIS, Table C.1). A 

8 matrix is used to rank the population category as low, medium, or high (GEIS, Figure C.1). 

9 According to the 2000 Census, approximately 86,224 people lived within 20 miles of KPS, which 

10 equates to a population density of 132 persons per square mile (DEK, 2008). This density 

11 translates to GEIS Category 4, least sparse (greater than, or equal to, 120 persons per square 

12 mile within 20 miles). Approximately 723,900 people live within 50 miles of KPS (DEK, 2008). 

13 This equates to a population density of 202 persons per square mile. Applying the GEIS 

14 proximity measures, KPS is classified as proximity Category 4 (greater than, or equal to, 

15 190 persons per square mile within 50 miles). Therefore, according to the sparseness and 

16 proximity matrix presented in the GEIS, rankings of sparseness Category 4 and proximity 

17 Category 4 result in the conclusion that KPS is located in a high population area. 

18 Since Kewaunee, Manitowoc, and Brown counties are not subject to growth control measures 

19 that would limit housing development, any changes in employment at KPS would have little 

20 noticeable effect on housing availability in these counties. Considering that DEK has no plans to 

21 add non-outage employees during the license renewal period, employment levels at KPS would 

22 remain relatively constant with no additional demand for permanent housing during the license 

23 renewal term. Based on this information, there would be no impact on housing during the 

24 license renewal term beyond what has already been experienced. 
Environmental Impacts of Operation 

February 2010 4-29 Draft NUREG-1437, Supplement 40 

1 4.9.3 Public Services: Public Utilities 

2 Impacts on public utility services are considered SMALL if the existing infrastructure could 

3 accommodate any plant-related demand without a noticeable effect on the level of service. 

4 Impacts are considered MODERATE if the demand for service or use of the infrastructure is 

5 sizeable and would noticeably decrease the level of service or require additional resources to 

6 maintain the level of service. Impacts are considered LARGE when new programs, upgraded or 

7 new facilities, or substantial additional staff is needed because of plant-related demand. In the 

8 absence of new and relevant information to the contrary, the only significant impacts on public 

9 utilities would be on public water supplies. 

10 Analysis of impacts on the public water systems considered both plant demand and plant11 related population growth. Section 2.1.3 of this draft SEIS describes the permitted withdrawal 

12 rate and actual use of water for reactor cooling at KPS. 

13 Because DEK has no plans to add non-outage employees during the license renewal period, 

14 employment levels at KPS would remain relatively unchanged with no additional demand for 

15 public water services. Public water systems in the region would be adequate to meet the 

16 demands of residential and industrial customers in the area. Therefore, there would be no 

17 additional impact to public water services during the license renewal term beyond what is 

18 currently being experienced. 

19 4.9.4 Offsite Land Use 

20 Offsite land use during the license renewal term is a Category 2 issue. Table B-1 of 10 CFR 

21 Part 51, Subpart A, Appendix B notes that, "significant changes in land use may be associated 

22 with population and tax revenue changes resulting from license renewal." 

23 Section 4.7.4 of the GEIS defines the magnitude of land-use changes as a result of plant 

24 operation during the license renewal term as follows: 

25 ● SMALL - Little new development and minimal changes to an area's land-use pattern. 

26 ● MODERATE - Considerable new development and some changes to the land-use 

27 pattern. 

28 ● LARGE - Large-scale new development and major changes in the land-use pattern. 

29 Tax revenue can affect land use because it enables local jurisdictions to provide the public 

30 services (e.g., transportation and utilities) necessary to support development. Section 4.7.4.1 of 

31 the GEIS states that the assessment of tax-driven land-use impacts during the license renewal 

32 term should consider: (1) the size of the plant’s tax payments relative to the community’s total 

33 revenues, (2) the nature of the community’s existing land-use pattern, and (3) the extent to 

34 which the community already has public services in place to support and guide development. 

35 If the plant’s tax payments are projected to be small relative to the community’s total revenue, 

36 tax-driven land-use changes during the plant’s license renewal term would be SMALL, 

37 especially where the community has pre-established patterns of development and has provided 

38 public services to support and guide development. Section 4.7.2.1 of the GEIS states that if new 
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Draft NUREG-1437, Supplement 40 4-30 February 2010 

1 tax payments are less than 10 percent of the taxing jurisdiction’s revenue, the significance level 

2 would be SMALL. If tax payments are 10 to 20 percent of the community’s total revenue, new 

3 tax driven land-use changes would be MODERATE. If tax payments are greater than 20 percent 

4 of the community’s total revenue, new tax-driven land-use changes would be LARGE. This 

5 would be especially true where the community has no pre-established pattern of development or 

6 has limited public services available to support and guide development. 

7 4.9.4.1 Population-Related Impacts 

8 DEK has no plans to add non-outage employees during the license renewal period. Therefore, 

9 there would be no plant operations-driven population increase in the vicinity of KPS. 

10 Additionally, there would be no population-related offsite land use impacts during the license 

11 renewal term beyond what has already been experienced. 

12 4.9.4.2 Tax-Revenue-Related Impacts 

13 As previously discussed in Chapter 2, by state law, DEK makes annual gross revenue tax 

14 Payments In Lieu Of Taxes (PILOT) to the State of Wisconsin. Since DEK started making 

15 payments, population levels and land use conditions have not changed significantly, which 

16 might indicate that these tax revenues have had little or no effect on land use activities within 

17 the county. 

18 Beginning in 2009, the Wisconsin Department of Revenue changed the methodology for 

19 computing the utility aid payment. Because of pending changes to the Wisconsin Shared 

20 Revenue Program (WSRP) methodology for taxing public utilities in the State of Wisconsin, it is 

21 anticipated that KPS will be taxed differently beginning in tax-year 2009. The estimated WSRP 

22 Utility payment from the State of Wisconsin to the town of Carlton and Kewaunee County will 

23 increase over previous years. Although these changes will increase the size of the payment, the 

24 overall tax-revenue-related impact from KPS in Kewaunee County and the town of Carlton will 

25 not change because KPS does not directly pay taxes to these jurisdictions and there is no direct 

26 correlation between the amount of taxes KPS pays to the State of Wisconsin and the distribution 

27 of funds to local jurisdictions. 

28 DEK has no plans to add non-outage employees during the license renewal period. Therefore, 

29 employment levels would remain relatively unchanged. After the 2009 tax payment increase, 

30 annual PILOT payments would likely remain unchanged throughout the license renewal period. 

31 Based on this information, there would be no tax-revenue-related offsite land use impacts during 

32 the license renewal term beyond what has already been experienced. 

33 4.9.5 Public Services: Transportation Impacts During Operations 

34 Table B-1, 10 CFR Part 51 states: “Transportation impacts (level of service) of highway traffic 

35 generated... during the term of the renewed license are generally expected to be of small 

36 significance. However, the increase in traffic associated with additional workers and the local 

37 road and traffic control conditions may lead to impacts of moderate or large significance at some 

38 sites.” All applicants are required by 10 CFR, Part 51.53(c)(3)(ii)(J) to assess the impacts of 

39 highway traffic generated by the proposed project on the level of service of local highways 

40 during the term of the renewed license. 
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February 2010 4-31 Draft NUREG-1437, Supplement 40 

1 Since DEK has no plans to add non-outage employees during the license renewal period, there 

2 would be no noticeable change in traffic volume and levels of service on roadways in the vicinity 

3 of KPS. Therefore, there would be no transportation impacts during the license renewal term 

4 beyond what is currently being experienced. 

5 4.9.6 Historic and Archaeological Resources 

6 The National Historic Preservation Act (NHPA) requires Federal agencies to consider the effects 

7 of their undertakings on historic properties. Historic properties are defined as resources that are 

8 eligible for listing on the National Register of Historic Places (NRHP). The criteria for eligibility 

9 are listed in Title 36, “Parks, Forests, and Public Property,” Part 60, Section 4, “Criteria for 

10 Evaluation,” of the Code of Federal Regulations (36 CFR Part 60.4) and include: (1) association 

11 with significant events in history; (2) association with the lives of persons significant in the past; 

12 (3) distinctive characteristics of type and period of construction, and (4) sites or places that have 

13 yielded or are likely to yield important information (Advisory Council on Historic Preservation 

14 (ACHP) 2009). The historic preservation review process (Section 106 of the NHPA) is outlined 

15 in regulations issued by the ACHP in Title 36, “Parks, Forests, and Public Property,” Part 800, 

16 “Protection of Historic Properties,” of the Code of Federal Regulations (36 CFR Part 800). 

17 The issuance of a renewed operating license for a nuclear power plant is a Federal action that 

18 could affect historic properties on or near the nuclear plant site and transmission lines. In 

19 accordance with the provisions of the NHPA, the NRC is required to make a reasonable effort to 

20 identify historic properties included in, or eligible for inclusion in, the NRHP in the area of 

21 potential effect (APE). The APEs for license renewal are the nuclear power plant site, 

22 transmission lines, and immediate environs. If historic properties are present, the NRC is 

23 required to contact the State Historic Preservation Office (SHPO), assess the potential impact, 

24 and resolve any possible adverse effects of the undertaking (license renewal) on historic 

25 properties. The NRC is also required to notify the SHPO if historic properties would not be 

26 affected by license renewal or if no historic properties are present. 

27 Dominion contacted the Wisconsin Historical Society (WHS) in February requesting information 

28 on historic and archaeological resources in the vicinity of KPS and describing the proposed 

29 action (license renewal) (DEK, 2008). In October 2007, Dominion forwarded its Phase 1 

30 Archaeological Survey (AVD Archaeological Services, Inc. (AVD)) to the WHS for review and 

31 comment (DEK, 2008). In December 2007, the WHS concurred with the archaeological 

32 assessment (WHS, 2007). 

33 In accordance with 36 CFR 800.8(c), the NRC contacted the WHS (NRC 2008a), the Advisory 

34 Council on Historic Preservation (NRC, 2008b), and Federally-recognized American Indian 

35 Tribes to initiate Section 106 consultation. These letters are presented in Appendix D. 

36 As discussed in Section 2.2.9, a search of the WHS site files identified no previously recorded 

37 historic properties at KPS; however, the AVD report indicates that portions of site 47KE72 could 

38 extend onto KPS property. In addition, there are no eligible or listed NRHP properties located on 

39 the KPS site. 

40 A review of WHS records found only 141 historic and archaeological sites within Kewaunee 

41 County compared with more than 500 each for bordering Manitowoc, Brown, and Door counties 
Environmental Impacts of Operation 

Draft NUREG-1437, Supplement 40 4-32 February 2010 

1 (AVD, 2007). Only fourteen archaeological sites have been recorded in Carlton Township. Five 

2 of these sites are cemeteries and the remaining are pre-contact sites (AVD, 2007). Three 

3 archaeological sites are located within one mile of the KPS site. 

4 In 2007, DEK contracted with AVD to conduct a Phase 1 survey of the KPS site. Approximately 

5 80 acres of the site were heavily disturbed from construction of KPS. A majority of the remaining 

6 land is open grassland and approximately 407 acres are leased agricultural cropland (AVD, 

7 2007). The survey identified three known archaeological sites (47KE10, 47KE72, and 47KE44 

8 [BKE-0044]) within one mile of KPS and nine new isolated artifact finds on the KPS site. 

9 However, there remains a potential for additional prehistoric sites and historic (camp) sites to be 

10 in the area. This area was part of the Potawatomi hunting, farming, and gathering lands. In 

11 addition, historical records indicate that American Indians utilized the Sandy Bay area for fishing 

12 and hunting. 

13 The area in the vicinity of KPS was also settled by Euro-Americans who farmed the area prior to 

14 the construction of KPS. While there are no visible remnants of the former farmhouses and 

15 outbuildings at KPS, subsurface portions of these buildings could remain. During NRC’s 

16 walkover survey, the staff noted the presence of barbed wire fencing, farm equipment, 

17 rudimentary farm bridges, and historic artifact scatters on KPS property. 

18 Site 47KE10 is a campsite/village of unknown prehistoric affiliation. Very little information about 

19 this site exists within the WHS database. The site is located offsite and would not be affected by 

20 plant operation. 

21 In 1996, site 47KE72 was recorded and listed as a Late Archaic site of unknown purpose. The 

22 extent of this site remains undetermined. Portions of this archaeological site could extend onto 

23 the KPS site. According to the site file, previous land owners recovered a few artifacts which 

24 remain in a private collection. Any land disturbing activities near 47KE72 should be surveyed 

25 prior to any disturbance. 

26 Site 47KE44 is the Sandy Bay Cemetery (St. John’s Cemetery) and was associated with St. 

27 John’s Church. The church was founded in 1869 and the congregation disbanded in 1947. The 

28 church no longer exists; however, subsurface portions of the church could remain. Burials 

29 associated with fifteen families are located in this cemetery with the last burial dating to 1943. In 

30 1969, the cemetery was turned over to Carlton Township (AVD, 2007). The township maintains 

31 the cemetery. 

32 Nine locations on the KPS site yielded artifacts. Location #71 was a scatter of nineteenth to 

33 twentieth century (domestic) artifacts found in the vicinity of a former farm. A single diagnostic 

34 point was recovered at location #72, which could date to either the Late Archaic or Woodland 

35 time periods (AVD, 2007). No other lithics materials were recovered in this area. One thermally 

36 altered piece of chert was recovered from Location #73. AVD noted that this piece of chert was 

37 probably pushed to this location during construction of KPS. One chert diagnostic fragment 

38 (Location #74) was recovered in a cultivated field. The fragment appears to date to the Middle 

39 Woodland Period. A uniface of off-white chert was found at Location #75. There is no sign of 

40 utilization on the edge of the piece (AVD, 2007). No other lithics materials were recovered from 

41 this location. 
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February 2010 4-33 Draft NUREG-1437, Supplement 40 

1 A projectile point chert tip was recovered from Location #76. No temporal affiliation can be 

2 assigned to this point. An oolitic chert projectile point fragment that potentially dates to either the 

3 Late Archaic or Woodland time periods was recovered from Location #77 (AVD, 2007). A side 

4 notched chert projectile point (tip missing) was found at Location 78. This point bears 

5 resemblance to the Madison side-notched type (AVD, 2007). A possible chert tool which had 

6 indications of pressure flaking on one edge was recovered at Location #79 (AVD, 2007). In total, 

7 one historic scatter, five projectile point fragments, one possible chert scraping or cutting tool, 

8 and two possible tools. These finds indicate that pre-contact American Indians hunted in this 

9 area and provides evidence of Euro-American occupation. According to AVD, all farmstead10 related artifacts are out of context due to the demolition of the buildings prior to the construction 

11 of KPS. The fixed projectile point fragments and three pieces of chert were single items found 

12 without context or association with other artifacts. AVD stated that either the projectile points 

13 were merely discarded or lost in use, or later dispersed/damaged by farm equipment (AVD, 

14 2007). 

15 DEK is in the process of revising its procedures and establishing a Cultural Resources 

16 Protection Plan for the protection of historic and archaeological resources at KPS. In its plan, 

17 KPS has an inadvertent discovery (stop work) provision. Should historic and archaeological 

18 resources be encountered during land disturbing activities, work will be halted and the WHS will 

19 be consulted for guidance. 

20 DEK currently has no planned changes or ground disturbing activities associated with license 

21 renewal at KPS. However, given the potential for the discovery of additional historic and 

22 archaeological resources at the KPS site, DEK needs to ensure that these resources are 

23 considered prior to any ground disturbance during future plant operations and maintenance 

24 activities. DEK currently has a stop work order within its Cultural Resource Protection Plan and 

25 procedures to ensure that proper notification is taken to protect these resources should they be 

26 discovered. 

27 Based on review of WHS archaeological file surveys, assessments, and other information, the 

28 potential impacts of continued operations and maintenance on historic and archaeological 

29 resources at KPS would be SMALL. DEK could reduce any potential impacts to historic and 

30 archaeological resources located at the KPS by training staff in the Section 106 consultation 

31 process and cultural awareness training to ensure that informed decisions are made prior to any 

32 ground disturbing activities. In addition, KPS may also forward its Cultural Resources Protection 

33 Plan to the WHS for review and comment. This will ensure that historic and archaeological 

34 resources are protected at the KPS site. Any revisions to the Cultural Resources Protection 

35 Plan should be developed in consultation with the NRC and the WHS. In addition, lands not 

36 surveyed should be investigated by a qualified archaeologist prior to any ground disturbing 

37 activity. 

38 4.9.7 Environmental Justice 

39 Under Executive Order (E.O.) 12898 (59 FR Federal Register 7629), Federal agencies are 

40 responsible for identifying and addressing potential disproportionately high and adverse human 

41 health and environmental impacts on minority and low-income populations. In 2004, the 

42 Commission issued a Policy Statement on the Treatment of Environmental Justice Matters in 
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Draft NUREG-1437, Supplement 40 4-34 February 2010 

1 NRC Regulatory and Licensing Actions (69 FR 52040). That policy states: “The NRC is 

2 committed to the general goals of E.O. 12898, [and] will strive to meet those goals through its 

3 normal and traditional NEPA review process.” 

4 The Council of Environmental Quality (CEQ) provides the following information in Environmental 

5 Justice: Guidance Under the National Environmental Policy Act (NEPA) 1997: 

6 Disproportionately High and Adverse Human Health Effects. Adverse health 

7 effects are measured in risks and rates that could result in latent cancer fatalities, 

8 as well as other fatal or nonfatal adverse impacts on human health. Adverse 

9 health effects may include bodily impairment, infirmity, illness, or death. 

10 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 

12 population is significant (as defined by NEPA) and appreciably exceeds the risk 

13 or exposure rate for the general population or for another appropriate comparison 

14 group (CEQ, 1997). 

15 Disproportionately High and Adverse Environmental Effects. A 

16 disproportionately high environmental impact that is significant (as defined by 

17 NEPA) refers to an impact or risk of an impact on the natural or physical 

18 environment in a low-income or minority community that appreciably exceeds the 

19 environmental impact on the larger community. Such effects may include 

20 ecological, cultural, human health, economic, or social impacts. An adverse 

21 environmental impact is an impact that is determined to be both harmful and 

22 significant (as defined by NEPA). In assessing cultural and aesthetic 

23 environmental impacts, impacts that uniquely affect geographically dislocated or 

24 dispersed minority or low-income populations or American Indian tribes are 

25 considered (CEQ, 1997). 

26 The environmental justice analysis assesses the potential for disproportionately high and 

27 adverse human health or environmental effects on minority and low-income populations that 

28 could result from the operation of KPS during the renewal term. In assessing the impacts, the 

29 following CEQ (1997) definitions of minority individuals and populations and low-income 

30 population were used: 

31 Minority individuals. Individuals who identify themselves as members of the 

32 following population groups: Hispanic or Latino, American Indian or Alaska 

33 Native, Asian, Black or African American, Native Hawaiian or Other Pacific 

34 Islander, or two or more races meaning individuals who identified themselves on 

35 a Census form as being a member of two or more races, for example, Hispanic 

36 and Asian. 

37 Minority populations. Minority populations are identified when (1) the minority 

38 population of an affected area exceeds 50 percent, or (2) the minority population 

39 percentage of the affected area is meaningfully greater than the minority 

40 population percentage in the general population or other appropriate unit of 

41 geographic analysis. 
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February 2010 4-35 Draft NUREG-1437, Supplement 40 

1 Low-income population. Low-income populations in an affected area are 

2 identified with the annual statistical poverty thresholds from the Census Bureau’s 

3 Current Population Reports, Series PB60, on Income and Poverty. 

4 4.9.7.1 Minority Population in 2000 

5 The 50-mile radius around KPS includes 12 counties in Wisconsin. The geographic area 

6 includes any census block with all or part of its area within the 50-mile radius. According to 2000 

7 census data, 7.6 percent of the population (approximately 724,241 individuals) residing within a 

8 50-mile (80-km) radius of KPS identified themselves as minority individuals. The largest minority 

9 group was Hispanic or Latino (19,195 persons or 2.7 percent), followed by Asian (17,200 or 

10 about 2.4 percent) (USCB, 2003 – Land View 6). About 1.8 percent of the Kewaunee County 

11 population identified themselves as minorities, with Hispanic or Latino as the largest minority 

12 group (0.8 percent) followed by American Indian and Alaska Native (0.6 percent) (USCB, 2009) 

13 (see Table 2.2.8.5–2). 

14 Approximately 15 census block groups within 50 miles of KPS were determined to have high 

15 density minority population percentages that exceeded the state average by 20 percentage 

16 points or more. The largest number of high density minority block groups was Hispanic or 

17 Latino, with six census block groups that exceed the state average 20 percent or more. The 

18 greatest concentrations of high density minority population block groups are located near Green 

19 Bay, Wisconsin, or the Oneida Indian Reservation just west of Green Bay. No high density 

20 minority census block groups were found within 20 miles of KPS (DEK, 2008). The Oneida 

21 Nation Indian Reservation is located west of Green Bay, Wisconsin (Brown and Outagamie 

22 counties). 

23 Based on 2000 census data, Figure 4-1 shows the location of high density minority blocks within 

24 a 50-mile radius of KPS. 
Environmental Impacts of Operation 

Draft NUREG-1437, Supplement 40 4-36 February 2010 

1 

2 

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

4 (DEK, 2008; USCB, 2003) 
Environmental Impacts of Operation 

February 2010 4-37 Draft NUREG-1437, Supplement 40 

1 

2 4.9.7.2 Low-Income Population in 2000 

3 According to 2000 census data, approximately 7,418 families and 41,197 individuals 

4 (approximately 3.9 and 5.7 percent, respectively) residing within a 50-mile radius of KPS were 

5 identified as living below the Federal poverty threshold in 1999 (USCB, 2003 LandView 6). The 

6 1999 Federal poverty threshold was $17,029 for a family of four. 

7 According to census data estimates, the median household income for Wisconsin in 2007 was 

8 $50,567, with 10.8 percent of the State population living below the Federal poverty threshold. 

9 Kewaunee County had the highest median household income average ($53,356) and the lowest 

10 percentage (7.3 percent) of individuals living below the poverty level when compared to the 

11 State average and the other three counties. Manitowoc County had the lowest median 

12 household income of the four counties ($48,175) and a lower percentage (8.6 percent) of 

13 individuals living below the poverty level when compared to the State. Brown County had a 

14 median household income of $52,452 and the highest percentage (10.3 percent) of individuals 

15 living below the poverty level among the three counties (USCB, 2009). 

16 Census block groups were considered high density low-income block groups if the percentage 

17 of households below the Federal poverty threshold exceeded the State average by 20 percent 

18 or more. Based on 2000 Census data, there were 2 block groups within the 50-mile radius of 

19 KPS that exceeded the State average for low income households by 20 percent or more. The 

20 census block groups with low-income populations were located in Brown County and in Green 

21 Bay, Wisconsin (DEK, 2008). Figure 4-2 shows the location of the high density low-income 

22 census block groups within a 50-mile radius of KPS. 
Environmental Impacts of Operation 

Draft NUREG-1437, Supplement 40 4-38 February 2010 

1 

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

3 Station (DEK, 2008; USCB, 2003) 
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February 2010 4-39 Draft NUREG-1437, Supplement 40 

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 50-

4 mile radius of the KPS. Based on the analysis of environmental health and safety impacts 

5 presented in Chapter 4 of this draft 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 KPS during the license renewal period. 

8 The NRC analyzed the risk of radiological exposure through the consumption patterns of special 

9 pathway receptors, including subsistence consumption of fish, native vegetation, surface 

10 waters, sediments, and local produce. The NRC also analyzed the absorption of contaminants 

11 in sediments through the skin and inhalation of plant materials. The special pathway receptors 

12 analysis is important to the environmental justice analysis because consumption patterns may 

13 reflect the traditional or cultural practices of minority and low-income populations in the area. 

14 This analysis is presented below. 

15 4.9.7.4 Subsistence Consumption of Fish and Wildlife 

16 Section 4-4 of E.O. 12898 (1994) directs Federal agencies, whenever practical and appropriate, 

17 to collect and analyze information on the consumption patterns of populations that rely 

18 principally on fish and/or wildlife for subsistence and to communicate the risks of these 

19 consumption patterns to the public. The NRC staff considered whether or not there were any 

20 means for minority or low-income populations to be disproportionately affected by examining 

21 impacts to American Indian, Hispanic, and other traditional lifestyle special pathway receptors. 

22 In addition, the NRC staff considered special pathways that took into account the levels of 

23 contaminants in native vegetation, crops, soils and sediments, surface water, fish, and game 

24 animals in the vicinity of KPS. 

25 DEK has an ongoing comprehensive Radiological Environmental Monitoring Program (REMP) 

26 at KPS that assesses the radiological impact of site operations on the environment. The REMP 

27 program monitors radiation levels in atmospheric, terrestrial, and aquatic environments. All 

28 samples are collected by DEK personnel and are shipped to a laboratory for analysis. 

29 To assess the radiological impact of the plant on the environment, the monitoring program at 

30 KPS 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 KPS. The 

37 aquatic pathways include fish, surface water, slime, bottom sediment, and ground water. The 

38 terrestrial pathways include airborne particulates, milk, domestic meat, eggs, garden 

39 vegetables, grass and cattle feed, soil, and direct radiation. During 2007, analyses performed on 

40 collected samples of environmental media showed no significant or measurable radiological 

41 impact from KPS operations (DEK, 2008b). 
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Draft NUREG-1437, Supplement 40 4-40 February 2010 

1 Surface water sampling at KPS consists of monthly samples from three locations on Lake 

2 Michigan and three creeks (North, Middle, and South creeks) that pass through the site. All 

3 samples are analyzed for gamma-emitting isotopes. Tritium activity is measured through one 

4 composite sample from South Creek. All results from the 2007 REMP were below the required 

5 lower limit of detection (DEK, 2008b). 

6 In bottom sediment samples, the mean gross beta concentrations measured lower at the 

7 indicator locations than the control locations. Cesium-134 measured below detection levels in all 

8 samples. A low level of cesium-137 was observed in one of the two control samples tested. On 

9 average, cesium-137 measurements are lower than, or similar to, levels observed from 1979 

10 through 2006. Levels of strontium-89 and strontium-90 measured below respective detection 

11 limits in all samples (DEK, 2008b). 

12 In fish, gross beta concentration was primarily due to potassium-40 activity. A concentration of 

13 Cesium-137 was detected in one of three tested samples in levels lower than those observed 

14 between 1979 and 1991, but at similar levels to those seen from 1992 through 2006. The 

15 strontium-89 and strontium-90 concentrations were below detection levels in all samples (DEK, 

16 2008b). 

17 According to the 2007 KPS REMP, 126 milk samples were collected and analyzed for low-level 

18 iodine-131 by radiochemical separation. All samples were below detection levels. Naturally 

19 occurring potassium-40 results were almost identical in all samples. Strontium-89 

20 concentrations measured below detection levels in all samples. Low levels of strontium-90 were 

21 found in 62 of the 84 samples tested. Mean values were almost identical for indicator and 

22 control sample locations and are similar to or less than averages seen from 1990 through 2006 

23 (DEK, 2008b). 

24 Ground water was collected from two onsite wells and analyzed for tritium and gamma emitting 

25 radionuclides. All samples were tested for tritium and gamma emitting isotopes. Tritium 

26 concentrations measured below detection levels. Gamma-emitting isotopes measured below 

27 respective detection levels (DEK, 2008b). 

28 In domestic meat and egg samples, gross alpha concentration measured below detection levels 

29 for both indicator and control locations. Gamma-spectroscopic analyses showed that almost all 

30 beta activity was due to naturally occurring potassium-40. All other gamma-emitting isotopes 

31 were below their respective detection levels (DEK, 2008b). 

32 In vegetables, gamma-spectroscopic analyses showed that almost all beta activity was due to 

33 naturally occurring potassium-40 and was below respective levels of detection. Levels of 

34 strontium-89 and strontium-90 measured below their respective levels of detection (DEK, 

35 2008b). 

36 In two samples (clover and oats) gamma-spectroscopic analyses showed that almost all beta 

37 activity was due to naturally occurring potassium-40 and beryllium-7 observed in the samples. 

38 Beryllium-7 is produced continuously in the upper atmosphere by cosmic radiation. Other 

39 gamma-emitting isotopes were below their respective levels of detection. Levels of strontium-89 

40 and strontium-90 measured below their respective levels of detection (DEK, 2008b). 
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February 2010 4-41 Draft NUREG-1437, Supplement 40 

1 In grass and cattlefeed samples, gamma-spectroscopic analyses showed that almost all beta 

2 activity was due to naturally occurring potassium-40 and beryllium-7. Other gamma-emitting 

3 isotopes were below their respective levels of detection. Levels of strontium-89 measured below 

4 the levels of detection in grass and cattlefeed samples. Strontium-90 activity was found in one 

5 of twelve cattlefeed samples tested, and was similar or lower than levels observed from 1996 

6 through 2006 (DEK, 2008b). 

7 Gross alpha concentrations in soil samples at the indicator locations were similar to 

8 concentrations at the control locations. Levels of strontium-89 measured below the levels of 

9 detection. Low levels of strontium-90 activity were detected in nine of fourteen samples tested 

10 (DEK, 2008b). 

11 Low levels of cesium-137 were detected in 12 of 14 soil samples, similar at both indicator and 

12 control locations. Potassium-40 was detected in all samples and averaged the same at indicator 

13 and control locations. All other gamma-emitting isotopes were below their respective detection 

14 levels. These levels of detected activities are similar to those observed from 1990 through 2006. 

15 The data suggests no evidence of a plant effect on soil measurements (DEK, 2008b). 

16 The results of the KPS 2007 REMP sampling demonstrate that the routine operation at KPS has 

17 had no significant or measurable radiological impact on the environment. No elevated radiation 

18 levels were detected in the offsite environment as a result of plant operations and the storage of 

19 radioactive waste. The results of the REMP continue to demonstrate that the operation of the 

20 KPS did not result in a significant measurable dose to a member of the general population or 

21 adversely impact the environment as a result of radiological effluents. The REMP continues to 

22 demonstrate that the dose to a member of the public from the operation of KPS remains 

23 significantly below the Federally required dose limits specified in 10 CFR Part 20, 10 CFR Part 

24 72, and 40 CFR Part 190. 

25 Based on recent monitoring results, concentrations of contaminants in native leafy vegetation, 

26 soils and sediments, surface water, and fish in areas surrounding KPS have been quite low (at 

27 or near the threshold of detection) and seldom above background levels. Consequently, no 

28 disproportionately high and adverse human health impacts would be expected in special 

29 pathway receptor populations in the region as a result of subsistence consumption of fish and 

30 wildlife. 

31 4.10 EVALUATION OF NEW AND POTENTIALLY SIGNIFICANT INFORMATION 

32 The new and significant assessment process that DEK used during preparation of the KPS ER 

33 (DEK, 2008) license renewal application included: 

34 (1) Interviews with DEK, Dominion Resources Services, Inc., WPSC, and ATC subject 

35 experts on information related to the conclusions in the GEIS as they relate to KPS; 

36 (2) Review of DEK and KPS environmental management systems for how current 

37 programs manage potential impacts and/or provide mechanisms for KPS staff to 

38 become aware of new and significant information; 
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Draft NUREG-1437, Supplement 40 4-42 February 2010 

1 (3) Correspondence with State and Federal regulatory agencies to determine if the 

2 agencies had concerns; 

3 (4) Review of documents related to environmental issues at KPS and regional environs; 

4 (5) Credit for oversight provided by inspections of plant facilities and environmental 

5 monitoring operations by State and Federal regulatory agencies; and 

6 (6) Independent review of plant-related information contracted by DEK with industry 

7 experts on license renewal and environmental impacts. 

8 DEK stated in the KPS ER (DEK, 2008) that it is aware of no new and significant information 

9 regarding the environmental impacts of KPS license renewal. 

10 The NRC staff evaluated this information during its independent review of the KPS ER, the 

11 scoping process, the site audit, and interviews with knowledgeable DEK personnel. The NRC 

12 staff concluded that there is no new and significant information related to the environmental 

13 impacts of the KPS license renewal. 

14 4.11 CUMULATIVE IMPACTS 

15 The NRC staff considered potential cumulative impacts in its environmental analysis of 

16 continued operation of KPS. For the purposes of this analysis, past actions are those related to 

17 the resources at the time of the power plant licensing and construction; present actions are 

18 those related to the resources at the time of current operation of the power plant, and future 

19 actions are considered to be those that are reasonably foreseeable through the end of plant 

20 operation including the period of extended operation. Therefore, the analysis considers potential 

21 impacts through the end of the current license terms as well as the 20-year renewal license 

22 term. The geographic area over which past, present, and future actions would occur is 

23 dependent on the type of action considered and is described below for each impact area. 

24 The impacts of the proposed action, as described in Sections 4.1 through 4.9, are combined 

25 with other past, present, and reasonably foreseeable future actions regardless of what agency 

26 (Federal or non-Federal) or person undertakes such other actions. 

27 4.11.1 Cumulative Impacts on Water and Aquatic Resources 

28 This section addresses the impacts of the proposed action that relate to the withdrawal and 

29 discharge of lake water by the KPS once-through cooling system, combined with other past, 

30 present, and future actions that occur within the defined geographic area of Lake Michigan. The 

31 geographic area considered for the analysis of cumulative impacts on aquatic resources 

32 focuses on the western portion of Lake Michigan. 

33 The water quality of Lake Michigan directly affects the aquatic resources in the vicinity of KPS. 

34 Lake Michigan’s water quality in turn is affected, and will continue to be affected, by boating and 

35 fishing, agricultural runoff, and development along and near the waterfront. Water quality has 

36 been a recognized issue within the Great Lakes for over a century. The Great Lakes Water 

37 Quality Agreement, which was first signed in 1972, was formed to address the deteriorating 
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February 2010 4-43 Draft NUREG-1437, Supplement 40 

1 water quality within the Great Lakes. Numerous fish species in Lake Michigan have 

2 consumption advisories as a result of elevated levels of mercury. Atrazine and other compounds 

3 found in herbicides and pesticides also contribute to the lake’s water quality problems. These 

4 compounds affect water quality most in the spring and summer months, corresponding to 

5 agricultural production. Atrazine concentrations, specifically, may be increasing under present 

6 loads to Lake Michigan (Brent et al., 2001). However, with continued bi-national management 

7 efforts, including the Great Lakes Fishery Commission, Great Lakes Water Quality Agreements, 

8 and the International Joint Commission, which are discussed in Section 2.2.5, Aquatic 

9 Resources, water quality is expected to improve in the future. 

10 Lake Michigan has undergone drastic changes in its fish communities due to exotic species 

11 introductions. As discussed in Section 2.2.5, Aquatic Resources, the sea lamprey (Petromyzon 

12 marinus) and alewife (Alosa pseudoharengus) have had the most pronounced impact on native 

13 aquatic populations. Overfishing and predation by sea lamprey is thought to be responsible for 

14 the extirpation of lake trout (Salvelinus namaycush) in Lake Michigan (USGS, 2008). Sea 

15 lamprey have also led to the extinction of three deepwater cisco species: the long jaw cisco 

16 (Coregonus alpenae), the deepwater cisco (C. johannae), and the blackfin cicso (C. nigripinnis) 

17 (Fuller et al. 2007). Alewives negatively impact water clarity by consuming zooplankton, 

18 outcompeting native species for food, and also preying on other species’ eggs (Crowder 1980). 

19 Future management challenges will include keeping the salmonid community stable given the 

20 available forage base, and suppressing the alewife population growth to a level that does not 

21 threaten the continued existence of native species (Eshenroder et al. 1995). 

22 Point Beach Nuclear Plant (PBNP) is located about 5 miles (8 km) south of KPS along Lake 

23 Michigan. PBNP is a two-unit pressurized-water reactor plant with a once-through cooling 

24 system. PBNP received a renewed license through 2030 and 2033 for Units 1 and 2, 

25 respectively, and therefore, will continue to operate during the term of KPS’s continued 

26 operation. The PBNP SEIS (NRC, 2005) concluded that the impacts of continued operation of 

27 PBNP on the impingement and entrainment of aquatic organisms and heat shock to aquatic 

28 organisms are all SMALL. Studies at PBNP indicated that alewives and rainbow smelt 

29 (Osmerus mordax) were the primary species in both impingement and entrainment samples. 

30 Though both cooling systems alone have been determined to have a SMALL effect on aquatic 

31 organisms, the combined impact of KPS and PBNP on the alewife and rainbow smelt 

32 populations, specifically, may be noticeable, though these combined impacts have not been 

33 specifically studied and both the alewife and rainbow smelt are considered invasive, nuisance 

34 species. The PBNP SEIS concluded that cumulative impacts from heat shock are not expected 

35 to be any greater when both plants are considered because the KPS and PBNP heated 

36 discharge mixing zones do not overlap (NRC, 2005). 

37 The NRC staff has determined that the cumulative impacts on aquatic resources resulting from 

38 all past, present, and reasonably foreseeable future actions, including non-KPS actions, would 

39 be MODERATE. This designation is largely the result of past actions including water quality 

40 issues and native aquatic community destabilization due to invasive species introductions. 
Environmental Impacts of Operation 

Draft NUREG-1437, Supplement 40 4-44 February 2010 

1 4.11.2 Cumulative Impacts on Terrestrial Resources 

2 This section addresses past, present, and future actions that could result in adverse cumulative 

3 impacts to terrestrial resources, including wildlife populations, upland habitats, wetlands, Lake 

4 Michigan shoreline, riparian zones, invasive species, protected species, and land use. For 

5 purposes of this analysis, the geographic area considered in the evaluation includes the KPS 

6 site, the adjacent shoreline both to the north and south, any wetlands on the KPS site or 

7 adjacent to the KPS site, and the in-scope transmission line ROWs identified in section 2.1.5 of 

8 this draft SEIS. 

9 Before construction of KPS, terrestrial communities on the surrounding area supported forested 

10 habitat, wetland habitat, Lake Michigan coastline, and agricultural lands. With the construction 

11 of KPS, 60 acres (24 ha) were converted to developed areas for the reactor building and other 

12 plant structures. 

13 Construction of the transmission line ROWs maintained by ATC for the KPS site resulted in 

14 changes to the plant species, and possibly wildlife within the ROWs. Habitat fragmentation 

15 resulting from the transmission line ROWs likely caused effects such as change in light, wind, 

16 and temperature; an increased susceptibility to invasive species; and a possible reduction in 

17 habitat ranges for certain species. ROW maintenance has likely had past impacts and is likely to 

18 have present and future impacts on the terrestrial habitat, which may include the buildup of 

19 herbicides, prevention of natural selection stages, an increase in edge species, a decrease in 

20 interior species, and an increase in invasive species. Continuing to lease agricultural land to 

21 farmers for areas within the transmission line ROWs will help reduce some of these potential 

22 impacts. 

23 Neither DEK nor ATC manage invasive species on their land holdings. Therefore, a potential 

24 exists for invasive species to be introduced on or in the vicinity of the KPS site or its associated 

25 transmission line ROWs from present and future actions. Introduction of these species may 

26 contribute to the establishment of an invasive species population, which could compete with 

27 native populations for resources and degrade areas of terrestrial habitat. 

28 Erosion to the Lake Michigan shoreline on the KPS site and its associated transmission lines 

29 from activities such as boating and fishing have the potential for adverse cumulative impacts. 

30 Continued maintenance for erosion on the shoreline by KPS should minimize impacts. 

31 Prior and continued residential, commercial, agricultural, and industrial development of the 

32 areas surrounding the KPS site and its associated transmission line ROWs may impact 

33 terrestrial habitat in the area. Increases in both commercial and residential development have 

34 occurred in these areas over the past 40 years. As this area continues to grow, additional runoff 

35 from roads and impervious surfaces, development adjacent to wetlands and riparian zones, and 

36 an increase in waste releases could have future impacts on the terrestrial habitat. Section 

37 2.2.8.3 of this draft SEIS discusses offsite land use in the vicinity of KPS. 

38 The potential cumulative effects of climate change could result in a variety of changes to 

39 terrestrial resources on and around the KPS site. Increases in average annual temperature and 

40 increased frequency of heat waves, droughts, and heavy rainfall events all have the potential to 

41 impact wildlife populations, protected species, upland habitats, wetlands, riparian zones, and 
Environmental Impacts of Operation 

February 2010 4-45 Draft NUREG-1437, Supplement 40 

1 invasive species. Increased precipitation could change vegetation composition on the KPS site, 

2 potentially increasing wetlands, and decreasing riparian communities due to coastal erosion. 

3 Long-term effects of climate change on terrestrial resources could include a shift in forest 

4 composition or even an overall loss of forests, loss of bird diversity, a change in local mammal 

5 populations, and an increase in the range of invasive species and other pests (CEQ, 1997). 

6 The NRC staff believes that the cumulative impacts during the term of license renewal on 

7 terrestrial habitat and associated species, when added to past, present, and reasonably 

8 foreseeable future actions, would be SMALL. 

9 4.11.3 Cumulative Impacts on Human Health 

10 The NRC and the EPA established radiological dose limits for protection of the public and 

11 workers from both acute and long-term exposure to radiation and radioactive materials. These 

12 dose limits are codified in 10 CFR Part 20 and 40 CFR Part 190. As discussed in Section 4.8.1 

13 of this draft SEIS, the doses resulting from operation of KPS are below regulatory limits and the 

14 impacts of these exposures would be SMALL. For the purposes of this analysis, the 

15 geographical area considered is within a 50-mile (80-km) radius of the KPS site. 

16 EPA regulations at 40 CFR Part 190 limit the dose to members of the public from all sources in 

17 the nuclear fuel cycle, including nuclear power plants, fuel fabrication facilities, waste disposal 

18 facilities, storage of spent nuclear fuel in dry casks, and transportation of fuel and waste. In 

19 addition, as discussed in Section 4.8.1, KPS has conducted a radiological environmental 

20 monitoring program around its site since before operations began in 1974. This program 

21 measures radiation and radioactive materials from KPS and all other sources, including the 

22 nearby PBNP. 

23 PBNP is located approximately 5 miles south of KPS on the western shore of Lake Michigan in 

24 Manitowoc County, Wisconsin. PBNP has two pressurized-water reactors and an independent 

25 spent fuel storage installation. In 2005, the NRC completed a supplemental EIS regarding the 

26 PBNP license renewal application. The NRC concluded that the cumulative doses from PBNP 

27 and KPS were within the dose limits in 10 CFR Part 20 and 40 CFR Part 190 (NRC, 2005). 

28 As discussed in Section 4.8.1 of this report, the staff reviewed the radiological environmental 

29 radiation monitoring results for KPS for the five-year period from 2004 through 2008 as part of 

30 the cumulative impacts assessment. Cumulative radiological impacts from all uranium fuel cycle 

31 facilities within a 50-mile (80-km) radius of the KPS site, which includes PBNP, are limited by 

32 the dose limits in 10 CFR Part 20 and 40 CFR Part 190. Based on the NRC staff review of the 

33 radiological environmental monitoring data from KPS and the State of Wisconsin, the 

34 radioactive effluent release data from KPS, and the SEIS regarding the PBNP license renewal, 

35 the cumulative radiological impacts to the public from the operation of KPS during the renewal 

36 term would be SMALL. The NRC and the State of Wisconsin will regulate any future 

37 development or actions in the vicinity of the KPS site that could contribute to cumulative 

38 radiological impacts. Therefore, the NRC staff has concluded that the cumulative radiological 

39 impacts to human health from the continued operation of KPS during the license renewal term 

40 would be SMALL. 
Environmental Impacts of Operation 

Draft NUREG-1437, Supplement 40 4-46 February 2010 

1 The NRC staff determined that the electric-field-induced currents from the KPS transmission 

2 lines are well below the NESC recommendations for preventing electric shock from induced 

3 currents. Therefore, the KPS transmission lines do not detectably affect the overall potential for 

4 electric shock from induced currents within the analysis area. With respect to chronic effects of 

5 EMFs, although the GEIS finding of “not applicable” is appropriate to KPS, the transmission 

6 lines associated with KPS are not likely to detectably contribute to the regional exposure to ELF7 EMFs. Therefore, the NRC staff determined that the cumulative impacts of the continued 

8 operation of the KPS transmission lines would be SMALL. The NRC staff identified a variety of 

9 measures that could mitigate potential acute EMF impacts resulting from continued operation of 

10 the KPS’s transmission lines. These mitigation measures would include erecting barriers along 

11 the length of the transmission line to prevent unauthorized access to the ground beneath the 

12 conductors and installing road signs at road crossings. These mitigation measures could reduce 

13 human health impacts by minimizing public exposures to electric shock hazards. The NRC staff 

14 did not identify any cost benefit studies applicable to these mitigation measures. 

15 4.11.4 Cumulative Impacts on Socioeconomics 

16 As discussed in Section 4.4 of this draft SEIS, continued operation of KPS during the license 

17 renewal term would have no impact on socioeconomic conditions in the region beyond those 

18 already experienced. Since DEK has no plans to hire additional workers during the license 

19 renewal term, overall expenditures and employment levels at KPS would remain relatively 

20 constant with no additional demand for permanent housing and public services. In addition, 

21 since employment levels and tax payments would not change, there would be no population or 

22 tax revenue-related land use impacts. There would also be no disproportionately high and 

23 adverse health and environmental impacts on minority and low-income populations in the 

24 region. Based on this and other information presented in this chapter there would be no 

25 cumulative socioeconomic impacts from the continued operation of KPS during the license 

26 renewal term beyond what is currently being experienced. 

27 Any ground disturbing activities during the license renewal term could, however, result in the 

28 cumulative loss of historic and archaeological resources. Historic and archaeological resources 

29 are non-renewable; therefore, the loss of archaeological resources is cumulative. The continued 

30 operation of KPS during the license renewal term has the potential to impact historic and 

31 archaeological resources. 

32 As discussed in Section 4.9.6, continued operation of the KPS during the license renewal term 

33 would have a SMALL impact on archaeological resources. While archaeological surveys were 

34 not conducted prior to the construction of KPS, DEK has conducted a Phase I survey to identify 

35 historic and archaeological resources on the KPS site. DEK is also revising its corporate 

36 procedures and establishing a “Cultural Resources Protection Plan” to improve the protection of 

37 archaeological resources at KPS. DEK could also train staff to ensure that historic and 

38 archaeological resources are protected at the KPS site. 

39 DEK has no plans to alter the KPS site for license renewal. Any future land disturbing activities 

40 would be carried out under corporate procedures. These procedures have stop work provisions 

41 in the case of any inadvertent discoveries. Should plans change, further consultation would be 

42 initiated by DEK with the NRC and WHS. Because impacts to historic and archaeological 
Environmental Impacts of Operation 

February 2010 4-47 Draft NUREG-1437, Supplement 40 

1 resources from the continued operation of KPS would be SMALL, the cumulative environmental 

2 impacts to historic and archaeological resources would be SMALL. 

3 4.11.5 Cumulative Impacts on Air Quality 

4 KPS is located in Kewaunee County, Wisconsin, which belongs to EPA Region 5. Kewaunee 

5 County belongs to the Lake Michigan Intrastate Air Quality Control Region (Wisconsin) (AQCR) 

6 designated by the EPA and codified in 40 CFR 81.67 and Chapter 404.03 of the Wisconsin 

7 Administrative Code. Seventeen counties in the State of Wisconsin belong to the Lake Michigan 

8 Intrastate AQCR, three counties among them (Door County, Manitowoc County and Sheboygan 

9 County) are currently designated by the EPA as 8-hour ozone non-attainment areas. Kewaunee 

10 County is a maintenance county for 8-hour ozone and is in attainment for all other criteria 

11 pollutants (EPA, 2009). 

12 As discussed in Air Quality Impacts Section 2.2.2.1, WDNR has primary responsibility for 

13 regulating air emission sources within the State of Wisconsin and also conducting ambient air 

14 monitoring in the State. WDNR is in the process of registering the Mayville monitoring site as a 

15 National Core (NCore) multi-pollutant higher-sensitivity monitoring station, therefore fulfilling the 

16 EPA’s final amendments to the ambient air monitoring regulations for criteria pollutants 

17 contained in 40 CFR Parts 53 and 58. KPS is recognized as a Synthetic Minor facility, non-Part 

18 70 by WDNR due to the quantities of emissions and restrictions on the hours of operation of its 

19 stationary sources of criteria pollutants (DEK, 2009a). 

20 In April 2009, the EPA published the official United States inventory of greenhouse gas (GHG) 

21 emissions that identifies and quantifies the primary anthropogenic sources and sinks of GHGs 

22 (EPA 2009a). GHG inventories, such as this, are mechanisms developed by the United Nations 

23 Framework Convention on Climate Change that enable participating countries to compare their 

24 relative global contributions from different emission sources and GHGs to assess their impact 

25 on climate change. In its report, the EPA estimates that energy-related activities in the United 

26 States account for three-quarters of human-generated GHG emissions, mostly in the form of 

27 carbon dioxide emissions from burning fossil fuels. More than half of the energy-related 

28 emissions come from major stationary sources like power plants, and approximately a third 

29 come from transportation. Industrial processes (production of cement, steel, and aluminum), 

30 agriculture, forestry, other land use and waste management are also sources of GHG emissions 

31 in the United States (EPA, 2009a). 

32 Potential cumulative effects of climate change on the Great Lakes Region, whether from natural 

33 cycles or anthropogenic (man-induced) activities, could result in a variety of changes to the air 

34 quality of the area. As projected in the “Global Climate Change Impacts in the United States” 

35 report by United States Global Change Research Program (USGCRP, 2009), average annual 

36 temperatures in the Great Lakes Region and Midwest are expected to rise, causing more 

37 frequent extreme weather events. The climate of the Midwest, and Wisconsin in particular, is 

38 projected to become drier in summer, causing mild to significant reductions in Great Lakes 

39 water levels and reduced ice cover. Reduced ice cover will contribute to faster evaporation in 

40 winter, causing water deficits. The projected increase in winter and spring precipitation will 

41 cause more frequent occurrences of severe weather events. Increases in average annual 

42 temperatures, increased occurrences of intense rainfall or drought, and changes in wind 
Environmental Impacts of Operation 

Draft NUREG-1437, Supplement 40 4-48 February 2010 

1 patterns could affect concentrations and long-range transport of air pollutants. The formation of 

2 air pollutants partially depends on temperature and humidity and interactions between hourly 

3 changes in the physical and dynamic properties of the atmosphere, including circulation 

4 features, wind, topography and energy use (IPCC, 2009). 

5 In 1993, WDNR conducted the "Wisconsin Greenhouse Gas Emissions Inventory and Emission 

6 Reduction Cost Study" which led to the development of a Climate Change Action Plan in 1998. 

7 The Wisconsin GHG emissions inventory is periodically updated per this plan. In 2007, the 

8 enactment of E.O. 191 in Wisconsin led to the creation of the Governor’s Task Force on Global 

9 Warming, which outlined its mission, goals and recommendations in the 2008 final report to the 

10 governor, “Wisconsin's Strategy for Reducing Global Warming” (WDNR, 2009). WDNR is also a 

11 member of the Wisconsin Initiative on Climate Change Impacts that assesses and evaluates 

12 climate change impacts on specific Wisconsin natural resources, industry, agriculture, tourism, 

13 and other human activities. 

14 Consistent with the findings in the GEIS, the Staff concludes that the impacts from continued 

15 operation of KPS on air quality are SMALL. In addition, as no refurbishment is planned at KPS 

16 during the license renewal period, no additional air emissions would result from refurbishment 

17 activities. With respect to GHG, the EPA has not established limits on such emission sources, 

18 as further evaluation of data is still needed. Therefore, the Staff concludes that, combined with 

19 the emissions from other past, present, and reasonably foreseeable future actions, cumulative 

20 hazardous and criteria air pollutants emissions on air quality from KPS-related actions would be 

21 SMALL. 

22 4.11.6 Summary of Cumulative Impacts 

23 The NRC staff considered the potential impacts resulting from the operation of KPS during the 

24 period of extended operation and other past, present, and future actions in its vicinity. The 

25 preliminary determination is that most of the potential cumulative impacts resulting from KPS 

26 operation during the period of extended operation would be SMALL. 

27 Table 4-17. Summary of Cumulative Impacts on Resource Areas. The cumulative impacts 

28 were determined to be SMALL for most of the resource areas. 

Resource Area Impact Discussion 

Water/Aquatic Resources MODERATE See Section 4.11.1 

Terrestrial Resources SMALL See Section 4.11.2 

Human Resources SMALL See Section 4.11.3 

Socioeconomics SMALL See Section 4.11.4 

Air Quality SMALL See Section 4.11.5 
Environmental Impacts of Operation 

February 2010 4-49 Draft NUREG-1437, Supplement 40 

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Environmental Impacts of Operation 

February 2010 4-53 Draft NUREG-1437, Supplement 40 

1 U.S. Nuclear Regulatory Commission (NRC). 2008. Letter from D. Pelton, Branch Chief, 

2 Division of License Renewal, to L. Clemency, Field Supervisor, Green Bay Field Office, U.S. 

3 Fish and Wildlife Service. Subject: Request for List of State Protected Species Within the Area 

4 Under Evaluation for the Kewaunee Power Station License Renewal Application Review. 

5 September 30, 2008. ADAMS Accession No. ML082610748. 

6 U.S. Nuclear Regulatory Commission (NRC). 2008a. Letter from D. Pelton, U.S. Nuclear 

7 Regulatory Commission, Washington, D.C., to S. Banker, Wisconsin Historical Society, 

8 Madison, Wisconsin. Subject: “Kewaunee Power Station License Renewal Application Review 

9 (Case #07-0127/KE).” ADAMS Accession No. ML082670685. 

10 U.S. Nuclear Regulatory Commission (NRC). 2008b. Letter from D. Pelton, U.S. Nuclear 

11 Regulatory Commission, Washington, D.C., to D. Klima, Advisory Council on Historic 

12 Preservation, Washington, D.C. Subject: “Kewaunee Power Station License Renewal 

13 Application Review.” ADAMS Accession No. ML082610168. 

14 U.S. Census Bureau (USCB). 2003. “LandView 6 – Census 2000 Profile of General 

15 Demographic Characteristics DP-1 (100%) and Census Profile of Selected Economic 

16 Characteristics DP-3, Summary of Census Block Groups in a 50-mile radius around the KPS 

17 (44.342222 Lat., -87.536111 Long.).” 

18 U.S. Census Bureau (USCB). 2009. American FactFinder, Census 2000 information and State 

19 and County QuickFacts on Kewaunee, Manitowoc, and Brown Counties. Available online at

20 http://factfinder.census.gov and http://quickfacts.census.gov (accessed July 2009). 

21 U.S. Fish and Wildlife Service (USFWS). 2003. “12-Month Finding For a Petition to List the 

22 Kootenai River Burbot (Lota lota) as Threatened or Endangered.” Federal Register

23 68(47):11574-11579. March 11. 

24 U.S. Fish and Wildlife Service (USFWS). 2008. Letter from L. Clemency, Field Supervisor, 

25 Green Bay Field Office, U.S. Fish and Wildlife Service, to D. Pelton, Branch Chief, Division of 

26 License Renewal. Subject: Reply to Request for Species List for License Renewal Application 

27 Review of Kewaunee Power Station, Kewaunee County, Wisconsin. October 28, 2008. ADAMS 

28 Accession No. ML083390643. 

29 U.S. Fish and Wildlife Service (USFWS). 2008a. Letter to the NRC regarding the Renewal 

30 Application Review of Kewaunee Power Station, Kewaunee County, Wisconsin. October 28, 

31 2008. ADAMS Accession No. ML 083390643. 

32 United States Global Change Research Program (USGCRP). 2009. Global Climate Change 

33 Impacts in the United States. Cambridge University Press. 

34 U.S. Geological Survey (USGS). 2008. “Sea Lamprey.” Available URL:

35 http://www.glsc.usgs.gov/main.php?content=research_lamprey&title=Invasive%20Fish0&menu=

36 research_invasive_fish (accessed November 4, 2008). ADAMS Accession No. ML093250040. 

37 Wisconsin Department of Health Services, Division of Public Health (WDHS). 2008. “State of 

38 Wisconsin 2007 Point Beach – Kewaunee Environmental Radioactivity Survey.” Madison, WI. 

39 ADAMS Accession No. ML083400062. 

40 Wisconsin Department of Natural Resources (WDNR). 2005. Letter from R. Rasmussen, 

41 Wisconsin Department of Natural Resources, to P. Faggert, Dominion Energy Kewaunee, Inc., 
Environmental Impacts of Operation 

Draft NUREG-1437, Supplement 40 4-54 February 2010 

1 transmitting WPDES Permit and Permit Fact Sheet. Subject: WPDES Permit Reissuance No. 

2 WI-0001571-07-0 – Kewaunee Power Station, State Highway 42, Kewaunee, WI. July 18, 2005. 

3 Wisconsin Department of Natural Resources (WDNR). 2005a. State of Wisconsin Department 

4 of Natural Resources Permit to Discharge Under the Wisconsin Pollutant Discharge Elimination 

5 System, Permit No. WI-0001571-07-0, Kewaunee Power Station, July, 2005. ADAMS Accession 

6 No. ML083520612. 

7 Wisconsin Department of Natural Resources (WDNR). 2007. Letter from D. Hantz, Wisconsin 

8 Department of Natural Resources, to P. Faggert, Dominion Energy Kewaunee, Inc. Subject: 

9 Requirements for Cooling Water Intake Structures – WPDES Permit WI-0001571-07. December 

10 3, 2007. ADAMS Accession No. ML083520612. 

11 Wisconsin Department of Natural Resources (WDNR). 2009. “Global Climate Change. Reports 

12 and Documents.” Available URL: http://dnr.wi.gov/air/aq/global/climatechange/reports.html

13 (accessed June, 2009). ADAMS Accession No. ML093250072. 

14 Wisconsin Department of Natural Resources (WDNR). 2009a. “Lake Michigan.” Available URL: 

15 http://www.dnr.state.wi.us/org/water/greatlakes/LakeMichigan.html (accessed July 28, 2009). 

16 ADAMS Accession No. ML093250073. 

17 Wisconsin Department of Natural Resources (WDNR). 2009b. “Proposed Revisions to NR 102 

18 and NR 106 (Wisconsin Administrative Code).” Available URL:

19 http://www.dnr.state.wi.us/org/water/wm/wqs/ThermalRules2009.pdf (accessed July 8, 2009). 

20 ADAMS Accession No. ML093250074. 

21 Wisconsin Historical Society (WHS). 2007, Fax from S. Banker to P. Faggert, December 3, 

22 2007, “Request for SHPO Comment and Consultation on a Federal Undertaking.” 

23 
 

February 2010 5-1 Draft NUREG-1437, Supplement 40 

1 5.0 ENVIRONMENTAL IMPACTS OF POSTULATED ACCIDENTS

2 This chapter describes the environmental impacts from postulated accidents that might occur 

3 during the period of extended operation. The term “accident” refers to any unintentional event 

4 outside the normal plant operational envelope that results in a release or the potential for 

5 release of radioactive materials into the environment. Two classes of postulated accidents, 

6 listed in Table 5-1 below, are evaluated in the generic environmental impact statement (GEIS). 

7 These are design-basis accidents (DBAs) and severe accidents.

8 Table 5-1. Issues Related to Postulated Accidents. Two issues related to postulated 

9 accidents are evaluated under the National Environmental Policy Act (NEPA) in the license 

10 renewal review: DBAs and severe accidents. 

Issue GEIS Section Category 

DBAs 5.3.2; 5.5.1 1 

Severe accidents 5.3.3; 5.3.3.2; 5.3.3.3; 5.3.3.4; 

5.3.3.5; 5.4; 5.5.2 

2 

11 5.1 DESIGN-BASIS ACCIDENTS 

12 In order to receive U.S. Nuclear Regulatory Commission (NRC) approval to operate a nuclear 

13 power facility, an applicant for an initial operating license must submit a safety analysis report 

14 (SAR) as part of its application. The SAR presents the design criteria and design information for 

15 the proposed reactor and comprehensive data on the proposed site. The SAR also discusses 

16 various hypothetical accident situations and the safety features that are provided to prevent and 

17 mitigate accidents. The NRC staff reviews the application to determine whether or not the plant 

18 design meets NRC regulations and requirements and includes, in part, the nuclear plant design 

19 and its anticipated response to an accident.

20 DBAs are those accidents that both the licensee and the staff evaluate to ensure that the plant 

21 can withstand normal and abnormal transients, and a broad spectrum of postulated accidents, 

22 without undue hazard to the health and safety of the public. A number of these postulated 

23 accidents are not expected to occur during the life of the plant, but are evaluated to establish 

24 the design basis for the preventive and mitigative safety systems of the facility. The acceptance 

25 criteria for DBAs are described in Title 10 of the Code of Federal Regulations (10 CFR) Part 50 

26 and Part 100. 

27 The environmental impacts of DBAs are evaluated during the initial licensing process, and the 

28 ability of the plant to withstand these accidents is demonstrated to be acceptable before 

29 issuance of the operating license. The results of these evaluations are found in license 

30 documentation such as the applicant’s final safety analysis report (FSAR), the safety evaluation 

31 report (SER), the final environmental statement (FES), and Section 5.1 of this supplemental 

32 environmental impact statement (SEIS). A licensee is required to maintain the acceptable 

33 design and performance criteria throughout the life of the plant, including any period of extended 

34 operation. The consequences for these events are evaluated for the hypothetical maximum 
Environmental Impacts of Postulated Accidents 

Draft NUREG-1437, Supplement 40 5-2 February 2010 

1 exposed individual; as such, changes in the plant environment will not affect these evaluations. 

2 Because of the requirements that continuous acceptability of the consequences and aging 

3 management programs must be in effect for the period of extended operation, the 

4 environmental impacts as calculated for DBAs should not differ significantly from initial licensing 

5 assessments over the life of the plant, including the period of extended operation. Accordingly, 

6 the design of the plant relative to DBAs during the period of extended operation is considered to 

7 remain acceptable and the environmental impacts of DBAs were not examined further in the 

8 GEIS. 

9 The Commission has determined that the environmental impacts of DBAs are of SMALL 

10 significance for all plants because the plants were designed to successfully withstand these 

11 accidents. Therefore, for the purposes of license renewal, DBAs are designated as a Category 1 

12 issue. The early resolution of the DBAs makes them a part of the current licensing basis of the 

13 plant; the current licensing basis of the plant is to be maintained by the licensee under its 

14 current license and, therefore, under the provisions of 10 CFR 54.30, is not subject to review 

15 under license renewal. 

16 No new and or significant information related to DBAs was identified during the review of the 

17 Dominion Energy Kewaunee, Inc.’s (DEK) environmental report (ER) (DEK, 2008a), site audit, 

18 the scoping process, or evaluation of other available information. Therefore, there are no 

19 impacts related to these issues beyond those discussed in the GEIS. 

20 5.2 SEVERE ACCIDENT MITIGATION ALTERNATIVES 

21 Regulation under 10 CFR 51.53(c)(3)(ii)(L) requires that license renewal applicants consider 

22 alternatives to mitigate severe accidents if the staff has not previously evaluated severe 

23 accident mitigation alternatives (SAMAs) for the applicant's plant in a GEIS or related 

24 supplement or in an environmental assessment. The purpose of this consideration is to ensure 

25 that plant changes (i.e., hardware, procedures, and training) with the potential for improving 

26 severe accident safety performance are identified and evaluated. SAMAs have not been 

27 previously considered for Kewaunee Power Station (KPS); therefore, the remainder of Chapter 

28 5 addresses those alternatives. 

29 5.2.1 Introduction 

30 This section presents a summary of the SAMA evaluation for KPS conducted by DEK and the 

31 NRC staff's review of that evaluation. The NRC staff performed its review with contract 

32 assistance from Information Systems Laboratories. The NRC staff’s review is available in full in 

33 Appendix F of this document; the SAMA evaluation is available in full in DEK’s ER. 

34 The SAMA evaluation for KPS was conducted with a four-step approach. In the first step DEK 

35 quantified the level of risk associated with potential reactor accidents using the plant-specific 

36 probabilistic risk assessment (PRA) and other risk models. 

37 In the second step DEK examined the major risk contributors and identified possible ways 

38 (SAMAs) for reducing that risk. Common ways of reducing risk are changes to components, 

39 systems, procedures, and training. DEK identified 189 potential SAMAs for KPS. DEK 

40 performed an initial screening to determine if any SAMAs could be eliminated because they: (1) 
 Environmental Impacts of Postulated Accidents 

February 2010 5-3 Draft NUREG-1437, Supplement 40 

1 are not applicable at KPS due to design differences, (2) have been effectively implemented at 

2 KPS, (3) have estimated costs that would exceed the dollar value associated with completely 

3 eliminating all severe accident risk at KPS, or (4) have a very low benefit because they are 

4 associated with a non-risk-significant system. This screening reduced the list of potential 

5 SAMAs to 64. 

6 In the third step DEK estimated the benefits and the costs associated with each of the remaining 

7 SAMAs. Estimates were made of how much each SAMA could reduce risk. Those estimates 

8 were developed in terms of dollars in accordance with NRC guidance for performing regulatory 

9 analyses (NRC, 1997). The cost of implementing the proposed SAMAs was also estimated. 

10 Finally, in the fourth step, the costs and benefits of each of the remaining SAMAs were 

11 compared to determine whether or not the SAMA was cost beneficial, meaning the benefits of 

12 the SAMA were greater than the cost (a positive cost benefit). DEK concluded in its ER that 

13 several of the SAMAs evaluated are potentially cost-beneficial (DEK, 2008a). However, in 

14 response to NRC staff inquiries regarding estimated benefits for certain SAMAs and lower cost 

15 alternatives, several additional potentially cost-beneficial SAMAs were identified (DEK, 2009a). 

16 The potentially cost-beneficial SAMAs do not relate to adequately managing the effects of aging 

17 during the period of extended operation; therefore, they need not be implemented as part of 

18 license renewal pursuant to 10 CFR Part 54. DEK's SAMA analyses and the NRC's review are 

19 discussed in more detail below. 

20 5.2.2 Estimate of Risk 

21 DEK submitted an assessment of SAMAs for KPS as part of the ER (DEK, 2008a). This 

22 assessment was based on the most recent KPS PRA available at that time, a plant-specific 

23 offsite consequence analysis performed using the MELCOR Accident Consequence Code 

24 System 2 (MACCS2) computer program, and insights from the KPS individual plant examination 

25 (IPE) (WPSC, 1992) and individual plant examination of external events (IPEEE) 

26 (WPSC, 1994). 

27 For the purpose of the SAMA evaluation, the baseline core damage frequency (CDF) is 

approximately 7.7 x 10-5 28 per year. The CDF value is based on the risk assessment for internally29 initiated events. DEK did not include the contributions from external events within the KPS risk 

30 estimates; however, it did account for the potential risk reduction benefits associated with 

31 external events by increasing the estimated benefits for internal events by a factor of two. The 

32 breakdown of CDF by initiating event is provided in Table 5-2 that follows. 

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

Initiating Event CDF

(Per Year) 

% Contribution to 

CDF 

Internal floods 4.5 x 10-5 58 

Transient with main feedwater available 6.5 x 10-6 8 

Loss of component cooling water 6.0 x 10-6 8 

Steam generator tube rupture (SGTR) 4.7 x 10-6 6 

Loss of offsite power 3.9 x 10-6 5 

Stuck open pressurizer 2.0 x 10-6 3 
Environmental Impacts of Postulated Accidents 

Draft NUREG-1437, Supplement 40 5-4 February 2010 

Initiating Event CDF

(Per Year) 

% Contribution to 

CDF 

Loss of service water 1.9 x 10-6 3 

Loss of main feedwater 1.6 x 10-6 2 

Small loss-of-coolant accident (LOCA) 1.2 x 10-6 2 

Vessel failure 9.5 x 10-7 1 

Loss of instrument air 8.0 x 10-7 1 

All others 2.5 x 10-6 3 

Total CDF (internal events) 7.7 x 10-5 100 

1 As shown in this table, events initiated by internal flooding are the dominant contributors to 

2 CDF. 

3 DEK estimated the dose to the population within 50 miles (80 km) of the KPS site to be 

4 approximately 0.302 person-sievert (Sv) (30.2 person-rem) per year. The breakdown of the total 

5 population dose by containment release mode is summarized in Table 5-3. Containment bypass 

6 events (such as transients with an induced SGTR, or SGTR-initiated accidents with a stuck 

7 open safety relief valve on the ruptured steam generator) and late containment failures without 

8 containment spray dominate the population dose risk at KPS. 

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

Containment Release Mode 

Population Dose 

(Person-Rem 

Per Year) 

% Contribution 

Late containment failure without containment sprays 8.6 29 

Interfacing-systems loss-of-coolant accident (ISLOCA) with 

scrubbing 0.2 <1 

ISLOCA without scrubbing 0.9 3 

SGTR with failure of secondary side isolation 19.5 64 

SGTR with successful secondary side isolation 0.9 3 

Other 0.1 1 

Total 30.2 100 

1

One person-rem = 0.01 person-Sv 

10 The NRC staff has reviewed DEK's data and evaluation methods and concludes that the quality 

11 of the risk analyses is adequate to support an assessment of the risk reduction potential for 

12 candidate SAMAs. Accordingly, the staff based its assessment of offsite risk on the CDFs and 

13 offsite doses reported by DEK. 

14 5.2.3 Potential Plant Improvements 

15 Once the dominant contributors to plant risk were identified, DEK searched for ways to reduce 

16 that risk. In identifying and evaluating potential SAMAs, DEK considered insights from the plant17 specific PRA, and SAMA analyses performed for other operating plants that have submitted 

18 license renewal applications. DEK identified 189 potential risk-reducing improvements (SAMAs) 

19 to plant components, systems, procedures and training. A detailed cost-benefit analysis was 

20 performed for each of the SAMAs. 
 Environmental Impacts of Postulated Accidents 

February 2010 5-5 Draft NUREG-1437, Supplement 40 

1 DEK removed all but 64 of the SAMAs from further consideration because they are not 

2 applicable at KPS due to design differences, have already been effectively implemented at KPS, 

3 have estimated costs that would exceed the dollar value associated with completely eliminating 

4 all severe accident risk at KPS, or have a very low benefit because they are associated with a 

5 non-risk-significant system. A detailed cost-benefit analysis was performed for each of the 

6 remaining SAMAs. 

7 The staff concludes that DEK used a systematic and comprehensive process for identifying 

8 potential plant improvements for KPS, and that the set of potential plant improvements identified 

9 by DEK is reasonably comprehensive and, therefore, acceptable. 

10 5.2.4 Evaluation of Risk Reduction and Costs of Improvements 

11 DEK evaluated the risk reduction potential of the remaining 64 SAMAs. The SAMA evaluations 

12 were performed using generally conservative assumptions. 

13 DEK estimated the costs of implementing the candidate SAMAs through the application of 

14 engineering judgment, the use of other licensee’s estimates for similar improvements, and the 

15 use of KPS actual experience for similar improvements. The cost estimates conservatively did 

16 not include the cost of replacement power during extended outages required to implement the 

17 modifications, nor did they include contingency costs associated with unforeseen 

18 implementation obstacles. 

19 The staff reviewed DEK’s bases for calculating the risk reduction for the various plant 

20 improvements and concludes that the rationale and assumptions for estimating risk reduction 

21 are reasonable and generally conservative (i.e., the estimated risk reduction is higher than what 

22 would actually be realized). Accordingly, the staff based its estimates of averted risk for the 

23 various SAMAs on DEK’s risk reduction estimates. 

24 The staff reviewed the bases for the applicant’s cost estimates. For certain improvements, the 

25 staff also compared the cost estimates to estimates developed elsewhere for similar 

26 improvements, including estimates developed as part of other licensee’s analyses of SAMAs for 

27 operating reactors and advanced light-water reactors. The staff found the cost estimates to be 

28 reasonable and generally consistent with estimates provided in support of other plants analyses. 

29 The staff concludes that the risk reduction and the cost estimates provided by DEK are sufficient 

30 and appropriate for use in the SAMA evaluation. 

31 5.2.5 Cost Benefit Comparison 

32 The cost benefit analysis performed by DEK was based primarily on NUREG/BR-0184 (NRC, 

33 1997) and was executed consistent with this guidance. NUREG/BR-0058 has recently been 

34 revised to reflect the agency’s revised policy on discount rates. Revision 4 of NUREG/BR-0058 

35 states that two sets of estimates should be developed─one at three percent and one at seven 

36 percent (NRC, 2004). DEK provided both sets of estimates (DEK, 2008a). 

37 DEK identified 14 potentially cost-beneficial SAMAs in the ER’s baseline analysis: 
Environmental Impacts of Postulated Accidents 

Draft NUREG-1437, Supplement 40 5-6 February 2010 

1 ● SAMA 66 - Install a new feedwater source. (The evaluated SAMA actually involved 

2 proceduralizing use of existing water sources) 

3 ● SAMA 80 - Add redundant ventilation systems. (The evaluated SAMA actually involved 

4 staging temporary equipment and providing procedures and power source 

5 connections) 

6 ● SAMA 82, 83, 170, 171 – Add switchgear room ventilation response. (The evaluated 

7 SAMA actually involved staging backup fans in switchgear rooms, adding switchgear 

8 room high temperature alarm, staging temporary fans and ducts along with power 

9 cords for safeguards alley room cooling, and providing high temperature alarms for the 

10 safeguards alley) 

11 ● SAMA 169 - Provide flood protection for MCC-52E, -62E, and -62H. 

12 ● SAMA 172 - Provide additional alarm for extremely low condensate storage tank level. 

13 ● SAMA 173 - Protect auxiliary building mezzanine cooling units from spray. 

14 ● SAMA 174 - Protect boric acid transfer pumps from spray. 

15 ● SAMA 175 - Protect a-train closed cooling water pump from spray. 

16 ● SAMA 176 - Install larger sump pumps in safeguards alley. 

17 ● SAMA 177 - Install watertight barrier between 480 VAC switchgear rooms. 

18 ● SAMA 181 - Install break-away mechanisms on emergency diesel generator (EDG) 

19 room doors. 

20 DEK performed additional analyses to evaluate the impact of parameter choices and 

21 uncertainties on the results of the SAMA assessment (DEK, 2008a). Based on this, DEK 

22 concluded that no additional SAMAs would be cost beneficial even at the 95 percentile risk 

23 values. 

24 DEK also considered the impact of simultaneous implementation of several of the SAMAs from 

25 both a benefit and a cost standpoint. DEK concluded that while the simultaneous 

26 implementation of several SAMAs would not increase the total benefit beyond that for each 

27 SAMA individually, the implementation cost could be reduced. Based on the evaluation of 

28 similar SAMAs involving improvements in room cooling and ventilation, DEK concluded that the 

29 following three additional SAMAs involving diesel room cooling improvements would be cost 

30 beneficial: 

31 ● SAMA 81 - Add a diesel building high temperature alarm or redundant louver and 

32 thermostat 

33 ● SAMA 166 - Open doors for alternate (diesel generator (DG) room cooling) 

34 ● SAMA 167 - Proceduralize actions to open EDG room doors on loss of heating, 

35 ventilation, and air conditioning (HVAC) and implement portable fans 

36 Finally, DEK reviewed the analysis of the K107Aa PRA, prepared subsequent to the SAMA 

37 evaluation documented in the ER, and found one new contributor to risk that could be impacted 

38 by a candidate SAMA. DEK concluded that a new SAMA addressing this contributor, loss of 
 Environmental Impacts of Postulated Accidents 

February 2010 5-7 Draft NUREG-1437, Supplement 40 

1 screenhouse ventilation, could be cost-effectively combined with similar SAMAs 81, 82, 83, 160, 

2 166, 167, 170, and 171. 

3 ● Implementation of temporary screenhouse ventilation, including installing additional 

4 temperature detectors 

5 DEK committed to further review these SAMAs for implementation as part of DEK’s ongoing 

6 performance improvement program (DEK 2008a; 2009a). 

7 The staff concludes that, with the exception of the potentially cost-beneficial SAMAs discussed 

8 above, the costs of the SAMAs evaluated would be higher than the associated benefits. 

9 5.2.6 Conclusions 

10 The staff reviewed DEK’s analysis and concluded that the methods used and the 

11 implementation of those methods are sound. The treatment of SAMA benefits and costs support 

12 the general conclusion that the SAMA evaluations performed by DEK are reasonable and 

13 sufficient for the license renewal submittal. 

14 Based on its review of the SAMA analysis, the staff concurs with DEK’s identification of areas in 

15 which risk can be further reduced in a cost-beneficial manner through the implementation of all 

16 or a subset of potentially cost-beneficial SAMAs. Given the potential for cost-beneficial risk 

17 reduction, the staff considers that further evaluation of these SAMAs by DEK is warranted. 

18 However, none of the potentially cost-beneficial SAMAs relate to adequately managing the 

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

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

21 5.3 REFERENCES 

22 10 CFR 50. Code of Federal Regulations, Title 10, Energy, Part 50, “Domestic Licensing of 

23 Production and Utilization Facilities.” 

24 10 CFR 51. Code of Federal Regulations, Title 10, Energy, Part 51, “Environmental Protection 

25 Regulations for Domestic Licensing and Related Regulatory Functions.” 

26 10 CFR 54. Code of Federal Regulations, Title 10, Energy, Part 54, “Requirements for Renewal 

27 of Operating Licenses for Nuclear Power Plants.” 

28 10 CFR 100. Code of Federal Regulations, Title 10, Energy, Part 100, “Reactor Site Criteria.” 

29 Dominion Energy Kewaunee, Inc. (DEK). 2008a. Kewaunee Power Station, Licensee=s 

30 Environmental ReportBOperating License Renewal Stage, August, 2008. Agencywide 

31 Documents Access and Management System (ADAMS) Accession No. ML082341039. 

32 Dominion Energy Kewaunee, Inc. (DEK). 2009a. Letter from Leslie N. Hartz, Dominion, to U.S. 

33 Nuclear Regulatory Commission Document Control Desk. Subject: Kewaunee Power Station, 

34 Response to Request Additional Information Regarding Severe Accident Mitigation Alternative 

35 for Kewaunee Power Station License Renewal Application, March 9, 2009. ADAMS Accession 

36 No. ML090690458. 
Environmental Impacts of Postulated Accidents 

Draft NUREG-1437, Supplement 40 5-8 February 2010 

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

2 for License Renewal of Nuclear Plants. NUREG-1437, Washington, D.C. Accessible at 

3 http://www.nrc.gov/reading-rm/doc-collections/nuregs/staff/sr1437/

4 U.S. Nuclear Regulatory Commission (NRC). 1997. Regulatory Analysis Technical Evaluation 

5 Handbook. NUREG/BR-0184, Washington, D.C., January 1997. 

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. NUREG9 1437, Vol. 1, Addendum 1, Washington, D.C. Accessible at: http://www.nrc.gov/reading-rm/doc10 collections/nuregs/staff/sr1437/

11 U.S. Nuclear Regulatory Commission (NRC). 2004. Regulatory Analysis Guidelines of the U.S. 

12 Nuclear Regulatory Commission. NUREG/BR-0058, Revision 4, Washington, D.C., September 

13 2004. 

14 Wisconsin Public Service Corporation (WPSC). 1992. Letter from C. R. Steinhardt, WPSC to 

15 U.S. Nuclear Regulatory Commission Document Control Desk. Subject: Docket No. 50-305, 

16 Operating License No. DPR-43, Kewaunee Nuclear Power Plant, Response to Generic Letter 

17 88-20, Individual Plant Examination, December 1, 1992. ADAMS Accession No. ML080170462. 

18 Wisconsin Public Service Corporation (WPSC). 1994. Letter from C. R. Steinhardt, WPSC to 

19 U.S. Nuclear Regulatory Commission Document Control Desk. Subject: Docket No. 50-305, 

20 Operating License No. DPR-43, Kewaunee Nuclear Power Plant, Response to Generic Letter 

21 88-20, Supplement 4. Individual Plant Examination of External Events, June 28, 1994. ADAMS 

22 Accession No. ML080170459.
February 2010 6-1 Draft NUREG-1437, Supplement 40 

1 6.0 ENVIRONMENTAL IMPACTS OF THE URANIUM FUEL CYCLE, 

2 SOLID WASTE MANAGEMENT, AND GREENHOUSE GAS 

3 6.1 THE URANIUM FUEL CYCLE 

4 This section addresses issues related to the uranium fuel cycle and solid waste management 

5 during the period of extended operation. The uranium cycle includes uranium mining and 

6 milling, the production of uranium hexafluoride, isotopic enrichment, fuel fabrication, 

7 reprocessing of irradiated fuel, transportation of radioactive materials, and management of low8 level wastes and high-level wastes related to uranium fuel cycle activities. The generic 

9 environmental impact statement (GEIS) (NRC 1996, 1999) details the potential generic impacts 

10 of the radiological and nonradiological environmental impacts of the uranium fuel cycle and 

11 transportation of nuclear fuel and wastes, as listed in Table 6-1 below. The GEIS is based, in 

12 part, on the generic impacts provided in Table S-3, “Table of Uranium Fuel Cycle Environmental 

13 Data,” in Title 10 of the Code of Federal Regulations (CFR), Section 51.51(b), and in Table S-4, 

14 “Environmental Impact of Transportation of Fuel and Waste to and from One Light-Water15 Cooled Nuclear Power Reactor,” in 10 CFR 51.52(c). The GEIS also addresses the impacts 

16 from radon-222 and technetium-99. 

17 The staff of the U.S. Nuclear Regulatory Commission (NRC) did not identify any new and 

18 significant information related to the uranium fuel cycle during the review of the Dominion 

19 Energy Kewaunee, Inc. (DEK) environmental report (ER) (DEK, 2008a), the site audit, and the 

20 scoping process. Therefore, there are no impacts related to these issues beyond those 

21 discussed in the GEIS. For these Category 1 issues, the GEIS concludes that the impacts are 

22 designated as SMALL, except for the collective offsite radiological impacts from the fuel cycle 

23 and from high-level waste and spent fuel disposal. 

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

25 generic issues are related to the fuel cycle and solid waste management. There are no site26 specific issues.

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 
Environmental Impacts of the Uranium Fuel Cycle 

Draft NUREG-1437, Supplement 40 6-2 February 2010 

Issues GEIS Section Category 

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 

1 

2 6.2 GREENHOUSE GAS EMISSIONS 

3 This section provides a discussion of potential impacts from greenhouse gases (GHGs) emitted 

4 during 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 

10 the carbon footprint of the nuclear power lifecycle vary depending on the type of study 

11 conducted. Additionally, considerable debate also exists among researchers regarding the 

12 relative impacts of nuclear and other forms of electricity generation on GHG emissions. Existing 

13 studies on GHG emissions from nuclear power plants generally take two different forms: 

14 (1) Qualitative discussions of the potential to use nuclear power to reduce GHG emissions 

15 and mitigate global warming; and 
Environmental Impacts of the Uranium Fuel Cycle 

February 2010 6-3 Draft NUREG-1437, Supplement 40 

1 (2) Technical analyses and quantitative estimates of the actual amount of GHGs generated 

2 by the nuclear fuel cycle or entire nuclear power plant life cycle and comparisons to the 

3 operational or life cycle emissions from other energy generation alternatives. 

4 6.2.1.1 Qualitative Studies 

5 The qualitative studies consist primarily of broad, large-scale public policy or investment 

6 evaluations of whether an expansion of nuclear power is likely to be a technically, economically, 

7 and/or politically feasible means of achieving global GHG reductions. Examples of the studies 

8 identified by the NRC staff during the subsequent literature search include: 

9 ● Evaluations to determine whether investments in nuclear power in developing 

10 countries should be accepted as a flexibility mechanism to assist industrialized 

11 nations in achieving their GHG reduction goals under the Kyoto Protocols 

12 (Schneider, 2000; IAEA, 2000; NEA, 2002; NIRS/WISE, 2005). Ultimately, the 

13 parties to the Kyoto Protocol did not approve nuclear power as a component under 

14 the Clean Development Mechanism (CDM) due to safety and waste disposal 

15 concerns (NEA, 2002). 

16 ● Analyses developed to assist governments, including the United States, in making 

17 long-term investment and public policy decisions in nuclear power (Keepin, 1988; 

18 Hagen et al., 2001; MIT, 2003). 

19 Although the qualitative studies sometimes reference and critique the existing quantitative 

20 estimates of GHGs produced by the nuclear fuel cycle or life cycle, their conclusions generally 

21 rely heavily on discussions of other aspects of nuclear policy decisions and investment such as 

22 safety, cost, waste generation, and political acceptability. Therefore, these studies are typically 

23 not directly applicable to an evaluation of GHG emissions associated with the proposed license 

24 renewal for a given nuclear power plant. 

25 6.2.1.2 Quantitative Studies 

26 A large number of technical studies, including calculations and estimates of the amount of 

27 GHGs emitted by nuclear and other power generation options, are available in the literature and 

28 were useful to the NRC staff’s efforts in addressing relative GHG emission levels. Examples of 

29 these studies include – but are not limited to – Mortimer (1990), Andseta et al. (1998), Spadaro 

30 (2000), Storm van Leeuwen and Smith (2005), Fritsche (2006), Parliamentary Office of Science 

31 and Technology (POST) (2006), Atomic Energy Authority (AEA) (2006), Weisser (2006), 

32 Fthenakis and Kim (2007), and Dones (2007). 

33 Comparing these studies and others like them is difficult because the assumptions and 

34 components of the lifecycles the authors evaluate vary widely. Examples of areas in which 

35 differing assumptions make comparing the studies difficult include: 

36 • Energy sources that may be used to mine uranium deposits in the future; 

37 • Reprocessing or disposal of spent nuclear fuel; 
Environmental Impacts of the Uranium Fuel Cycle 

Draft NUREG-1437, Supplement 40 6-4 February 2010 

1 • Current and potential future processes to enrich uranium and the energy sources 

2 that will power them; 

3 • Estimated grades and quantities of recoverable uranium resources; 

4 • Estimated grades and quantities of recoverable fossil fuel resources; 

5 • Estimated GHG emissions other than CO2, including the conversion to CO2

6 equivalents per unit of electric energy produced; 

7 • Performance of future fossil fuel power systems; 

8 • Projected capacity factors for alternatives means of generation; and 

9 • Current and potential future reactor technologies. 

10 In addition, studies may vary with respect to whether all or parts of a power plant’s lifecycle are 

11 analyzed, i.e., a full lifecycle analysis will typically address plant construction, operations, 

12 resource extraction (for fuel and construction materials), and decommissioning, whereas a 

13 partial lifecycle analysis primarily focuses on operational differences. 

14 In the case of license renewal, a GHG analysis for that portion of the plant’s lifecycle (operation 

15 for an additional 20 years) would not involve GHG emissions associated with construction 

16 because construction activities have already been completed at the time of relicensing. In 

17 addition, the proposed action of license renewal would also not involve additional GHG 

18 emissions associated with facility decommissioning, because that decommissioning must occur 

19 whether the facility is relicensed or not. However, in some of the aforementioned studies, the 

20 specific contribution of GHG emissions from construction, decommissioning, or other portions of 

21 a plant’s lifecycle cannot be clearly separated from one another. In such cases, an analysis of 

22 GHG emissions would overestimate the GHG emissions attributed to a specific portion of a 

23 plant’s lifecycle. Nonetheless, these studies provide some meaningful information with respect 

24 to the relative magnitude of the emissions among nuclear power plants and other forms of 

25 electric generation, as discussed in the following sections. 

26 In Tables 6-2, 6-3, and 6-4 the NRC staff presents the results of the aforementioned quantitative 

27 studies to provide a weight-of-evidence evaluation of the relative GHG emissions that may 

28 result from the proposed license renewal as compared to the potential alternative use of coal29 fired, natural gas-fired, and renewable generation. Most studies from Mortimer (1990) onward 

30 suggest that uranium ore grades and uranium enrichment processes are leading determinants 

31 in the ultimate GHG emissions attributable to nuclear power generation. These studies indicate 

32 that the relatively lower order of magnitude of GHG emissions from nuclear power when 

33 compared to fossil-fueled alternatives (especially natural gas) could potentially disappear if 

34 available uranium ore grades drop sufficiently while enrichment processes continued to rely on 

35 the same technologies. 
Environmental Impacts of the Uranium Fuel Cycle 

February 2010 6-5 Draft NUREG-1437, Supplement 40 

1 Summary of Nuclear Greenhouse Gas Emissions Compared to Coal 

2 Considering that coal fuels the largest share of electricity generation in the United States and 

3 that its burning results in the largest emissions of GHGs for any of the likely alternatives to 

4 nuclear power generation, including Kewaunee Power Station (KPS), most of the available 

5 quantitative studies focused on comparisons of the relative GHG emissions of nuclear to coal6 fired generation. The quantitative estimates of the GHG emissions associated with the nuclear 

7 fuel cycle (and, in some cases, the nuclear lifecycle), as compared to an equivalent coal-fired 

8 plant, are presented in Table 6-2. The following chart does not include all existing studies, but 

9 provides an illustrative range of estimates developed by various researchers. 

10 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. 

11 Summary of Nuclear Greenhouse Gas Emissions Compared to Natural Gas 

12 The quantitative estimates of the GHG emissions associated with the nuclear fuel cycle (and, in 

13 some cases, the nuclear lifecycle), as compared to an equivalent natural gas-fired plant, are 
Environmental Impacts of the Uranium Fuel Cycle 

Draft NUREG-1437, Supplement 40 6-6 February 2010 

1 presented in Table 6-3. The following chart does not include all existing studies, but provides an 

2 illustrative range of estimates developed by various researchers. 

3 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. 

4 

5 Summary of Nuclear Greenhouse Gas Emissions Compared to Renewable Energy Sources 

6 The quantitative estimates of the GHG emissions associated with the nuclear fuel cycle, as 

7 compared to equivalent renewable energy sources, are presented in Table 6-4. Calculation of 

8 GHG emissions associated with these sources is more difficult than the calculations for nuclear 

9 energy and fossil fuels because of the large variation in efficiencies due to their different 

10 sources and locations. For example, the efficiency of solar and wind energy is highly dependent 

11 on the location in which the power generation facility is installed. Similarly, the range of GHG 

12 emissions estimates for hydropower varies greatly depending on the type of dam or reservoir 

13 involved (if used at all). Therefore, the GHG emissions estimates for these energy sources have 

14 a greater range of variability than the estimates for nuclear and fossil fuel sources. The following 

15 chart does not include all existing studies, but provides an illustrative range of estimates 

16 developed by various researchers. 
Environmental Impacts of the Uranium Fuel Cycle 

February 2010 6-7 Draft NUREG-1437, Supplement 40 

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. 
Environmental Impacts of the Uranium Fuel Cycle 

Draft NUREG-1437, Supplement 40 6-8 February 2010 

1 

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. 

9 First, the various studies indicate a general consensus that nuclear power currently produces 

10 fewer GHG emissions than fossil-fuel-based electrical generation, e.g., the GHG emissions from 

11 a complete nuclear fuel cycle currently range from 2.5 to 55 g Ceq/kWh, as compared to the use 

12 of coal plants (264 to 1250 g Ceq/kWh) and natural gas plants (120 to 780 g Ceq/kWh). The 

13 studies also provide estimates of GHG emissions from five renewable energy sources based on 

14 current technology. These estimates included solar-photovoltaic (17 to 125 g Ceq/kWh), 

15 hydroelectric (1 to 64.6 g Ceq/kWh), biomass (8.4 to 99 g Ceq/kWh), wind (2.5 to 30 g Ceq/kWh), 

16 and tidal (25 to 50 g Ceq/kWh). The range of these estimates is wide, but the general conclusion 

17 is that current GHG emissions from the nuclear fuel cycle are of the same order of magnitude as 

18 from these renewable energy sources. 

19 Second, the studies indicate no consensus on future relative GHG emissions from nuclear 

20 power and other sources of electricity. There is substantial disagreement among the various 

21 authors regarding the GHG emissions associated with declining uranium ore concentrations, 

22 future uranium enrichment methods, and other factors, including changes in technology. Similar 

23 disagreement exists regarding future GHG emissions associated with coal and natural gas for 

24 electricity generation. Even the most conservative studies conclude that the nuclear fuel cycle 

25 currently produces fewer GHG emissions than fossil-fuel-based sources, and is expected to 

26 continue to do so in the near future. The primary difference between the authors is the projected 

27 cross-over date (the time at which GHG emissions from the nuclear fuel cycle exceed those of 

28 fossil-fuel-based sources) or whether cross-over will occur at all. 

29 Considering the current estimates and future uncertainties, it appears that GHG emissions 

30 associated with the proposed KPS relicensing action are likely to be lower than those 

31 associated with fossil-fuel-based energy sources. The NRC staff based this conclusion on the 

32 following rationale: 

33 1. As shown in Tables 6-2 and 6-3, the current estimates of GHG emissions from the 

34 nuclear fuel cycle are far below those for fossil-fuel-based energy sources; 

35 2. KPS license renewal will involve continued GHG emissions due to uranium mining, 

36 processing, and enrichment, but will not result in increased GHG emissions associated 

37 with plant construction or decommissioning (as the plant will have to be decommissioned 

38 at some point whether the license is renewed or not); and 

39 3. Few studies predict that nuclear fuel cycle emissions will exceed those of fossil fuels 

40 within a timeframe that includes the KPS periods of extended operation. Several studies 
Environmental Impacts of the Uranium Fuel Cycle 

February 2010 6-9 Draft NUREG-1437, Supplement 40 

1 suggest that future extraction and enrichment methods, the potential for higher grade 

2 resource discovery, and technology improvements could extend this timeframe. 

3 In comparing GHG emissions among the proposed KPS license renewal action and renewable 

4 energy sources, it appears likely that there will be future technology improvements and changes 

5 in mining, processing, and constructing facilities of all types. Currently, the GHG emissions 

6 associated with the nuclear fuel cycle and renewable energy sources are within the same order 

7 of magnitude. Because nuclear fuel production is the most significant contributor to possible 

8 future increases in GHG emissions from nuclear power, and because most renewable energy 

9 sources lack a fuel component, it is likely that GHG emissions from renewable energy sources 

10 would be lower than those associated with KPS at some point during the period of extended 

11 operation. 

12 The NRC staff provides an additional discussion about the contribution of GHGs to cumulative 

13 air quality impacts in Chapter 4.11.5 of this SEIS. 

14 

15 6.3 REFERENCES 

16 10 CFR Part 51. Code of Federal Regulations, Title 10, Energy, Part 51, “Environmental 

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

18 10 CFR Part 54. Code of Federal Regulations, Title 10, Energy, Part 54, “Requirements for 

19 Renewal of Operating Licenses for Nuclear Power Plants.” 

20 10 CFR Part 63. Code of Federal Regulations, Title 10, Energy, Part 63, “Disposal of High-Level 

21 Radioactive Wastes in a Geologic Repository at Yucca Mountain, Nevada.” 

22 40 CFR Part 191. Code of Federal Regulations, Title 40, Protection of Environment, Part 191, 

23 “Environmental Radiation Protection Standards for Management and Disposal of Spent Nuclear 

24 Fuel, High-Level and Transuranic Radioactive Waste.” 

25 AEA Technology (AEA). 2006. “Carbon Footprint of the Nuclear Fuel Cycle, Briefing Note.” 

26 Prepared for British Energy. March 2006. 

27 Andseta, S., M.J. Thompson, J.P. Jarrell, and D.R. Pendergast. 1998. “CANDU Reactors and 

28 Greenhouse Gas Emissions.” Canadian Nuclear Association, 11th Pacific Basin Nuclear 

29 Conference, Banff, Alberta, Canada. May 1998. 

30 Dominium Energy Kewaunee (DEK). 2008. Kewaunee Power Station, Applicant’s 

31 Environmental Report, Operating License Renewal Stage, Glen Allen, Virginia. ADAMS 

32 Accession Nos. ML082341020, ML082341038, and ML082341039. 

33 Dones, R. 2007. “Critical Note on the Estimation by Storm Van Leeuwen J.W., and Smith P. of 

34 the Energy Uses and Corresponding CO2 Emissions for the Complete Nuclear Energy Chain.” 

35 Paul Sherer Institute. April 2007. 

36 Fritsche, U.R. 2006. “Comparison of Greenhouse-Gas Emissions and Abatement Cost of 

37 Nuclear and Alternative Energy Options from a Life-Cycle Perspective.” Oko-Institut, Darmstadt 

38 Office. January 2006. 
Environmental Impacts of the Uranium Fuel Cycle 

Draft NUREG-1437, Supplement 40 6-10 February 2010 

1 Fthenakis, V.M. and H.C. Kim. 2007. Greenhouse-gas emissions from solar-electric and nuclear 

2 power: A life cycle study. Energy Policy, Volume 35, Number 4. 

3 International Atomic Energy Agency (IAEA). 2000. “Nuclear Power for Greenhouse Gas 

4 Mitigation under the Kyoto Protocol: The Clean Development Mechanism (CDM).” November 

5 2000. 

6 Mortimer, N. 1990. “World Warms to Nuclear Power.” SCRAM Safe Energy Journal. December 

7 1989 and January 1990. Available URL: 

8 http://www.no2nuclearpower.org.uk/articles/mortimer_se74.php (accessed February 29, 2007). 

9 Organization for Economic Co-Operation and Development, Nuclear Energy Agency (NEA). 

10 2002. Nuclear Energy and the Kyoto Protocol. 

11 Parliamentary Office of Science and Technology (POST). 2006. “Carbon Footprint of Electricity 

12 Generation.” Postnote, Number 268. October 2006. 

13 Schneider, M. 2000. Climate Change and Nuclear Power. World Wildlife Fund for Nature. April 

14 2000. 

15 Spadaro, J.V., L. Langlois and B. Hamilton. 2000. “Greenhouse Gas Emissions of Electricity 

16 Generation Chains: Assessing the Difference.” IAEA Bulletin 42/2/2000, Vienna, Austria. 

17 Storm van Leeuwen, J.W. and P. Smith 2005. Nuclear Power—The Energy Balance. August 

18 2005. 

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

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

21 1996. ADAMS Accession Nos. ML040690705 and ML040690738. 

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

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

24 Summary of Findings on NEPA Issues for License Renewal of Nuclear Power Plants, Final 

25 Report.” NUREG-1437, Volume 1, Addendum 1, Washington, D.C. 

26 Weisser, D. 2006. “A Guide to Life-Cycle Greenhouse Gas (GHG) Emissions from Electric 

27 Supply Technologies.” Available URL: 

28 http://www.iaea.org/OurWork/ST/NE/Pess/assets/GHG_manuscript_pre29 print_versionDanielWeisser.pdf (accessed May 19, 2009). 
February 2010 7-1 Draft NUREG-1437, Supplement 40 

1 7.0 ENVIRONMENTAL IMPACTS OF DECOMMISSIONING 

2 Decommissioning is defined as the safe removal of a nuclear facility from service and the 

3 reduction of residual radioactivity to a level that permits release of the property for unrestricted 

4 use and termination of the license. The U.S. Nuclear Regulatory Commission (NRC) issued a 

5 generic environmental impact statement (GEIS) for decommissioning (NRC, 2002) that 

6 evaluated environmental impacts from the activities associated with the decommissioning of any 

7 reactor before or at the end of an initial or renewed license. 

8 The NRC staff did not identify any new and significant information during the review of the 

9 Dominion Energy Kewaunee, Inc. (DEK) environmental report (DEK, 2008a), the site audit, or 

10 the scoping process. Therefore, there are no impacts related to these issues beyond those 

11 discussed in the GEIS (NRC 1996, 1999). For all of these issues, the GEIS concluded that the 

12 impacts are SMALL. 

13 Table 7-1. Issues Related to Decommissioning. Decommissioning would occur regardless if 

14 Kewaunee Power Station (KPS) is shut down at the end of its current operating license or at the 

15 end of the period of extended operation. There are no site-specific issues related to 

16 decommissioning. 

Issues GEIS Sections Category 

Radiation doses 7.3.1; 7.4 1 

Waste management 7.3.2; 7.4 1 

Air quality 7.3.3; 7.4 1 

Water quality 7.3.4; 7.4 1 

Ecological resources 7.3.5; 7.4 1 

Socioeconomic impacts 7.3.7; 7.4 1 

17 7.1 REFERENCES 

18 Dominium Energy Kewaunee, Inc. (DEK). 2008a. Kewaunee Power Station, Applicant’s 

19 Environmental Report, Operating License Renewal Stage, Glen Allen, Virginia. ADAMS 

20 Accession Nos. ML082341020, ML082341038, and ML082341039. 

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

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

23 ADAMS Accession Nos. ML040690705 and ML040690738. 

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

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

26 Summary of Findings on NEPA Issues for License Renewal of Nuclear Power Plants, Final 

27 Report.” NUREG-1437, Volume 1, Addendum 1, Washington, D.C. ADAMS Accession No. 

28 ML040690720. 
Environmental Impacts of Decommissioning 

Draft NUREG-1437, Supplement 40 7-2 February 2010 

1 

2 U.S. Nuclear Regulatory Commission (NRC). 2002. Generic Environmental Impact Statement 

3 for Decommissioning of Nuclear Facilities: Supplement 1, Regarding the Decommissioning of 

4 Nuclear Power Reactors. NUREG-0586, Supplement 1, Washington, D.C. ADAMS Accession 

5 Nos. ML023500228 and ML023500412. 
February 2010 8-1 Draft NUREG-1437, Supplement 40 

1 8.0 ENVIRONMENTAL IMPACTS OF ALTERNATIVES 

2 The National Environmental Policy Act of 1969 (NEPA) mandates that each environmental 

3 impact statement (EIS) consider alternatives to any proposed major Federal action. U.S. 

4 Nuclear Regulatory Commission (NRC) regulations implementing NEPA for license renewal 

5 require that a supplemental environmental impact statement (SEIS) considers and weighs the 

6 environmental effects of the proposed action [license renewal]; the environmental impacts of 

7 alternatives to the proposed action; and alternatives available for reducing or avoiding adverse 

8 environmental impacts, per 10 CFR 51.71(d). In this case, the proposed Federal action is 

9 issuing a renewed license for the Kewaunee Power Station (KPS), which will allow the plant to 

10 operate for 20 years beyond its current license expiration date.

11 In this chapter, the staff examines the potential environmental impacts of alternatives to issuing 

12 a renewed operating license for KPS. 

13 While the Generic Environmental Impact Statement (GEIS) for License Renewal of Nuclear 

14 Plants, NUREG-1437 (NRC 1996, 1999), reached generic conclusions regarding many 

15 environmental issues associated with license renewal, it did not determine which alternatives 

16 are reasonable or reach conclusions about site-specific environmental impact levels. Therefore, 

17 the staff must evaluate environmental impacts of alternatives on a site-specific basis. 

18 In accordance with the GEIS, alternatives to the proposed action of issuing renewed KPS 

19 operating license must meet the purpose and need for issuing a renewed license; they must 

20 provide an option that allows for power generation capability beyond the term of a current 

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

22 may be determined by State, utility, and, where authorized, Federal (other than NRC) 

23 decisionmakers (10 CFR 51.71(f)). 

24 The staff ultimately makes no decision regarding whether an alternative or the proposed action 

25 is implemented, since that decision falls to utility, State, or other Federal officials. Comparing the 

26 environmental effects of these alternatives will assist the staff in deciding whether the 

27 environmental impacts of license renewal are so great that preserving the option of license 

28 renewal for energy-planning decision makers would be unreasonable (10 CFR 51.95(c)(4)). If 

29 the NRC acts to issue a renewed license, all of the alternatives, including the proposed action, 

30 will be available to energy-planning decision makers. If the NRC decides not to renew the 

31 license (or takes no action at all), then energy-planning decision makers may no longer elect to 

32 continue operating KPS and will have to resort to another alternative, which may or may not be 

33 one of the alternatives the staff considers in this section, in order to meet their energy needs. 

34 In addition to evaluating alternatives to the proposed action, when appropriate the staff also 

35 examines alternatives that may reduce or avoid environmental impacts of the proposed action; 

36 the staff does so to illustrate how such alternatives may act to mitigate potential impacts of 

37 license renewal. 

38 In evaluating alternatives to license renewal, the 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 KPS
Environmental Impacts of Alternatives 

Draft NUREG-1437, Supplement 40 8-2 February 2010 

In-Depth 

Alternatives: 

• Natural gas-fired 

combined-cycle 

• Coal-fired alternative 

• Combination 

including gas-fired, 

conservation, and 

wind (Combination 

Option 1) or woodfired (Combination 

Option 2) 

Other Alternatives 

Considered: 

• Wind power 

• Wood-fired 

• Conservation 

• Solar power 

• Conventional 

hydroelectric power 

• Geothermal power 

• Biofuels 

• New nuclear 

• Oil-fired power 

• Fuel cells 

• Municipal solid waste 

• Delayed retirement 

2 operating license expires. Given that only four years 

4 remain before the KPS license expires, the options staff 

6 considers in this section are generally commercially 

8 available today. 

10 Second, the staff screens the alternatives to remove those 

12 that cannot meet future system needs. Then, the staff 

14 screens the remaining options to remove those for which 

16 the cost or benefits do not justify inclusion in the range of 

18 reasonable alternatives. Any alternatives remaining 

20 constitute alternatives to the proposed action that the staff 

22 evaluates in-depth throughout this section. In Section 8.5, 

24 the staff briefly addresses each alternative that was 

26 removed during screening. 

28 The staff initially considered 14 discrete potential 

30 alternatives to the proposed action and narrowed the list to 

32 the two single-source alternatives and two combination 

34 alternatives considered in this chapter. 

36 Once the staff identified the in-depth alternatives, it 

38 referred to generic environmental impact evaluations in the 

40 GEIS. The GEIS provides overviews of some energy 

42 technologies available at the time of its publishing in 1996, 

44 though it does not reach any conclusions regarding which 

46 alternatives are most appropriate, nor does it precisely 

48 categorize impacts for each site. Since 1996, many energy 

50 technologies have evolved significantly in capability and 

52 cost-effectiveness, while regulatory structures have 

54 changed to either promote or impede development of 

56 particular alternatives. 

58 Where applicable, the staff uses information in the GEIS 

59 and includes updated information from the Energy Information Administration (EIA), other 

60 organizations within the Department of Energy (DOE), the Environmental Protection Agency 

61 (EPA), industry sources and publications, and information submitted by Dominion Energy 

62 Kewaunee, Inc. (DEK) in the KPS environmental report (ER). 

63 For each in-depth analysis, the staff analyzes environmental impacts across seven impact 

64 categories: air quality, groundwater use and quality, surface water use and quality, ecology, 

65 human health, socioeconomics, and waste management. As in earlier chapters of this draft 

66 SEIS, the staff uses the NRC’s three-level standard of significance—SMALL, MODERATE, or 

67 LARGE—to indicate the intensity of environmental effects for each alternative that the staff 

68 evaluates in-depth. 
Environmental Impact of Alternatives 

February 2010 8-3 Draft NUREG-1437, Supplement 40 

Energy Outlook: Each year 

the EIA, part of the DOE, 

issues its updated Annual 

Energy Outlook (AEO). AEO 

2009 indicates that natural 

gas will account for most 

new electrical capacity 

through 2030, with 

significant contributions from 

new renewable sources and 

coal, as well as some growth 

in nuclear capacity (EIA, 

2009a) 

“Natural-gas-fired plants account for 53 

percent of capacity additions in the 

reference case [2008-2030], as compared 

with 22 percent for renewables, 18 percent 

for coal-fired plants, and 5 percent for 

nuclear. Escalating construction costs have 

the largest impact on capital-intensive 

technologies, including renewables, coal, 

and nuclear [ ]; but Federal tax incentives, 

State energy programs, and rising prices 

for fossil fuels increase the costcompetitiveness of renewable and nuclear 

capacity. In contrast, uncertainty about 

future limits on GHG [greenhouse gas] 

emissions and other possible 

environmental regulations ... reduces the 

competitiveness of coal.” 

1 By placing the detailed alternatives analyses in 

2 this order, the staff does not imply which 

3 alternative would have the least impact, or which 

4 alternative an energy planning decision maker 

5 would be most likely to implement. Whenever 

6 possible, the staff considers effects from locating 

7 the alternative at the existing site, as well as at 

8 an alternate site. In general, impacts are smaller 

9 at an existing site because infrastructure 

10 necessary to support a power plant already 

11 exists, nearby populations are accustomed to 

12 power plant operations, and the site has already 

13 been disturbed to some degree. 

14 Sections 8.1 through 8.3 include the staff’s 

15 analyses of environmental impacts of alternatives 

16 to license renewal. These include a gas-fired 

17 alternative located both at the KPS site and at a 

18 different site (8.1), a coal-fired alternative at the 

19 KPS site and an alternate site (8.2), and two 

20 combination alternatives that include gas-fired 

21 capacity onsite as well as conservation and either 

22 wind power or wood-fired power (8.3). In section 

23 8.4, the staff briefly discusses purchased power. 

24 In Section 8.5, the staff addresses alternatives 

25 excluded from in-depth analysis and addresses 

26 why they were excluded. Finally, in Section 8.6, 

27 the staff considers the environmental effects that 

28 may occur if NRC takes no action and does not 

29 issue renewed licenses for KPS. 

30 8.1 GAS-FIRED GENERATION 

31 In this section, the staff evaluates the 

32 environmental impacts of natural gas-fired generation at both the KPS site and at an alternate 

33 site. 

34 Natural gas fueled 21 percent of electric generation in the United States in 2008, accounting for 

35 the second greatest share of electrical power after coal (EIA, 2009b). Like coal-fired power 

36 plants, natural gas-fired plants may be affected by perceived or actual action to limit greenhouse 

37 gas (GHGs) emissions, though they produce markedly fewer GHGs per unit of electrical output 

38 than coal-fired plants. Natural gas-fired power plants are feasible, commercially-available 

39 options for providing electrical generating capacity beyond the current license terms for KPS. 

40 EIA projects that gas-fired generation will account for the largest share of capacity additions in 

41 the United States through 2030 (EIA, 2009a). 

42 Combined-cycle power plants differ significantly from power plants that generate electricity 

43 solely from a steam cycle, as almost all coal-fired and all existing domestic nuclear power plants 
Environmental Impacts of Alternatives 

Draft NUREG-1437, Supplement 40 8-4 February 2010 

1 do. Combined-cycle power plants derive the majority of their electrical output from a gas-turbine 

2 cycle, and then generate additional power—without burning any additional fuel—through a 

3 second, steam-turbine cycle. The first, gas-turbine stage (similar to a large jet engine) burns 

4 natural gas that turns a driveshaft to power an electric generator. Ducts carry the hot exhaust 

5 from the turbine to a heat recovery steam generator, which then produces steam to drive 

6 another turbine and produce additional electrical power. The combined-cycle approach is 

7 significantly more efficient than any one cycle on its own; efficiencies can reach or exceed 60 

8 percent. Natural gas combined-cycle generation requires significantly less cooling water and 

9 smaller cooling towers than the existing KPS, partly because of greater thermal efficiency and 

10 partly because gas turbines do not require condenser cooling like steam turbines do. 

11 In order to replace the 556 megawatts-electric (MWe) output that KPS currently supplies, the 

12 NRC staff selected a gas-fired alternative that uses two General Electric Company (GE) 

13 MS7001FB combined cycle units, which together produce a net of 560 MWe (roughly 4 percent 

14 of gross plant output would power auxiliary systems, so the gross output is approximately 

15 585 MWe). While any number of commercially-available combined-cycle units could be installed 

16 in a variety of combinations to replace the power currently produced by KPS, the MS7001FB is 

17 an efficient model that operates at a heat rate of 5,950 British thermal units per kilowatt hour 

18 (Btu/kWh), or 57.3 percent thermal efficiency (GE, 2007). GE and other manufacturers, like 

19 Siemens, offer similar high efficiency models, including several that slightly exceed the thermal 

20 efficiency of this model. Cooling towers for this alternative would likely be mechanical draft-type 

21 towers approximately 65 feet (20 m) in height. 

22 In addition to cooling towers, other visible structures onsite would include the turbine buildings 

23 and heat recovery steam generators (which may be enclosed in the turbine building), two 

24 exhaust stacks, an electrical switchyard, and, possibly, equipment associated with a natural gas 

25 pipeline, like a compressor station. The GEIS estimated that a 1,000 MWe gas-fired alternative 

26 would require 110 acres (40 ha), meaning this 560-MWe plant would require 64 acres (26 ha). 

27 In their ER, DEK (2008) indicated that the plant would require 26 acres (11 ha), a number more 

28 consistent with minimum utility needs as demonstrated by existing power plants (including 

29 Dominion Resources’ Fairless Energy Works located in Falls Township, Pennsylvania). The 

30 staff uses DEK’s estimate for the purposes of the following analysis. According to DEK, a gas31 fired plant constructed onsite would also require 272 acres (110 ha) for a natural gas pipeline. A 

32 gas-fired plant constructed at an alternate site would likely require a new pipeline spur, as well. 

33 For the purpose of this analysis, the staff assumes that a gas-fired alternative at an alternate 

34 site would require a similar amount of land for a pipeline and associated right of way (ROW). 

This 560-MWe power plant would consume 25.3 billion ft3

 (718 million m3 35 ) of natural gas 

annually, assuming an average heat content of 1,021 British thermal units per cubic feet (Btu/ft3 36 ) 

37 (EIA, 2008). Natural gas would be extracted from the ground through wells in another region of 

38 the United States, then treated to remove impurities (like hydrogen sulfide), and blended to 

39 meet pipeline gas standards, before being piped through the interstate pipeline system to the 

40 power plant site. This gas-fired alternative would produce relatively little waste, which would 

41 primarily be in the form of spent catalysts used for emissions controls. 

42 Environmental impacts from the gas-fired alternative will be greatest during construction. Site 

43 crews will clear vegetation from the site, prepare the site surface, and begin excavation before 

44 other crews begin actual construction on the plant and any associated infrastructure, including a 
Environmental Impact of Alternatives 

February 2010 8-5 Draft NUREG-1437, Supplement 40 

1 pipeline spur to serve the plant and electricity transmission infrastructure connecting the plant to 

2 existing transmission lines. 

3 Constructing the gas-fired alternative on the KPS site would allow the gas-fired alternative to 

4 make use of the site’s existing transmission system, as well as take advantage of partially 

5 cleared areas of the site. 

6 A gas-fired unit constructed offsite may cause additional construction-related impacts depending 

7 on the nature of the site selected. A site that has never been developed will likely experience 

8 greater impacts than a site that was previously industrial; a site near other power plants or 

9 industrial facilities will likely experience smaller impacts than a site surrounded by farmland or 

10 relatively natural surroundings. 

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

12 Compared to Continued Kewaunee Power Station Operation 

Gas-fired combined-cycle 

At KPS site At alternate site 

Continued 

KPS Operation 

Air Quality MODERATE MODERATE SMALL 

Groundwater SMALL SMALL SMALL 

Surface Water SMALL SMALL to MODERATE SMALL 

Ecology SMALL to MODERATE SMALL to MODERATE SMALL 

Human Health SMALL SMALL SMALL 

Socioeconomics SMALL to MODERATE SMALL to MODERATE SMALL to 

MODERATE 

Waste Management SMALL SMALL SMALL 

13 8.1.1 Air Quality 

14 Kewaunee County, Wisconsin, where KPS is located, is in EPA Region 5 and is in attainment 

15 for all criteria pollutants, except ozone. Kewaunee County is a maintenance area for 8-hour 

16 ozone (EPA, 2009a). 

17 A new gas-fired generating plant in Kewaunee County would qualify as a new major-emitting 

18 industrial facility and require New Source Review (NSR) and Prevention of Significant 

19 Deterioration of Air Quality review under the Clean Air Act (CAA), as adopted by Wisconsin 

20 Department of Natural Resources (WDNR) in the Wisconsin Administrative Code and its 

21 Statutes (EPA, 2008a; Wis. Adm. Code chapters NR400-499; Wis. Stats. Chapter 285). The 

22 EPA delegated the authority of regulating the issuance of construction and operating permits to 

23 the WDNR, which coordinates the Wisconsin air pollution control permit program for new and 

24 existing pollution sources. A natural gas-fired plant would also need to comply with the 

25 standards of performance for electric utility steam generating units set forth in Title 40 of the 

26 Code of Federal Regulations (CFR) Part 60 Subpart Da. 
Environmental Impacts of Alternatives 

Draft NUREG-1437, Supplement 40 8-6 February 2010 

1 Section 169A of the CAA (42 USC 7491) establishes a national goal of preventing future and 

2 remedying existing impairment of visibility in mandatory Class I Federal areas when impairment 

3 results from man-made air pollution. The EPA issued a regional haze rule in 1999 (64 FR 

4 35714; EPA, 1999). The rule specifies that for each mandatory Class I Federal area located 

5 within a State, the State must establish goals that provide for reasonable progress toward 

6 achieving natural visibility conditions through developing and implementing air quality protection 

7 plans to reduce the pollution that causes visibility impairment. There are five regional planning 

8 organizations (RPO) that are collaborating on the visibility impairment issue and developing the 

9 technical basis for these plans. Wisconsin, Illinois, Indiana, Michigan and Ohio belong to the 

10 Midwest Regional Planning Organization (Midwest RPO) that along with tribes, Federal 

11 agencies and other interested parties identifies regional haze and visibility issues and develops 

12 strategies to address them. The visibility protection regulatory requirements, contained in 40 

13 CFR Part 51, Subpart P, include the review of the new sources that would be constructed in the 

14 attainment or unclassified areas and may affect visibility in any Federal Class I area (40 CFR 

15 51.307). If a coal-fired plant were located close to a mandatory Class I area, additional air 

16 pollution control requirements would be imposed. 

17 There are no Mandatory Class I Federal areas in the State of Wisconsin or in close proximity to 

18 KPS. The closest Mandatory Class I Federal Areas to KPS are Seney Wilderness Area, 

19 Michigan, located 149 miles northeast from KPS, and Isle Royale National Park, Michigan, 

20 located 255 miles northwest of KPS. 

21 The emissions from the natural gas-fired alternative at the KPS site, based on published EIA 

22 data, EPA emission factors and on performance characteristics for this alternative and 

23 implemented emission controls, would be: 

24 ● Sulfur oxides (SOx) – 43.98 tons (39.90 Metric ton(s) (MT)) per year 

25 ● Nitrogen oxides (NOx) – 141.00 tons (127.91 MT) per year 

26 ● Carbon monoxide (CO) – 29.31 tons (26.59 MT) per year 

27 ● Total suspended particles (TSP) – 24.58 tons (22.30 MT) per year 

28 ● Particulate matter (PM) PM10 – 24.58 tons (22.30 MT) per year 

29 ● Carbon dioxide (CO2) – 1,513,164.22 tons (1,372,719.49 MT) per year 

30 The new natural gas-fired plant would have to comply with Title IV of the CAA reduction 

31 requirements for sulfur dioxide (SO2) and NOx, which are the main precursors of acid rain and a 

32 major cause of reduced visibility. Title IV establishes maximum SO2 and NOx emission rates for 

33 existing plants and a system of SO2 emission allowances that can be used, sold or saved for 

34 future use by new plants. On March 10, 2005, the EPA issued the Clean Air Interstate Rule 

35 (CAIR), which would create large permanent reductions in SO2 and NOx across 28 eastern 

36 states and the District of Columbia. However, petitions for review of the CAIR and CAIR Federal 

37 Implementation Plans (FIPs), including the provisions establishing the CAIR NOx annual and 

38 ozone season and SO2 trading programs, were filed in the U.S. Court of Appeals for the D.C. 

39 Circuit. 

40 On July 11, 2008, the Court issued an opinion vacating and remanding the CAIR and CAIR 

41 FIPs. After requested rehearing of the Court's decision, the Court granted rehearing only to the 

42 extent that it remanded the rules to EPA without vacating them on December 23, 2008. This 

43 ruling leaves CAIR and the CAIR FIPs, including the CAIR trading programs, in place until EPA 
Environmental Impact of Alternatives 

February 2010 8-7 Draft NUREG-1437, Supplement 40 

1 issues a new rule to replace CAIR in accordance with the July 11, 2008 decision. Wisconsin is 

2 among the States covered by this rule (EPA, 2009b). WDNR adopted the rule and is allocating 

3 annual NOx allowances for new electricity generating units subject to CAIR as specified in 

4 chapter NR 432 of the Wisconsin Administrative Code starting 2009. The NOx allowances are 

5 allocated from a "new unit set-aside" reserved pool of allowances, which represents 7 percent of 

6 Wisconsin's total budget of NOx allowances. 

7 As stated above, the new natural gas-fired alternative would produce 43.98 tons (39.90 MT) per 

8 year of SOx and 141.00 tons (127.91 MT) per year of NOx based on the use of the dry low NOx 

9 combustion technology and use of the selective catalytic reduction (SCR) in order to 

10 significantly reduce NOx emissions. 

11 The new plant would be subjected to the continuous monitoring requirements of SO2, NOx and 

12 CO2 specified in 40 CFR Part 75. The natural gas-fired plant would emit approximately 

13 1,513,164.22 tons (1,372,719.49 MT) per year of unregulated CO2 emissions. As of today, there 

14 is no required reporting of GHG emissions. In response to the Consolidated Appropriations Act 

15 of 2008, the EPA proposed a rule that would require mandatory reporting of GHG emissions 

16 from large sources, such as the presented alternative. The rule would allow for the collection of 

17 accurate and comprehensive emissions data to inform future policy decisions. The EPA 

18 proposes that suppliers of fossil fuels or industrial greenhouse gases, manufacturers of vehicles 

19 and engines, and facilities that emit 25,000 metric tons or more per year of GHG emissions 

20 submit annual reports to the EPA. The gases covered by the proposed rule are CO2, methane 

21 (CH4), nitrous oxide (N2O), hydrofluorocarbons (HFC), perfluorocarbons (PFC), sulfur 

22 hexafluoride (SF6), and other fluorinated gases including nitrogen trifluoride (NF3) and 

23 hydrofluorinated ethers (HFE). 

24 In 1993, WDNR conducted the “Wisconsin Greenhouse Gas Emissions Inventory and Emission 

25 Reduction Cost Study,” and, in 1998, developed the Climate Change Action Plan. The 

26 Wisconsin GHG emissions inventory is periodically updated. In 2007, following the signing of 

27 Executive Order (E.O.) 191 by the governor of Wisconsin, the Governor’s Task Force on Global 

28 Warming was created. The Task Force outlined its mission, goals and recommendations in the 

29 2008 final report to the governor, “Wisconsin's Strategy for Reducing Global Warming” (WDNR, 

30 2009). 

31 The gas-fired alternative would emit 24.58 tons (22.30 MT) per year of particulate matter having 

32 an aerodynamic diameter less than or equal to 10 micrometer (μm) (PM10) (40 CFR 50.6a). All 

33 emitted particulates are PM10. 

34 In December 2000, the EPA issued regulatory findings (EPA, 2000a) on emissions of 

35 hazardous air pollutants from electric utility steam-generating units. Natural gas-fired 

36 power plants were found by the EPA to emit hazardous air pollutants such as arsenic, 

37 formaldehyde and nickel. Unlike coal- and oil-fired power plants, the EPA did not 

38 determine that emissions of hazardous air pollutants from natural gas-fired power plants 

39 should be regulated under Section 112 of the CAA. 

40 Activities associated with the construction of a new natural gas-fired plant onsite or offsite would 

41 cause some additional air effects as a result of equipment emissions and fugitive dust from the 

42 operation of the earth moving and material handling equipment. Exhaust emissions from 
Environmental Impacts of Alternatives 

Draft NUREG-1437, Supplement 40 8-8 February 2010 

1 workers’ vehicles and motorized construction equipment would be temporary. Construction 

2 crews would employ dust-control practices in order to control and reduce fugitive dust, which 

3 would be temporary in nature. The staff concludes that the impact of vehicle exhaust emissions 

4 and fugitive dust from operation of the earth-moving and material handling equipment would be 

5 SMALL. 

6 The overall air-quality impacts of a new natural gas-fired plant located at the KPS site or at an 

7 alternate site would be MODERATE, primarily due to emissions released during plant operation. 

8 8.1.2 Groundwater Use and Quality 

9 The use of groundwater for a natural gas-fired combined-cycle plant (onsite or offsite) would 

10 likely be limited to supply wells for drinking water and possibly filtered service water for system 

11 cleaning purposes. For an onsite alternative, total usage would likely be much less than KPS 

12 because fewer workers would be onsite and because the gas-fired alternative would have fewer 

13 auxiliary systems requiring service water. 

14 No effects on groundwater quality would be apparent except during the construction phase due 

15 to temporary dewatering (if necessary) and run-off control measures. Because of the temporary 

16 nature of construction and the likelihood of reduced groundwater usage during operation as 

17 compared to KPS, the impact of the gas-fired alternative (onsite or offsite) would be SMALL. 

18 8.1.3 Surface Water Use and Quality 

19 Total withdrawals of surface water from Lake Michigan would be much less for an onsite gas20 fired plant than the 401,200 gallons per minute (gpm) (894 cubic feet per second (cfs) or 25.3 

cubic meter per second (m3 21 /s)) average currently used by KPS. However, by switching from the 

22 open-cycle cooling system currently used by KPS to a closed-cycle cooling system used by the 

23 proposed alternative, consumptive water losses will increase. Because the onsite gas-fired plant 

24 would draw water from Lake Michigan and not a small river with reduced flow, the NRC 

25 concludes the impact of surface water use from the onsite alternative would be SMALL. If the 

26 alternate offsite location is also adjacent to Lake Michigan, the NRC concludes that the impact 

27 of surface water use will also be SMALL, but could be MODERATE if the plant withdrew cooling 

28 water from a small river with low flow. 

29 A new gas-fired plant (onsite or offsite) would be required to obtain a Wisconsin Pollutant 

30 Discharge and Elimination System (WPDES) permit from the WDNR for regulation of industrial 

31 wastewater, storm water, and other discharges. Assuming the plant operates within the limits of 

32 this permit, the impact from any possible site runoff and effluent discharges on surface water 

33 quality would be SMALL. 

34 8.1.4 Aquatic and Terrestrial Ecology 

35 Aquatic Ecology

36 A new gas-fired plant would require a source of water for the plant’s closed-cycle cooling 

37 system, and a discharge point for cooling tower blowdown. Locating the plant on the existing 

38 KPS site will enable some already-existing buildings and infrastructure to be used; however, 

39 impacts to aquatic ecology are likely during construction regardless of where the plant is 
Environmental Impact of Alternatives 

February 2010 8-9 Draft NUREG-1437, Supplement 40 

1 located. Site disturbance will likely increase erosion and sedimentation runoff into Lake 

2 Michigan and nearby streams, increasing turbidity. While site procedures and management 

3 practices, as well as using already-existing structures on the KPS site when possible, may limit 

4 this effect, the impact will likely be noticeable. Overall construction effects are expected to be 

5 less significant for the gas-fired alternative than the coal-fired alternative because the amount of 

6 site disturbance is less and many of the major plant components are smaller and require less 

7 onsite fabrication. 

8 During operations, the gas-fired alternative would require significantly less water for cooling than 

9 either the coal-fired alternative or the existing KPS unit, which would minimize the potential for 

10 impingement and entrainment and lessen the thermal discharge from the plant. Spills occurring 

11 during onsite activities will need to be appropriately handled, and runoff from new, impervious 

12 surfaces (e.g., roads and rooftops) may affect aquatic ecology, as could deposition of airborne 

13 pollutants to surface water, though these impacts are likely to be less pronounced than those 

14 from the coal-fired alternative. 

15 Overall impacts to aquatic ecology from a gas-fired alternative are expected to be SMALL. 

16 Terrestrial Ecology

17 Constructing the natural gas alternative, if the location is off site, will require approximately 

18 32 acres (13 ha) of land. Land requirements would be minimal if the location is on the current 

19 KPS site. These land disturbances form the basis for impacts to terrestrial ecology. (Gas 

20 extraction and collection will also affect terrestrial ecology in offsite gas fields, although, as 

21 noted in Section 8.1, much of this land is likely already disturbed by gas extraction, and the 

22 incremental effects of this alternative on gas field terrestrial ecology are difficult to gauge.) 

23 Impacts to terrestrial ecology will be minor if the selected site is the current KPS site because 

24 the site has been previously disturbed. Impacts to terrestrial ecology could be adverse if the 

25 location is off site; however, locating an offsite gas-fired plant on a previously disturbed site 

26 would minimize impacts. There is potential for disturbance of some areas with trees, Lake 

27 Michigan shoreline, or wetlands, and possible habitat fragmentation would occur. Construction 

28 of any additional transmission line ROWs, a lengthy pipeline, or additional roads on undisturbed 

29 or less-disturbed areas could adversely impact terrestrial ecology by fragmenting or destroying 

30 habitats. However, a pipelined fuel source and a small workforce would help to minimize the 

31 need for additional transportation infrastructure. 

32 In addition, construction onsite, if some shorelines are impacted, or some of the forested lands 

33 and/or wetlands are converted to building facilities may eliminate onsite habitats and alter the 

34 site for a long period of time. Some areas onsite, such as any buffer areas, may remain 

35 undeveloped and could still harbor habitat for terrestrial species, though site lighting, noise, and 

36 activities may degrade the value of any remaining ecosystems. Deposition of air pollutants from 

37 this alternative may affect terrestrial ecology, but it is unlikely to be noticeable. Impacts to 

38 terrestrial resources from a natural gas combined-cycle alternative at both the KPS site and an 

39 alternate site would like be SMALL to MODERATE. Some of these impacts could be mitigated if 

40 the location of the gas-fired alternative is either placed on the current KPS site or on a 

41 previously disturbed location. 
Environmental Impacts of Alternatives 

Draft NUREG-1437, Supplement 40 8-10 February 2010 

1 8.1.5 Human Health 

2 The effects of gas-fired generation on human health are generally low, although in Table 8-2 of 

3 the GEIS (NRC, 1996), the staff identified cancer and emphysema as potential health risks from 

4 gas-fired plants. These risks are likely attributable to NOx emissions that contribute to ozone 

5 formation, which in turn contribute to health risks. It is expected that appropriate emission 

6 controls installed on the gas-fired alternative option would maintain NOx emissions well below 

7 EPA air quality standards established for the protection of human health. In addition, the use of 

8 emissions trading or offset requirements would ensure that the overall NOx in the region will not 

9 increase. There are potential health risks to plant workers from handling spent catalysts used to 

10 filter the emissions, because they may contain toxic heavy metals. However, the use of 

11 protective equipment and adherence to safety requirements would minimize the danger to the 

12 workers. It is expected that the facility would operate in compliance with Federal and State 

13 safety and emission standards. 

14 Overall, the impacts on human health of the natural gas-fired alternative are likely to be SMALL. 

15 8.1.6 Socioeconomics 

16 Land Use

17 The analysis of land use impacts focuses on the amount of land area that would be affected by 

18 the construction and operation of a two unit natural gas-fired combined-cycle power plant at the 

19 KPS site and an alternative site. Land-use impacts would vary depending on where the plant 

20 would be located and whether construction would take place on undeveloped land or within a 

21 previously disturbed industrial (brownfield) area. 

22 DEK indicated that over 298 acres (121 ha) of land would be needed to support a natural gas23 fired alternative capable of replacing the KPS (DEK, 2008) including pipeline. The GEIS, 

24 however, estimates 110 acres (45 ha) of land would be needed to support a 1,000-MWe 

25 generating station (NRC, 1996). DEK estimated that 272 acres would be needed for a natural 

26 gas pipeline connection to KPS. This amount of land use would include other plant structures 

27 and associated infrastructure. By scaling the GEIS estimate, the 590-MWe KPS plant could 

28 require up to 336 acres (136 ha) of land. 

29 However, if additional land would be necessary for a buffer around plant structures or to support 

30 transmission lines at an alternate site and gas pipelines at both KPS and at an alternate site, the 

31 staff believes the DEK estimate to be reasonable, although additional land may be used for 

32 buffer around plant structures or to support transmission lines. Even assuming additional land 

33 use for these purposes, total land required by the natural gas-fired alternative is unlikely to 

34 exceed 298 acres (121 ha) for all uses, excluding land for natural gas wells and collection 

35 stations. Land use impacts from construction would be SMALL, and could be further reduced if 

36 the power plant is collocated at an alternate site with another generating station or on a 

37 previously industrial site like KPS. Impacts could be further mitigated at an alternate site by 

38 constructing new transmission lines in existing ROWs. 

39 In addition to onsite land requirements, land would be required off site for natural gas wells and 

40 collection stations. The GEIS estimates that 3,600 acres (1,457 ha) would be required for wells, 

41 collection stations, and pipelines to bring the gas to a 1,000-MWe generating facility. If this land 
Environmental Impact of Alternatives 

February 2010 8-11 Draft NUREG-1437, Supplement 40 

1 requirement were scaled with generating capacity, a natural gas-fired power plant at the KPS 

2 could require 2,124 acres (860 ha). Most of this land requirement would occur on land where 

3 gas extraction already occurs. In addition, some natural gas could come from outside of the 

4 United States and be delivered as liquefied gas. 

5 The elimination of uranium fuel for the KPS could partially offset offsite land requirements. In the 

6 GEIS, the NRC staff estimated that approximately 1,000 acres (405 ha) would not be needed for 

7 mining and processing uranium during the operating life of a 1,000-MWe nuclear power plant. 

8 For KPS, roughly 590 acres (239 ha) of uranium mining area would no longer be needed. 

9 Overall land use impacts from a gas-fired power plant would be SMALL to MODERATE, 

10 depending on local land use and the availability of land near the proposed site. 

11 Socioeconomics

12 Socioeconomic impacts are defined in terms of changes to the demographic and economic 

13 characteristics and social conditions of a region. For example, the number of jobs created by the 

14 construction and operation of a new natural gas-fired power plant could affect regional 

15 employment, income, and expenditures. Two types of job creation may occur: (1) construction16 related jobs, which are transient, short in duration, and less likely to have a long-term 

17 socioeconomic impact; and (2) operation-related jobs in support of power plant operations, 

18 which have the greater potential for permanent, long-term socioeconomic impacts. Staff 

19 estimated workforce requirements of power plant construction and operations for the natural 

20 gas-fired power plant alternative in order to determine their possible effect on current 

21 socioeconomic conditions. 

22 The GEIS projects a workforce of 1,200 for a 1,000-MWe plant, which means a workforce of 

23 approximately 708 for a 590-MWe plant. During construction, the communities surrounding the 

24 power plant site would experience increased demand for rental housing and public services, 

25 although these effects would be moderated if the alternate construction site is located near an 

26 urban area with many skilled workers. The relative economic effect of construction workers on 

27 local economy and tax base would vary over time. 

28 After construction, local communities may be temporarily affected by the loss of construction 

29 jobs and associated loss in demand for business services, and the rental housing market could 

30 experience increased vacancies and decreased prices. As noted in the GEIS, the 

31 socioeconomic impacts at a rural construction site could be larger than at an urban site, 

32 because the workforce would have to move to be closer to the construction site. The impact of 

33 construction on socioeconomic conditions could range from SMALL to MODERATE depending 

34 on whether the new power plant would be located at KPS or an alternate site. The 

35 socioeconomic impacts of power plant construction could be further reduced if the power plant 

36 is located near an urban area with many skilled workers. 

37 DEK estimated a power plant operations workforce of 20 (DEK, 2008), while scaled GEIS 

38 estimates indicate up to 89 workers (150 operations workers for a 1,000-MWe plant). The DEK 

39 estimate appears to be low, but is consistent with trends toward lowering labor costs by 

40 reducing the size of power plant operations workforces. Nevertheless, depending on location, 

41 the small number of operations workers would not likely have a noticeable effect on 
Environmental Impacts of Alternatives 

Draft NUREG-1437, Supplement 40 8-12 February 2010 

1 socioeconomic conditions in the region. Therefore, socioeconomic impacts associated with the 

2 operation of a gas-fired power plant could be SMALL at KPS or an alternate site. 

3 Transportation

4 During construction, approximately 700 workers would be commuting to the site. In addition to 

5 commuting workers, trucks would transport construction materials and equipment to the 

6 worksite increasing the amount of traffic on local roads. The increase in vehicular traffic would 

7 peak during shift changes resulting in temporary levels of service impacts and delays at 

8 intersections. Pipeline construction and modification to existing natural gas pipeline systems 

9 could also have an impact. 

10 During plant operations, transportation impacts would almost disappear. As noted in this 

11 section, relatively few workers are required to operate the gas-fired alternative. Since fuel is 

12 transported by pipeline, most transportation infrastructure would experience little increased use 

13 from plant operations. 

14 Overall, the gas-fired alternative would have a SMALL impact on transportation conditions in the 

15 region around the KPS or at an alternate site. Transportation impacts at an alternate site would 

16 depend on road capacity and average daily volume. 

17 Aesthetics

18 Aesthetic resources are the natural and manmade features that give a particular landscape its 

19 character and aesthetic quality. The aesthetics impact analysis focuses on the degree of 

20 contrast between the power plant and the surrounding landscape and the visibility of the power 

21 plant. 

22 The two gas-fired units could be approximately 100 feet (30 m) tall, with two exhaust stacks up 

23 to 175 feet (53 m) tall or taller depending on the topography at an alternate site. Some 

24 structures may require aircraft warning lights. Power plant infrastructure would generally be 

25 smaller and less noticeable than the KPS. Mechanical draft cooling towers would generate 

26 condensate plumes and operational noise. Noise during power plant operations would be limited 

27 to industrial processes and communications. Pipelines delivering natural gas fuel could be 

28 audible off site near compressors. 

29 In addition to new power plant structures, the alternate plant site may require the construction of 

30 transmission lines and natural gas pipelines. The transmission lines would have a lasting visual 

31 effect on the landscape. 

32 In general, aesthetic changes would be limited to the immediate vicinity of the KPS or an 

33 alternate site. Impacts would likely to be SMALL to MODERATE at KPS or an alternate site and 

34 would depend on the amount of new transmission line required. 

35 Historic and Archaeological Resources

36 Cultural resources are the indications of human occupation and use of the landscape as defined 

37 and protected by a series of Federal laws, regulations, and guidelines. Prehistoric resources are 

38 physical remains of human activities that predate written records; they generally consist of 

39 artifacts that may alone or collectively yield information about the past. Historic resources 
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February 2010 8-13 Draft NUREG-1437, Supplement 40 

1 consist of physical remains that postdate the emergence of written records; in the United States, 

2 they are architectural structures or districts, archaeological objects, and archaeological features 

3 dating after 1492. Ordinarily, sites less than 50 years old are not considered historic, but 

4 exceptions can be made for such properties if they are of particular importance, such as 

5 structures associated with the development of nuclear power (e.g., Shippingport Atomic power 

6 Station) or Cold War themes. American Indian resources are sites, areas, and materials 

7 important to American Indians for religious or heritage reasons. Such resources may include 

8 geographic features, plants, animals, cemeteries, battlefields, trails, and environmental features. 

9 The cultural resource analysis encompassed the power plant site and adjacent areas that could 

10 potentially be disturbed by the construction and operation of alternative power plants. 

11 The potential for historic and archaeological resources can vary greatly depending on the 

12 location of the proposed site. To consider a project's effects on historic and archaeological 

13 resources, any proposed areas will need to be surveyed to identify and record historic and 

14 archaeological resources, identify cultural resources (e.g., traditional cultural properties), and 

15 develop possible mitigation measures to address any adverse effects from ground disturbing 

16 activities. Studies will be needed for all areas of potential disturbance at the proposed plant site 

17 and along associated corridors where new construction will occur (e.g., roads, transmission 

18 corridors, rail lines, or other ROWs). In most cases, project proponents should avoid areas with 

19 the greatest sensitivity. 

20 The impact for a gas-fired alternative at the KPS site would be SMALL. As noted in Section 

21 4.9.6, DEK conducted a survey of the KPS site in 2007 and is developing a Cultural Resources 

22 Management Plan. This plan includes pre-job briefings for workers and an inadvertent discovery 

23 (stop work) provision. Depending on the resource richness of an alternative site ultimately 

24 chosen for the gas-fired alternative, impacts could range from SMALL to MODERATE. 

25 Environmental Justice

26 The environmental justice impact analysis evaluates the potential for disproportionately high and 

27 adverse human health and environmental effects on minority and low-income populations that 

28 could result from the construction and operation of a new natural gas-fired power plant. Adverse 

29 health effects are measured in terms of the risk and rate of fatal or nonfatal adverse impacts on 

30 human health. Disproportionately high and adverse human health effects occur when the risk or 

31 rate of exposure to an environmental hazard for a minority or low-income population is 

32 significant and exceeds the risk or exposure rate for the general population or for another 

33 appropriate comparison group. The minority and low-income populations are subsets of the 

34 general public residing around the site, and all are exposed to the same hazards generated 

35 from various power plant operations. 

36 Minority and low-income populations could be affected by the construction and operation of a 

37 new natural gas-fired power plant. Some of these effects have been identified in resource areas 

38 discussed in this section. The extent of disproportionate effect is difficult to determine since it 

39 would depend on the location of the natural gas-fired power plant. For example, increased 

40 demand for rental housing during construction could disproportionately affect low-income 

41 populations. However, demand for rental housing could be mitigated if the alternate plant site is 

42 constructed near a metropolitan area. 
Environmental Impacts of Alternatives 

Draft NUREG-1437, Supplement 40 8-14 February 2010 

1 Impacts on minority and low-income populations from the construction and operation of a 

2 natural gas-fired power plant alternative could range from SMALL to MODERATE, due to the 

3 small number of workers needed to construct and operate the natural gas-fired power plant. 

4 8.1.7 Waste Management 

5 During the construction stage of this alternative, land clearing and other construction activities 

6 would generate waste that can be recycled, disposed onsite or shipped to an offsite waste 

7 disposal facility. If the alternative were constructed at the KPS site or any previously disturbed 

8 site, the amounts of wastes produced during land-clearing would be reduced. 

9 During the operational stage, spent SCR catalysts, which are used to control NOx emissions 

10 from the natural gas-fired plants, would make up the majority of the waste generated by this 

11 alternative. 

12 The staff concluded in the GEIS (NRC, 1996) that a natural gas-fired plant would generate 

13 minimal waste and the waste impacts would be SMALL for a natural gas-fired alternative 

14 located at the KPS site or offsite. 

15 8.2 COAL-FIRED GENERATION 

16 Coal-fired generation accounts for a greater share of U.S. electrical power generation than any 

17 other fuel (EIA, 2009b). While coal-fired power plants are widely used and are likely to remain 

18 widely used, the staff notes that future coal capacity additions may be affected by perceived or 

19 actual efforts to limit greenhouse gas emissions. For now, the staff considers a coal-fired 

20 alternative to be a feasible, commercially available option that could provide electrical 

21 generating capacity after KPS’s current license expires. 

22 Supercritical technologies are increasingly common in new coal-fired plants. Supercritical plants 

23 operate at higher temperatures and pressures than most existing coal-fired plants (beyond 

24 water’s “critical point”, where boiling no longer occurs and no clear phase change occurs 

25 between steam and liquid water). Operating at higher temperatures and pressures allows this 

26 coal-fired alternative to operate at a higher thermal efficiency than many existing coal-fired 

27 power plants do. While supercritical facilities are more expensive to construct, they consume 

28 less fuel for a given output, reducing environmental impacts. Based on technology forecasts 

29 from EIA, the staff expects that a new, supercritical coal-fired plant beginning operation in 2014 

30 would operate at a heat rate of 9,069 Btu/kWh, or approximately 38 percent thermal efficiency 

31 (EIA, 2009c). 

32 In a supercritical coal-fired power plant, burning coal heats pressurized water. As the 

33 supercritical steam/water mixture moves through plant pipes to a turbine generator, the 

34 pressure drops and the mixture flashes to steam. The heated steam expands across the turbine 

35 stages, which then spin and turn the generator to produce electricity. After passing through the 

36 turbine, any remaining steam is condensed back to water in the plant’s condenser. 

37 In most modern U.S. facilities, condenser cooling water circulates through cooling towers or a 

38 cooling pond system (either of which are closed-cycle cooling systems). Older plants often 

39 withdraw cooling water directly from existing rivers or lakes and discharge heated water directly 
Environmental Impact of Alternatives 

February 2010 8-15 Draft NUREG-1437, Supplement 40 

1 to the same body of water (called open-cycle cooling). In this case, a coal-fired alternative 

2 constructed on the KPS site would withdraw makeup water from and discharge blowdown 

3 (water containing concentrated dissolved solids and biocides) from cooling towers back to Lake 

4 Michigan. As KPS currently uses a once-through cooling system, it is possible that a new coal5 fired plant on the KPS site could continue to use the existing KPS intake for a once-through 

6 cooling system. The staff will evaluate a closed-cycle option, as it results in lower operational 

7 impacts to aquatic life. At the same time, a closed-cycle option may increase aesthetic impacts 

8 as well as construction-stage impacts. 

9 In order to replace the 556 net MWe that KPS currently supplies, the coal-fired alternative would 

10 need to produce roughly 618 gross MWe, using about 6 percent of power output for onsite 

11 power usage. Onsite electricity demands include scrubbers, cooling towers, coal-handling 

12 equipment, lights, communication, and other onsite needs. A supercritical coal-fired power plant 

13 equivalent in capacity to KPS and using the same cooling system would require less cooling 

14 water than KPS because the alternative operates at a higher thermal efficiency. 

15 The coal-fired power plant would consume 2.27 million tons (2.06 million MT) of coal annually 

16 assuming an average heat content of 8,967 British thermal units per pound (Btu/lb) (EIA, 2008). 

17 EIA reported that most coal consumed in Wisconsin originates in Wyoming. Given current coal 

18 mining operations in the State of Wyoming, the coal used in this alternative would likely be 

19 mined in surface mines, then mechanically processed and washed, before being transported—

20 via an existing rail spur—to the power plant site. Limestone for scrubbers would also arrive by 

21 rail. This coal-fired alternative would then produce roughly 123,400 tons (112,000 MT) of ash, 

22 and roughly 42,300 tons (38,400 MT) scrubber sludge annually. As noted above, much of the 

23 coal ash and scrubber sludge could be reused depending on local recycling and reuse markets. 

24 Environmental impacts from the coal-fired alternative will be greatest during construction. Site 

25 crews will clear the plant site of vegetation, prepare the site surface, and begin excavation 

26 before other crews begin actual construction on the plant and any associated infrastructure. 
Environmental Impacts of Alternatives 

Draft NUREG-1437, Supplement 40 8-16 February 2010 

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

2 Continued Kewaunee Power Station Operation 

Coal-fired Alternative 

At the KPS Site At an Alternative Site 

Continued KPS 

Operation 

Air Quality MODERATE MODERATE SMALL 

Groundwater SMALL SMALL SMALL 

Surface Water SMALL SMALL to MODERATE SMALL 

Ecology MODERATE MODERATE SMALL 

Human Health SMALL SMALL SMALL 

Socioeconomics SMALL to LARGE SMALL to LARGE SMALL TO MODERATE 

Waste Management MODERATE MODERATE SMALL 

3 8.2.1 Air Quality 

4 The coal-fired generation air quality impacts can be substantial because of the significant 

5 quantity of SOx, NOx, particulates, CO emissions, hazardous air pollutants (HAPs) such as 

6 mercury, and naturally occurring radioactive materials resulting from the process. However, 

7 many of these pollutants can be effectively controlled by various technologies. 

8 KPS is located in Kewaunee County, Wisconsin, which is a maintenance area for 8-hour ozone 

9 and in attainment for all other criteria air pollutants. A new coal-fired generating plant would 

10 qualify as a new major-emitting industrial facility and would require new source review (NSR) 

11 and Prevention of Significant Deterioration of Air Quality review under the under CAA (EPA, 

12 2008a). The NSR program requires that a permit be obtained before construction of the new 

13 major-emitting industrial facility (42 USC 7475(a)). The EPA delegated the authority of 

14 regulating the issuance of the construction and operating permits to the WDNR, which 

15 coordinates the Wisconsin air pollution control permit program for new and existing pollution 

16 sources. The new coal-fired generating plant would also have to comply with the new source 

17 performance standards for coal-fired plants set forth in 40 CFR 60 Subpart Da. The standards 

18 establish limits for particulate matter and opacity (40 CFR 60.42(a)), SO2 (40 CFR 60.43(a)), 

19 and NOx (40 CFR 60.44(a)). 

20 Section 169A of the CAA (42 USC 7401) establishes a national goal of preventing future and 

21 remedying existing impairment of visibility in mandatory Class I Federal areas when impairment 

22 results from man-made air pollution. The EPA issued a new regional haze rule in 1999 (64 FR 

23 35714; EPA, 1999). The rule specifies that for each mandatory Class I Federal area located 

24 within a State, the State must establish goals that provide for reasonable progress toward 

25 achieving natural visibility conditions through developing and implementing air quality protection 

26 plans to reduce the pollution that causes visibility impairment. As noted in 8.1.1, there are 

27 Regional Planning Organizations (RPOs) collaborating on the visibility impairment issue, 

28 developing the technical basis for these plans. Wisconsin, Illinois, Indiana, Michigan, and Ohio 

29 belong to the Midwest RPO that along with tribes, Federal agencies and other interested parties 
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February 2010 8-17 Draft NUREG-1437, Supplement 40 

1 identifies regional haze and visibility issues and develops strategies to address them. The 

2 visibility protection regulatory requirements, contained in 40 CFR Part 51, Subpart P, include the 

3 review of the new sources that would be constructed in the attainment or unclassified areas and 

4 may affect visibility in any Federal Class I area (40 CFR 51.307). If a coal-fired plant were 

5 located close to a mandatory Class I area, additional air pollution control requirements would be 

6 imposed. There are no Mandatory Class I Federal areas in the State of Wisconsin or in the 

7 close proximity to KPS. The closest Mandatory Class I Federal Areas to KPS are Seney 

8 Wilderness Area, Michigan, located 149 miles northeast from KPS, and Isle Royale National 

9 Park, Michigan, located 255 miles northwest from KPS. 

10 The emissions from the coal-fired alternative at KPS site, based on published Energy 

11 Information Administration (EIA) data, EPA emission factors, and on performance 

12 characteristics for this alternative and implemented emission controls, would likely be: 

13 ● Sulfur oxides (SOx) – 775.81 tons (703.80 MT) per year 

14 ● Nitrogen oxides (NOx) – 567.11 tons (514.47 MT) per year 

15 ● Total suspended particles (TSP) – 61.70 tons (55.97 MT) per year 

16 ● Particulate matter (PM) PM10 – 123.40 tons (111.95 MT) per year 

17 ● Particulate matter (PM) PM2.5 – 61.70 tons (55.97 MT) per year 

18 ● Carbon monoxide (CO) – 567.11 tons (514.47 MT) per year 

19 ● Mercury (Hg) – 0.09 tons (0.08 MT) per year 

20 Sulfur oxides emissions and nitrogen oxides emissions. The coal-fired alternative at the KPS 

21 site would likely use wet, limestone-based scrubbers to remove SOx. The EPA indicates that 

22 this technology can remove more than 95 percent of SOx from flue gases. NRC staff projects 

23 total SOx emissions would be 775.81 tons (703.80 MT) per year. 

24 On March 10, 2005, the EPA issued the Clean Air Interstate Rule (CAIR), which would create 

25 large permanent reductions in SO2 and NOx across 28 eastern states and the District of 

26 Columbia. However, petitions for review of the CAIR and CAIR Federal Implementation Plans 

27 (FIPs), including the provisions establishing the CAIR NOx annual and ozone season and SO2

28 trading programs, were filed in the U.S. Court of Appeals for the D.C. Circuit. On July 11, 2008, 

29 the Court issued an opinion vacating and remanding the CAIR and CAIR FIPs. After requested 

30 rehearing of the Court's decision, the Court granted rehearing only to the extent that it 

31 remanded the rules to the EPA without vacating them on December 23, 2008. This ruling leaves 

32 CAIR and the CAIR FIPs, including the CAIR trading programs, in place until the EPA issues a 

33 new rule to replace CAIR in accordance with the July 11, 2008 decision. Wisconsin is among 

34 the States covered by this rule (EPA, 2009b). WDNR adopted the rule and is allocating annual 

35 NOx allowances for new electricity generating units subject to CAIR as specified in chapter NR 

36 432 of the Wisconsin Administrative Code starting in 2009. The NOx allowances are allocated 

37 from a "new unit set-aside" reserved pool of allowances, which represents 7 percent of 

38 Wisconsin's total budget of NOx allowances. 

39 SOx emissions from a new coal-fired power plant would be subject to the requirements of Title 

40 IV of the CAA. Title IV was enacted to reduce emissions of SO2 and NOx, the two principal 

41 precursors of acid rain, by restricting emissions of these pollutants from power plants. Title IV 

42 caps aggregate annual power plant SO2 emissions and imposes controls on SO2 emissions 

43 through a system of marketable allowances. The EPA issues one allowance for each ton of SO2
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Draft NUREG-1437, Supplement 40 8-18 February 2010 

1 that a unit is allowed to emit. New units do not receive allowances, but are required to have 

2 allowances to cover their SO2 emissions. Owners of new units must therefore purchase 

3 allowances from owners of other power plants or reduce SO2 emissions at other power plants 

4 they own. Allowances can be banked for use in future years. Thus, provided a new coal-fired 

5 power plant is able to purchase sufficient allowances to operate, it would not add to net regional 

6 SO2 emissions, although it might do so locally. 

7 A coal-fired alternative constructed either at the KPS site or offsite would most likely employ 

8 various available NOx-control technologies, which can be grouped into two main categories: 

9 combustion modifications and post-combustion processes. Combustion modifications include 

10 low-NOx burners, over fire air, flue gas recirculation and operational modifications. Post11 combustion processes include SCR, selective noncatalytic reduction and hybrid processes. 

12 Effective combination of the combustion modifications and post-combustion processes can 

13 reduce NOx emissions by up to 95 percent. DEK would use the combination low-NOx burners, 

14 over fire air and SCR technologies in order to reduce NOx emissions from this alternative. 

15 Assuming the use of such technologies at KPS site, NOx emissions after scrubbing are 

16 estimated at 567.11 tons (514.47 MT) annually. 

17 Section 407 of the CAA establishes technology-based NOx emissions limitations. A new coal18 fired power plant would be subject to the new source performance standards for such plants as 

19 indicated in 40 CFR 60.44a(d)(1). This regulation, issued on September 16, 1998 (63 FR 

20 49422), limits the discharge of any gases that contain NOx to 200 nanograms (ng) per joule (J) 

21 of gross energy output (equivalent to 1.6 lb/megawatt hours (MWh)), based on a 30-day rolling 

22 average. 

23 Particulate emissions. The new coal-fired power plant would use fabric filters to remove 

24 particulates from flue gases. DEK indicates that fabric filters would remove 99.9 percent of 

25 particulate matter (DEK, 2008). The EPA notes that filters are capable of removing in excess of 

26 99 percent of particulate matter and that SO2 scrubbers further reduce particulate matter 

27 emissions (EPA, 2008b). As such, NRC staff believes DEK removal factor is appropriate. Based 

28 on this, the new supercritical coal-fired plant would emit 123.40 tons (111.95 MT) per year of 

29 PM10 and approximately 61.70 tons (55.97 MT) per year of PM2.5. In addition, coal-handling 

30 equipment would introduce fugitive dust emissions when fuel is being transferred to onsite 

31 storage and then reclaimed from storage for use in the plant. 

32 During the construction of a coal-fired plant, onsite activities would also generate fugitive dust. 

33 Also vehicles of the workers and motorized equipment would create exhaust emissions during 

34 the construction process. However, these impacts would be intermittent and short-termed. 

35 There would be dust-control measures implemented in order to minimize dust generation. 

36 Carbon monoxide emissions. Based on EPA emission factors (EPA, 1998), NRC staff estimates 

37 that the total CO emissions would be approximately 567.11 tons (514.47 MT) per year. 

38 Hazardous Air Pollutants including mercury. The EPA is in the process of developing emissions 

39 standards for power plants under the Clean Air Act (Section 112), including mercury emissions, 

40 following the D.C. Circuit Court’s February 8, 2008 ruling that vacated EPA’s Clean Air Mercury 

41 Rule (CAMR) (EPA, 2007). Before CAMR, the EPA determined that coal- and oil-fired electric 

42 utility steam-generating units are significant emitters of HAPs (EPA, 2000a). The EPA 
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February 2010 8-19 Draft NUREG-1437, Supplement 40 

1 determined that coal plants emit arsenic, beryllium, cadmium, chromium, dioxins, hydrogen 

2 chloride, hydrogen fluoride, lead, manganese, and mercury (EPA, 2000a). The EPA concluded 

3 that mercury is the HAP of greatest concern and that (1) a link exists between coal combustion 

4 and mercury emissions, (2) electric utility steam-generating units are the largest domestic 

5 source of mercury emissions, and (3) certain segments of the U.S. population (e.g., the 

6 developing fetus and subsistence fish-eating populations) are believed to be at potential risk of 

7 adverse health effects resulting from mercury exposures caused by the consumption of 

8 contaminated fish (EPA, 2000a). In light of the court’s decision, the EPA will revisit mercury 

9 regulation, although it is possible that the agency will continue to regulate mercury as a HAP, 

10 thus requiring the use of best available control technology to prevent its release to the 

11 environment. The Wisconsin Mercury Rule, revised in 2008, requires all new coal-fired power 

12 plants to achieve Maximum Achievable Control Technology (MACT) in order to reduce 

13 emissions of hazardous air pollutants, including mercury, and specifies that the permitted 

14 mercury reduction shall not be less than 90 percent of the removal of mercury from combusted 

15 coal (WDNR, 2008). 

16 Carbon Dioxide. A coal-fired plant would also have unregulated CO2 emissions during 

17 operations as well as during mining, processing, and transportation. The coal-fired plant would 

18 emit between 4,176,024.00 tons (3,788,425.25 MT) to 4,326,548.00 tons (3,924,978.32 MT) of 

19 CO2 per year, depending on the type and quality of the coal. 

20 Summary of Air Quality

21 While the GElS analysis mentions global warming from unregulated CO2 emissions and acid 

22 rain from SOx and NOx emissions as potential impacts, it does not quantify emissions from 

23 coal-fired power plants. However, the GElS analysis implies that air impacts would be 

24 substantial (NRC, 1996). The above analysis shows that emissions of air pollutants, including 

25 SOx, NOx, CO, and particulates, exceed those produced by the existing nuclear power plant, as 

26 well as those of the other alternatives considered in this section. Operational emissions of CO2

27 are also much greater under the coal-fired alternative. Adverse human health effects such as 

28 cancer and emphysema have also been associated with air emissions from coal combustion, 

29 and are discussed further in Section 8.2.5. 

30 The NRC analysis for a coal-fired alternative at an alternate site indicates that impacts from the 

31 coal-fired alternative would have clearly noticeable effects, but given existing regulatory 

32 regimes, permit requirements, and emissions controls, the coal-fired alternative would not 

33 destabilize air quality. Therefore, the appropriate characterization of air impacts from coal-fired 

34 plant located at KPS site would be MODERATE. Existing air quality would result in varying 

35 needs for pollution control equipment to meet applicable local and federal requirements, or 

36 varying degrees of participation in emissions trading schemes. 

37 8.2.2 Groundwater Use and Quality 

38 If the onsite coal-fired alternative continued to use groundwater for drinking water and service 

39 water, the need for groundwater at the plant would be minor, with supply wells used for potable 

40 drinking water and various service water functions. Total usage would likely be much less than 

41 KPS because fewer workers would be onsite and because the coal-fired unit would have fewer 

42 auxiliary systems requiring service water. No effect on groundwater quality would be apparent. If 
Environmental Impacts of Alternatives 

Draft NUREG-1437, Supplement 40 8-20 February 2010 

1 an alternative site is chosen, the need for groundwater use for plant operations would likely be 

2 minor. 

3 Construction of a coal-fired plant (onsite or offsite) could have a localized effect on groundwater 

4 due to temporary dewatering and run-off control measures. Because of the temporary nature of 

5 construction and the likelihood of reduced groundwater usage during operation, the impact of 

6 the coal-fired alternative would be SMALL. 

7 8.2.3 Surface Water Use and Quality 

8 Because the onsite alternative would draw water from Lake Michigan, most of the approximately 

8,000 gpm (0.5 m3 9 /s) needed for maximum withdrawal would be taken from the lake with an 

average consumptive loss of about 10 million gallons per day (mgd) (0.4 m3 10 /s). The alternative 

11 would use a closed-cycle system with cooling towers, which would increase consumptive water 

12 losses from the currently operating open-cycle cooling system used by KPS. However, because 

13 the onsite coal-fired plant would draw water from Lake Michigan and not a small river, the NRC 

14 concludes the impact of surface water use would be SMALL. If the chosen alternative site is 

15 also adjacent to Lake Michigan, the NRC concludes that the impact of surface water use will 

16 also be SMALL, but could increase to MODERATE if the plant relies on a small river with low 

17 flow for cooling water. 

18 Any new coal-fired plant in the area (onsite or offsite) would be required to obtain a WPDES 

19 permit from the WDNR for regulation of industrial wastewater, storm water, and other 

20 discharges. Assuming the plant operates within the limits of this permit, the impact from any 

21 possible runoff from coal piles and effluent discharges on surface water quality would be 

22 SMALL. 

23 8.2.4 Aquatic and Terrestrial Ecology 

24 A new coal-fired plant would require a source of water for the plant’s cooling system, most likely 

25 a closed-cycle cooling tower system, and a discharge point for cooling tower blowdown. 

26 Locating the plant on the existing KPS site will enable some already-existing buildings and 

27 infrastructure to be used; however, impacts to aquatic ecology are likely during construction 

28 regardless of where the plant is located. Site disturbance will likely increase erosion and 

29 sedimentation runoff into Lake Michigan and nearby streams, increasing turbidity. While site 

30 procedures and management practices, as well as using already-existing structures on the KPS 

31 site when possible, may limit this effect, the impact will likely be noticeable. 

32 Surface mining of coal, which would occur offsite, is associated with degradation of aquatic 

33 communities due to acid mine drainage, sedimentation, and diversion or destruction of streams, 

34 lakes, and ponds. High sediment levels can kill fish directly, bury spawning beds, and alter 

35 water temperature and flow. Federal law requires mining operations to meet standards for 

36 protecting surface and groundwater from contamination, which would minimize sedimentation 

37 and other contaminants to the extent possible. Transportation of coal and limestone would likely 

38 occur via barge and would also contribute to erosion. Manitowoc, located 18 miles (29 km) 

39 south-southwest of the KPS site, and Green Bay, located 27 miles (44 km) west-northwest of 

40 the site, have coal docks, though no rail spur connects the site to either location. A new docking 

41 facility would likely need to be constructed, which would require dredging bottom sediments and 
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February 2010 8-21 Draft NUREG-1437, Supplement 40 

1 construction of breakwaters and docks. Dredging of bottom sediments will disrupt aquatic 

2 communities and, depending on the extent of dredging, could impair benthic communities by 

3 removing suitable substrate. 

4 Following construction, the greater thermal efficiency of the coal-fired alternative versus the 

5 existing KPS unit will result in slightly less consumptive water use for cooling and blowdown. 

6 During operations, disposal of waste materials will have to comply with local and State 

7 regulations, some of which are intended to prevent runoff into surface water. Management of 

8 runoff from coal piles will also be necessary. Spills occurring during onsite activities will need to 

9 be appropriately handled, and runoff from new, impervious surfaces (e.g., roads and rooftops) 

10 may affect aquatic ecology, as could deposition of acids or chemicals emitted through the 

11 plant’s stacks. Given current regulations, as well as the emission controls discussed in the Air 

12 Quality section, these impacts may be noticeable, but are not likely to be destabilizing. 

13 Overall impacts to aquatic ecology from a coal-fired alternative are expected to be MODERATE. 

14 As indicated in previous sections, constructing the coal-fired alternative will require 129 acres 

15 (52 ha) of land if located offsite, and will not require additional land if located on the current KPS 

16 site. Coal-mining operation will also affect terrestrial ecology in offsite coal mining areas, 

17 although some of the land is likely already disturbed by mining operations. Onsite and offsite 

18 land disturbances form the basis for impacts to terrestrial ecology. 

19 Impacts to terrestrial ecology will vary based on the degree to which the proposed plant site is 

20 already disturbed. On a previous industrial site, impacts to terrestrial ecology would be minor, 

21 unless substantial transmission line ROWs, railways, or roads would need to be constructed 

22 through less disturbed areas. These construction activities may have a cumulative effect of 

23 fragmenting or destroying habitats. Any onsite or offsite water disposal by landfilling will also 

24 affect terrestrial ecology at least through the time period when the disposal area is reclaimed. 

25 Some areas onsite, such as buffer areas, may remain undeveloped and could serve as habitat 

26 for terrestrial species, though site lighting, noise, and activities may degrade the value of these 

27 ecosystems. Deposition of acid rain or other emissions can also affect terrestrial ecology. Given 

28 the emission controls discussed in Section 8.2.1, air deposition impacts may be noticeable, but 

29 are not likely to be destabilizing. Impacts to terrestrial resources from a coal-fired alternative 

30 would be SMALL to MODERATE, and occur mostly during construction. Some of these impacts 

31 could be mitigated if the location of the coal-fired alternative is the current KPS site or on a 

32 previously disturbed location. 

33 8.2.5 Human Health 

34 Coal-fired power plants introduce worker risks from coal and limestone mining, from coal and 

35 limestone transportation, and from disposal of coal combustion and scrubber wastes. In 

36 addition, there are public risks from inhalation of stack emissions and the secondary effects of 

37 eating foods grown in areas subject to deposition from plant stacks. 

38 In Table 8-2 of the GEIS (NRC, 1996), the staff stated that human health impacts (cancer and 

39 emphysema) could result from inhalation of toxins and particulates, but it did not identify the 

40 significance of these impacts. Enforcement by the EPA and/or State agencies of regulations 

41 restricting harmful emissions from coal-fired plants has significantly reduced the potential health 
Environmental Impacts of Alternatives 

Draft NUREG-1437, Supplement 40 8-22 February 2010 

1 effects, but has not eliminated them. These agencies also impose site-specific emission limits, 

2 as needed, to protect human health. Even if the coal-fired alternative were located in a 

3 designated nonattainment area, the use of emission trading or offset mechanisms could prevent 

4 further regional degradation. However, localized effects could be visible. Many of the byproducts 

5 of coal combustion responsible for health effects are largely controlled, captured, or converted 

6 to a benign state in modern power plants, although some level of health effects may remain. 

7 Aside from emission impacts, the coal-fired alternative introduces the risk of coal pile fires and 

8 for those plants that use coal combustion liquid and sludge waste impoundments, the release of 

9 the waste due to a failure of the impoundment. However, the occurrence of these types of 

10 events is relatively rare. 

11 It is expected that the facility would operate in compliance with Federal and State safety and 

12 emission standards. 

13 Overall, the impacts on human health of the coal-fired alternative are likely to be SMALL. 

14 8.2.6 Socioeconomics 

15 Land Use

16 As discussed in 8.1.6, the analysis of land use impacts focuses on the amount of land area that 

17 would be affected by the construction and operation of a coal-fired power plant at the KPS site 

18 and an alternative site. Land-use impacts would vary depending on where the plant would be 

19 located and whether construction would take place on undeveloped land or within a previously 

20 disturbed industrial (brownfield) area. 

21 DEK indicated that 136 acres (55 ha) of land would be needed to support a coal-fired alternative 

22 capable of replacing the KPS. The GEIS estimates 1,700 acres (700 ha) would be needed to 

23 support a 1,000-MWe generating station (NRC, 1996). This amount of land use includes power 

24 plant structures and associated coal delivery and waste disposal infrastructure. By scaling GEIS 

25 estimates, a 590-MWe plant could require approximately 1,000 acres (405 ha) of land. 

26 However, if additional land would be necessary for a buffer around plant structures or to support 

27 transmission lines at an alternate site and rail and barge offloading facilities at KPS and an 

28 alternate site, the staff believes the DEK estimate to be low and additional land would be 

29 needed to support a rail yard and coal offloading facility. Even assuming additional land use for 

30 these purposes, total land required by the coal-fired alternative is unlikely to exceed 1,000 acres 

31 (405 ha) for all uses, excluding coal mining. The coal-fired alternative would require 

32 approximately 30 acres (12 ha) of land area for waste disposal. Land use impacts from 

33 construction would be MODERATE to LARGE, and could be reduced if the power plant is 

34 collocated at an alternate site with another generating station or on a previously industrial site 

35 like KPS. Impacts could be further mitigated at an alternate site by constructing new 

36 transmission lines in existing ROWs. 

37 Offsite land use impacts would occur from coal mining in addition to land use impacts from the 

38 construction and operation of the new power plant. The GEIS indicates that approximately 

39 22,000 acres (8,903 ha) of land could be affected by mining coal and waste disposal to support 

40 a 1,000-MWe coal plant during its operational life (NRC, 1996). Therefore, to replace KPS 
Environmental Impact of Alternatives 

February 2010 8-23 Draft NUREG-1437, Supplement 40 

1 approximately 12,980 acres (5,253 ha) of land could be affected by coal mining. However, most 

2 of the land in existing coal-mining areas has already experienced some level of disturbance. 

3 The elimination of the need for uranium mining to supply fuel for the KPS would partially offset 

4 this offsite land use impact. The GEIS estimates that approximately 1,000 acres (405 ha) of land 

5 would be affected by uranium mining and processing for a 1.000-MWe nuclear plant. For the 

6 KPS, roughly 590 acres (239 ha) of land used for uranium mining and processing would no 

7 longer be needed. 

8 Based on this information, land use impacts could range from MODERATE to LARGE, 

9 depending on local land use and the availability of land near the proposed site. Some portion of 

10 this impact could be mitigated by constructing the rail spur in existing ROWs. 

11 Socioeconomics

12 The GEIS projected a peak workforce of 1,200 to 2,500 workers for a 1,000-MWe plant, or a 

13 peak of 708 to 1,475 workers for a replacement for KPS. During construction, the communities 

14 surrounding the power plant site would experience increased demand for rental housing and 

15 public services, although these effects would be moderated if the alternate construction site is 

16 located near an urban area with many skilled workers. The relative economic effect of 

17 construction workers on local economy and tax base would vary over time. 

18 After construction, local communities may be temporarily affected by the loss of construction 

19 jobs and associated loss in demand for business services, and the rental housing market could 

20 experience increased vacancies and decreased prices. As noted in the GEIS, the 

21 socioeconomic impacts at a rural construction site could be larger than at an urban site, 

22 because the workforce would need to relocate closer to the construction site. The impact of 

23 construction on socioeconomic conditions could range from MODERATE to LARGE depending 

24 on whether the new power plant would be located at KPS or an alternate site. The 

25 socioeconomic impacts of power plant construction could be further reduced if the power plant 

26 is located near an urban area with many skilled workers. 

27 DEK estimated an operational workforce of 79 (DEK, 2008), while scaling estimates from the 

28 GEIS indicate the need for 148 workers (250 operations workers for a 1,000-MWe plant). The 

29 DEK estimate appears low, but is consistent with trends calling for decreased workforces at 

30 power facilities. Even at rural sites, impacts are unlikely to be large. The small number of 

31 operations workers would not likely have a noticeable effect on socioeconomic conditions in the 

32 region. Depending on location, operations impacts would likely be SMALL to MODERATE. 

33 Transportation

34 During construction, approximately 1,500 workers would be commuting to the site. In addition to 

35 commuting workers, trucks would transport construction materials and equipment to the 

36 worksite increasing the amount of traffic on local roads. The increase in vehicular traffic would 

37 peak during shift changes resulting in temporary levels of service impacts and delays at 

38 intersections. Trains and/or barges could also be used to deliver large components to the KPS 

39 site or an alternate site. Transportation impacts are likely to be MODERATE to LARGE during 

40 construction. 
Environmental Impacts of Alternatives 

Draft NUREG-1437, Supplement 40 8-24 February 2010 

1 During operations, approximately 150 workers would be commuting to the coal-fired power 

2 plant. Frequent deliveries of coal and limestone by rail and barge could add to the overall 

3 transportation impact. Onsite coal storage would make it possible to receive several trains per 

4 day. Limestone could also likely be delivered by rail and barge, which could add additional traffic 

5 (though considerably less traffic than that generated by coal deliveries). 

6 The coal-fired alternative would likely create SMALL to MODERATE transportation impacts 

7 during plant operations depending on whether coal and limestone is delivered by rail and barge. 

8 Transportation impacts at an alternate site would depend on road capacity and average daily 

9 volume. 

10 Aesthetics

11 The coal-fired alternative’s boiler building would be up to 200 feet (61 m) tall and may be visible 

12 offsite in daylight hours at KPS and depending on the topography at an alternate site. The 

13 exhaust stack would be up to 500 feet (183 m) high. If the coal-fired alternative makes use of 

14 natural-draft cooling towers, then additional impacts would occur from the towers, which may be 

15 several hundred feet tall and topped with condensate plumes. Mechanical draft towers would 

16 also generate condensate plumes but would be markedly shorter than natural-draft towers. 

17 Other buildings onsite may also affect aesthetics. Noise and light from plant operations, as well 

18 as lighting on plant structures, may be detectable offsite. 

19 In addition to new power plant structures, the alternate plant site may require the construction of 

20 transmission lines. The transmission lines would have a lasting visual effect on the landscape. 

21 In general, aesthetic changes would be limited to the immediate vicinity of the KPS or an 

22 alternate site. Impacts would likely to be SMALL to MODERATE at KPS and an alternate site 

23 and would depend on the amount of new transmission line required. 

24 Historic and Archaeological Resources

25 Cultural resources are the indications of human occupation and use of the landscape as defined 

26 and protected by a series of Federal laws, regulations, and guidelines. Prehistoric resources are 

27 physical remains of human activities that predate written records; they generally consist of 

28 artifacts that may alone or collectively yield information about the past. Historic resources 

29 consist of physical remains that postdate the emergence of written records; in the United States, 

30 they are architectural structures or districts, archaeological objects, and archaeological features 

31 dating after 1492. Ordinarily, sites less than 50 years old are not considered historic, but 

32 exceptions can be made for such properties if they are of particular importance, such as 

33 structures associated with the development of nuclear power (e.g., Shippingport Atomic power 

34 Station) or Cold War themes. American Indian resources are sites, areas, and materials 

35 important to American Indians for religious or heritage reasons. Such resources may include 

36 geographic features, plants, animals, cemeteries, battlefields, trails, and environmental features. 

37 The cultural resource analysis encompassed the power plant site and adjacent areas that could 

38 potentially be disturbed by the construction and operation of alternative power plants. 

39 The potential for historic and archaeological resources can vary greatly depending on the 

40 location of the proposed site. To consider a project's effects on historic and archaeological 

41 resources, any proposed areas will need to be surveyed to identify and record historic and 
Environmental Impact of Alternatives 

February 2010 8-25 Draft NUREG-1437, Supplement 40 

1 archaeological resources, identify cultural resources (e.g., traditional cultural properties), and 

2 develop possible mitigation measures to address any adverse effects from ground disturbing 

3 activities. Studies will be needed for all areas of potential disturbance at the proposed plant site 

4 and along associated corridors where new construction will occur (e.g., roads, transmission 

5 corridors, rail lines, or other ROWs). In most cases, project proponents should avoid areas with 

6 the greatest sensitivity. 

7 The impact for a coal-fired alternative at the KPS site would be SMALL. As noted in Section 

8 4.9.6, DEK conducted a survey of the KPS site in 2007 and is developing a Cultural Resources 

9 Management Plan. This plan includes pre-job briefings for workers and an inadvertent discovery 

10 (stop work) provision. Depending on the resource richness of an alternative site ultimately 

11 chosen for the coal-fired alternative, impacts could range from SMALL to MODERATE. 

12 Environmental Justice

13 The environmental justice impact analysis evaluates the potential for disproportionately high and 

14 adverse human health and environmental effects on minority and low-income populations that 

15 could result from the construction and operation of a new coal-fired power plant. Adverse health 

16 effects are measured in terms of the risk and rate of fatal or nonfatal adverse impacts on human 

17 health. Disproportionately high and adverse human health effects occur when the risk or rate of 

18 exposure to an environmental hazard for a minority or low-income population is significant and 

19 exceeds the risk or exposure rate for the general population or for another appropriate 

20 comparison group. The minority and low-income populations are subsets of the general public 

21 residing around the site, and all are exposed to the same hazards generated from various 

22 power plant operations. 

23 Minority and low-income populations could be affected by the construction and operation of a 

24 new coal-fired power plant. Some of these effects have been identified in resource areas 

25 discussed in this section. The extent of disproportionate effect is difficult to determine since it 

26 would depend on the location of the coal-fired power plant. For example, increased demand for 

27 rental housing during construction could disproportionately affect low-income populations. 

28 However, demand for rental housing could be mitigated if the alternate plant site is constructed 

29 near a metropolitan area. Impacts on minority and low-income populations from the construction 

30 and operation of a coal-fired power plant alternative could range from SMALL to MODERATE. 

31 8.2.7 Waste Management 

32 The coal-fired, supercritical power plant would be constructed either onsite or offsite. Waste 

33 would be generated during construction of this alternative. During operation of this alternative, 

34 ash (a dry solid) and sludge (a semi-solid by-product of emission control system operation) 

35 waste streams would be generated. The staff estimates that 618-MW power plant would 

36 generate annually total 60,823.94 tons (55,178.55 MT) of dry solid ash and scrubber sludge. 

37 Disposal of the waste from the 40-year operation of this alternative would require approximately 

38 136 acres (55 ha). Disposal of the waste could noticeably affect land use and groundwater 

39 quality, but with proper siting and implementation of monitoring and management practices, it 

40 would not destabilize resources. After closure of the waste site and revegatation, the land could 

41 be available for other uses. 
Environmental Impacts of Alternatives 

Draft NUREG-1437, Supplement 40 8-26 February 2010 

1 The impacts from waste generated during operation of this coal-fired alternative would be 

2 MODERATE; the impacts would be clearly visible, but would not destabilize any important 

3 resource. 

4 The impacts from waste generated during the construction stage would be short-term. The 

5 amount of construction waste is small compared to the amount of waste generated during 

6 operational stage and could be recycled. Overall, the impacts from waste generated during the 

7 construction stage would be SMALL. 

8 Therefore, the NRC staff concludes that impacts from construction and operation of this 

9 alternative would be MODERATE. 

10 8.3 COMBINATION ALTERNATIVES 

11 In this section, the staff evaluates the environmental impacts that may occur from a combination 

12 of alternatives, some of which may not be capable of individually replacing the power from KPS, 

13 but which may have relatively low environmental impacts or rely on renewable fuel sources. In 

14 this section, staff will evaluate two combination alternatives that include onsite gas-fired 

15 generation, energy conservation, and either wind power (in option 1) or wood-fired power (in 

16 option 2). 

17 Combination Option 1: 

18 ● 280 MW gas-fired capacity on the KPS site 

19 ● 229 MW equivalent conservation 

20 ● 47 MW wind power (157 MW of wind turbines at several sites; 30 percent capacity 

21 factor) 

22 Combination Option 2: 

23 ● 280 MW gas-fired capacity on the KPS site 

24 ● 229 MW equivalent conservation 

25 ● 47 MW wood-fired plant 

26 Wisconsin has substantial conservation resources, but a recent study commissioned by the 

27 Wisconsin Public Service Commission (Energy Center of Wisconsin, 2009) indicates that it will 

28 take several years to ramp programs to offset the power generated by KPS. By the start of 2014 

29 (KPS license expires on December 21, 2013), Wisconsin could offset 4.8 percent of peak load 

30 and 4.8 percent of total energy consumption. These estimates explicitly do not include the 

31 potential for behavior-based programs to reduce consumption. Assuming that 50 percent of this 

32 potential could offset a base load duty cycle, roughly 229 MW (on a total energy consumption 

33 basis) or 360 MW (on a peak load basis) could be achieved by the time the KPS license 

34 expires. Using the lower number, 229 MW, to be conservative, conservation/energy efficiency 

35 could offset roughly 41 percent of KPS output. Most of the remaining output for both alternatives 

36 would come from a 280 MW gas-fired combined cycle power plant at the current plant site (half 

37 of the pure gas-fired alternative). 
Environmental Impact of Alternatives 

February 2010 8-27 Draft NUREG-1437, Supplement 40 

1 Some wind turbines could be located onsite or across nearby agricultural areas with little long2 term land use impact. As noted in 8.5.1, this area is also home to Wisconsin’s best wind 

3 potential and existing transmission lines. The other option relies on offsite wood-fired power that 

4 would likely be located in the northern part of the State near steady wood supply streams. 

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

6 to Continued Kewaunee Power Station Operation 

Combination Alternative 

Option 1 – Gas, 

Conservation, Wind 

Option 2 – Gas, 

Conservation, Wood 

Continued KPS Operation 

Air Quality MODERATE MODERATE SMALL 

Groundwater SMALL SMALL SMALL 

Surface Water SMALL SMALL SMALL 

Ecology SMALL to LARGE SMALL to LARGE SMALL 

Human Health SMALL to MODERATE SMALL to MODERATE SMALL 

Socioeconomics SMALL to MODERATE SMALL to MODERATE SMALL TO MODERATE 

Waste Management SMALL SMALL SMALL 

7 8.3.1 Air Quality 

8 Kewaunee County, Wisconsin, where KPS is located, belongs to EPA Region 5 and is in 

9 attainment for all criteria pollutants, except ozone. Kewaunee County is a maintenance area for 

10 8-hour ozone (EPA, 2009a). 

11 This alternative is a combination of a 280-MW gas-fired combined cycle power plant, 

12 constructed onsite, and two options: option 1 relies on wind power for the remainder of the 

13 electrical energy produced; option 2 relies on offsite wood-fired power. 

14 A new gas-fired generating plant, proposed to be built in Kewaunee County, would qualify as a 

15 new major-emitting industrial facility and require a new source review (NSR) and Prevention of 

16 Significant Deterioration of Air Quality review under the CAA, enforced by WDNR, along with 

17 other air pollution control requirements in the Wisconsin Administrative Code and its statutes 

18 (EPA, 2008a; Wis. Adm. Code chapters NR400-499). The EPA delegated the authority of 

19 regulating the issuance of construction and operating permits to the WDNR, which was codified 

20 in NR406 and NR407 of the Wisconsin Administrative Code. The natural gas-fired plant would 

21 also need to comply with the standards of performance for electric utility steam generating units 

22 set forth in 40 CFR Part 60 Subpart Da. 

23 Section 169A of the CAA (42 USC 7401) establishes a national goal of preventing future and 

24 remedying existing impairment of visibility in mandatory Class I Federal areas when impairment 

25 results from man-made air pollution. The EPA issued a new regional haze rule in 1999 (64 FR 
Environmental Impacts of Alternatives 

Draft NUREG-1437, Supplement 40 8-28 February 2010 

1 35714; EPA, 1999). The rule specifies that for each mandatory Class I Federal area located 

2 within a State, the State must establish goals that provide for reasonable progress toward 

3 achieving natural visibility conditions through developing and implementing air quality protection 

4 plans to reduce the pollution that causes visibility impairment. As noted in 8.1.1 and 8.2.1, there 

5 are five RPOs collaborating on the visibility impairment issue and developing the technical basis 

6 for these plans. The Midwest RPO, along with tribes, Federal agencies and other interested 

7 parties identifies regional haze and visibility issues and develops strategies to address them. 

8 The visibility protection regulatory requirements, contained in 40 CFR Part 51, Subpart P, 

9 include the review of the new sources that would be constructed in the attainment or 

10 unclassified areas and may affect visibility in any Federal Class I area (40 CFR 51.307). If a 

11 coal-fired plant were located close to a mandatory Class I area, additional air pollution control 

12 requirements would be imposed. There are no Mandatory Class I Federal areas in the State of 

13 Wisconsin or in the close proximity to KPS. The closest Mandatory Class I Federal Areas to 

14 KPS are Seney Wilderness Area, Michigan, located 149 miles northeast from KPS, and Isle 

15 Royale National Park, Michigan, located 255 miles northwest from KPS. 

16 The emissions from the natural gas-fired alternative at KPS site, based on published Energy 

17 Information Administration (EIA) data, EPA emission factors and on performance characteristics 

18 for this alternative and implemented emission controls, would likely be: 

19 ● Nitrogen oxides (NOx) – 70.50 tons (63.96 MT) per year 

20 ● Carbon monoxide (CO) – 14.66 tons (13.30 MT) per year 

21 ● Total suspended particles (TSP) – 12.29 tons (11.15 MT) per year 

22 ● Particulate matter (PM) PM10 – 12.29 tons (11.15 MT) per year 

23 ● Carbon dioxide (CO2) – 756,582.11 tons (686,359.75 MT) per year 

24 The new natural gas-fired plant would have to comply with Title IV of the CAA reduction 

25 requirements for SO2 and NOx, which are main precursors of acid rain and major causes of 

26 reduced visibility. Title IV establishes maximum SO2 and NOx emission rates for existing plants 

27 and a system of SO2 emission allowances that can be used, sold or saved for future use by new 

28 plants. 

29 On March 10, 2005, the EPA issued the Clean Air Interstate Rule (CAIR), which would create 

30 large permanent reductions in SO2 and NOx across 28 eastern states and the District of 

31 Columbia. However, petitions for review of the CAIR and CAIR Federal Implementation Plans 

32 (FIPs), including the provisions establishing the CAIR NOx annual and ozone season and SO2

33 trading programs, were filed in the U.S. Court of Appeals for the D.C. Circuit. On July 11, 2008, 

34 the Court issued an opinion vacating and remanding the CAIR and CAIR FIPs. After requested 

35 rehearing of the Court's decision, the Court granted rehearing only to the extent that it 

36 remanded the rules to the EPA without vacating them on December 23, 2008. This ruling leaves 

37 CAIR and the CAIR FIPs, including the CAIR trading programs, in place until the EPA issues a 

38 new rule to replace CAIR in accordance with the July 11, 2008 decision. Wisconsin is among 

39 the States covered by this rule (EPA, 2009b). WDNR adopted the rule and is allocating annual 

40 NOx allowances for new electricity generating units subject to CAIR as specified in chapter NR 

41 432 of the Wisconsin Administrative Code starting in 2009. The NOx allowances are allocated 

42 from a “new unit set-aside” reserved pool of allowances, which represents 7 percent of 

43 Wisconsin's total budget of NOx allowances. 
Environmental Impact of Alternatives 

February 2010 8-29 Draft NUREG-1437, Supplement 40 

1 As stated above, the new natural gas-fired alternative would produce 21.99 tons (19.95 MT) per 

2 year of SOx and 70.50 tons (63.96 MT) per year of NOx based on the use of the dry low NOx 

3 combustion technology and use of the selective catalytic reduction (SCR) in order to 

4 significantly reduce NOx emissions. 

5 The new plant would be subjected to the continuous monitoring requirements of SO2, NOx and 

6 CO2 specified in 40 CFR Part 75. The natural gas-fired plant would emit approximately 

7 756,582.11 tons (686,359.75 MT) per year of unregulated CO2 emissions. As of today, there is 

8 no required reporting of GHG emissions. In response to the Consolidated Appropriations Act of 

9 2008, the EPA proposed a rule that would require mandatory reporting of GHG emissions from 

10 large sources, such as the presented alternative. The rule would allow for the collection of 

11 accurate and comprehensive emissions data to inform future policy decisions. The EPA 

12 proposes that suppliers of fossil fuels or industrial GHGs, manufacturers of vehicles and 

13 engines, and facilities that emit 25,000 metric tons or more per year of GHG emissions submit 

14 annual reports to the EPA. The gases covered by the proposed rule are CO2, CH4, N2O, HFC, 

15 PFC, SF6, and other fluorinated gases including NF3 and HFE. 

16 The natural gas-fired portion of this alternative would emit 12.29 tons (11.15 MT) of particulate 

17 matter per year having an aerodynamic diameter less than or equal to 10 μm (PM10) (40 CFR 

18 50.6(a)), based on the assumption that effective fabric filters or electrostatic precipitators would 

19 be used to minimize emissions. 

20 In December 2000, the EPA issued regulatory findings (EPA, 2000a) on emissions of hazardous 

21 air pollutants from electric utility steam-generating units, which indicated that natural gas-fired 

22 plants emit hazardous air pollutants such as arsenic, formaldehyde and nickel and stated that: 

23 “. . . the impacts due to HAP emissions from natural gas-fired electric utility steam generating 

24 units were negligible based on the results of the study. The Administrator finds that regulation of 

25 HAP emissions from natural gas-fired electric utility steam generating units is not appropriate or 

26 necessary.” 

27 The new natural gas-fired alternative would produce 12.29 tons (11.15 MT) per year of the TSP 

28 as PM10 emissions. 

29 There would be no emissions from the wind-powered portion of option 1 for this alternative. 

30 When fossil fuels are burned in the production of electricity, a variety of gases and particulates 

31 are formed and, if not captured by pollution control equipment, will be released into the 

32 atmosphere. The pollutants released during electricity production depend upon complex 

33 relationships between factors such as fuel type and mix (sulfur content of coal, gas utilization), 

34 operational mode (combustion temperatures), technologies employed (combustion processes, 

35 environmental equipment), and regulatory constraints (non-attainment and maintenance areas). 

36 The emissions from the wood-fired component of option 2, based on published EIA data, EPA 

37 emission factors, performance characteristics for this alternative, and implemented emission 

38 controls, would likely be: 

39 ● Sulfur oxides (SOx) – 58.33 tons (52.92 MT) per year 
Environmental Impacts of Alternatives 

Draft NUREG-1437, Supplement 40 8-30 February 2010 

1 ● Nitrogen oxides (NOx) (with SCR) – 285.80 tons (259.27 MT) per year 

2 ● Carbon monoxide (CO) – 349.96 tons (317.48 MT) per year 

3 ● TSP (filtered) – 233.31 tons (211.66 MT) per year 

4 ● PM10 (filtered) – 172.65 tons (156.63MT) per year 

5 ● PM2.5 (filtered) – 151.65 tons (137.58 MT) per year 

6 ● Carbon dioxide (CO2) – 454,950.60 tons (412,724.24 MT) per year 

7 The wood-fired combustion facility would be subject to the Federal and State air emissions 

8 regulations described above for the natural gas-fired component of this alternative. Option 2 

9 would also produce 172.65 tons (156.63 MT) per year of particulate matter having an 

10 aerodynamic diameter less than or equal to 10 μm (PM10) (40 CFR 50.6(a)) and 151.65 tons 

11 (137.58 MT) per year of the particulate matter less than 2.5 μm in diameter (PM2.5) which have 

12 to meet the national primary and secondary ambient air quality standards (40 CFR 50.7a). 

13 Activities associated with the construction of the new natural gas-fired plant onsite or offsite 

14 KPS would cause some additional air effects as a result of equipment emissions and fugitive 

15 dust from operation of the earth-moving and material handling equipment. Vehicles of workers 

16 and construction motorized equipment exhaust emissions would be temporary. The construction 

17 crews would employ dust-control practices in order to control and reduce fugitive dust, which 

18 would be temporary in nature. The staff concludes that the impact of vehicle exhaust emissions 

19 and fugitive dust from operation of the earth-moving and material handling equipment would be 

20 SMALL. 

21 The overall air-quality impacts of the combination alternative consisting of a natural gas-fired 

22 plant located at the KPS site and wind power (option 1), or of a natural gas-fired plant located at 

23 the KPS site and wood-fired power (option 2) would be MODERATE. 

24 8.3.2 Groundwater Use and Quality 

25 Impacts to groundwater use and quality from the gas-fired portion of the combination alternative 

26 would be similar to those identified for the wholly gas-fired alternative in 8.1.2, though roughly 

27 half as large in magnitude. These impacts would be SMALL. 

28 An onsite or offsite wind alternative would likely use much less groundwater than KPS uses for 

its operations. The current average withdrawal rate at KPS is less than 100 gpm (0.01 m3 29 /s), 

30 and pumping tests indicate this rate will not cause an effect on nearby supply wells. A reduction 

31 in this withdrawal rate means that impacts of the combination alternative would remain SMALL. 

32 An offsite wood-fired alternative would likely rely on a minimal amount of groundwater for its 

33 operations because not many workers would be onsite and because the wood-fired unit would 

34 be relatively small and would have few auxiliary systems requiring service water. This 

35 combination alternative would use less groundwater than KPS. A reduction in the current KPS 

36 withdrawal rate means that impacts of the combination alternative would remain SMALL. 
Environmental Impact of Alternatives 

February 2010 8-31 Draft NUREG-1437, Supplement 40 

1 8.3.3 Surface Water Use and Quality 

2 Impacts to surface water use and quality from the gas-fired portion of the combination 

3 alternative would be similar to those identified for the wholly gas-fired alternative in 8.1.2, 

4 though roughly half as large in magnitude. These impacts would be SMALL. 

5 An onsite or offsite wind alternative would consume significantly less surface water than the 

6 amount consumed by KPS for cooling purposes. The maximum consumptive use would be 

7 reduced to a fraction of the surface water withdrawn by the open-cycle cooling system currently 

8 in use by KPS. A reduction in this withdrawal rate means that impacts of the combination 

9 alternative would be SMALL. 

10 An offsite wood-fired alternative would likely consume only a small amount of surface water as 

11 compared to the amount consumed by KPS for cooling purposes because the wood-fired unit is 

12 relatively small and would have few auxiliary systems requiring service water. This combination 

13 alternative would use less surface water than KPS. Assuming that the offsite location utilizes 

14 water from a large enough body of water to support its operations, the impacts of the 

15 combination alternative would be SMALL. 

16 8.3.4 Aquatic and Terrestrial Ecology 

17 The conservation portion of the combination alternative will have positive impacts on aquatic 

18 communities because less power would need to be generated. Requiring less power will 

19 decrease the cooling water requirements and pollutant deposition of the gas-fired alternative. 

20 The gas-fired portion of the combination alternative would have similar effects to those 

21 discussed in Section 8.2.4 Terrestrial and Aquatic Ecology; however, because the gas-fired 

22 portion of this alternative would only produce 280 MW, rather than 560 MW for the gas-fired 

23 alternative, the imprint of the plant may be smaller, and therefore, erosion and sedimentation 

24 during construction, and pollutant deposition during operation are expected to be less. Impacts 

25 from wind-powered and wood-fired portions of this alternative would vary depending on the 

26 location and ecology of the site, but would likely be minimal. Construction in a previously 

27 disturbed area would have lower impacts to aquatic communities than construction in an 

28 undisturbed area. Impacts during operation are expected to be minimal as neither option 

29 requires a source of cooling water. Some deposition of carbon compounds and particulate 

30 matter would occur on nearby waterways as a result of burning wood waste. 

31 Overall impacts to aquatic ecology from a combination alternative are expected to be SMALL. 

32 The largest potential impact to terrestrial resources would occur from the wind turbines. Wind 

33 turbines have the potential to require large amounts of undisturbed land. There would be a 

34 potential to mitigate some of these impacts by locating the turbines offshore on Lake Michigan. 

35 ROW maintenance would continue, although no additional transmission lines would be 

36 necessary. The only construction activities that would occur for the combination alternative are 

37 the construction of a combined-cycle gas-fired power plant and any retrofit-related construction. 

38 These activities would be confined to previously disturbed areas at the KPS site. Some habitat 

39 fragmentation impacts on the KPS site may occur. Impacts to terrestrial ecology would be 

40 SMALL to LARGE. 
Environmental Impacts of Alternatives 

Draft NUREG-1437, Supplement 40 8-32 February 2010 

1 8.3.5 Human Health 

2 The human health risks from a combination of alternatives include the combined cycle gas-fired 

3 plant already discussed in 8.1.5. The GEIS (NRC, 1996) notes that the environmental impacts 

4 of the conservation/demand-side management alternative are likely to be centered on indoor air 

5 quality. This is due to increased weatherization of the home in the form of extra insulation and 

6 reduced air turnover rates from the reduction in air leaks. However, the actual impact from the 

7 conservation alternative is highly site specific and not yet well-established. For wind power, the 

8 GEIS notes that, except for a potentially small number of occupational injuries associated with 

9 the construction and routine maintenance of the units, human health would not be affected by 

10 routine operations. The occupational human health impacts for the operation of a wood-fired 

11 facility would be comparable to that of agriculture, which is high. This is primarily due to the 

12 routine movement and handling of large amounts of wood waste that would be needed to fuel 

13 the plant. The use of protective equipment and adherence to safety requirements would 

14 minimize the danger to workers. The burning of the wood would generate air emissions that can 

15 impact human health. The most significant would involve the release of particulate matter. 

16 However, these emissions can be controlled effectively with existing technology. It is expected 

17 that the facilities would operate in compliance with Federal and State safety and emission 

18 standards. 

19 The human health risks from the combination of alternatives are uncertain, but considered to be 

20 SMALL to MODERATE. 

21 8.3.6 Socioeconomics 

22 Land Use

23 The GEIS generically evaluates the impacts of nuclear power plant operations on land use both 

24 on and off each power plant site. The analysis of land use impacts for the combination 

25 alternative focuses on the amount of land area that would be affected by the construction and 

26 operation of a single natural gas-fired unit power plant at the KPS, an offsite wind energy 

27 generating power, and demand-side energy conservation. 

28 Approximately 285 acres (115 ha) would be needed to support a single natural gas-fired unit 

29 combination alternative including the gas pipeline, according to staff scaling of DEK estimates. 

30 By scaling the GEIS estimate, a 292-MWe (gross capacity) plant could require up to 

31 approximately 304 acres (123 ha) of land including pipeline. The NRC staff believes that the 

32 DEK estimate is reasonable. Nevertheless, land use impacts from construction of the natural 

33 gas-fired power plant at KPS would be SMALL. 

34 In addition to onsite land requirements, land would be required off site for natural gas wells and 

35 collection stations. The GEIS estimates that 3,600 acres (1,457 ha) would be required for wells, 

36 collection stations, and pipelines to bring the gas to a 1,000-MWe generating facility. If this land 

37 requirement were scaled with a 292-MWe generating capacity, the natural gas-fired power plant 

38 at the KPS could require 1,051 acres (425 ha). Most of this land requirement would occur on 

39 land where gas extraction already occurs. In addition, some natural gas could come from 

40 outside of the United States and be delivered as liquefied gas. 
Environmental Impact of Alternatives 

February 2010 8-33 Draft NUREG-1437, Supplement 40 

1 The wind farm option of the combination alternative producing 47 MWe of electricity would 

2 require approximately 10,000 acres (4,050 ha) spread over several locations with approximately 

3 40 acres (16 ha) in actual use. The wood-fired option of the combination alternative producing 

4 47 MWe of electricity would require approximately 90 acres (36 ha). 

5 Since existing transmission lines would be used, land use impacts from the energy conservation 

6 alternative would be SMALL. Quickly replacing and disposing of old inefficient appliances could 

7 generate waste material and potentially increase the size of landfills. Given the time for program 

8 development and implementation, the replacement process would need to begin as soon as 

9 possible. Some older appliances would simply be replaced by more efficient appliances as they 

10 fail (especially in the case of frequently replaced items, like light bulbs). In addition, many items 

11 (like home appliances or industrial equipment) have substantial recycling value and would likely 

12 not be disposed of in landfills. 

13 The elimination of uranium fuel for KPS could partially offset offsite land requirements. In the 

14 GEIS, the staff estimated that approximately 1,000 acres (405 ha) would not be needed for 

15 mining and processing uranium during the operating life of a 1,000-MWe nuclear power plant. 

16 For the KPS, roughly 590 acres (239 ha) of uranium mining area would no longer be needed. 

17 Overall land use impacts from the combination alternative would be SMALL to MODERATE. 

18 Socioeconomics

19 As previously discussed, socioeconomic impacts are defined in terms of changes to the 

20 demographic and economic characteristics and social conditions of a region. For example, the 

21 number of jobs created by the construction and operation of a new single natural gas-fired 

22 power plant at the KPS site and wind farm or wood-fired power generating plant could affect 

23 regional employment, income, and expenditures. Two types of job creation would occur: (1) 

24 construction-related jobs, which are transient, short in duration, and less likely to have a long25 term socioeconomic impact; and (2) operation-related jobs in support of power generating 

26 operations, which have the greater potential for permanent, long-term socioeconomic impacts. 

27 Construction and operations workforce requirements for the combination alternative were 

28 determined in order to measure their possible effect on current socioeconomic conditions. 

29 Based on GEIS projections and a workforce of 1,200 for a 1,000-MWe plant, a single 292-MWe 

30 unit at KPS would require a peak estimated construction workforce of 350 workers. Additional 

31 estimated construction workforce requirements for this combination alternative would include 

32 300 construction workers for the wind farm option and 131 construction workers for the wood33 fired option. The number of additional workers would cause a short-term increase in the demand 

34 for services and temporary (rental) housing in the region around the construction site. 

35 After construction and depending on the size of the community, some local communities may be 

36 temporarily affected by the loss of the construction jobs and associated loss in demand for 

37 business services. The rental housing market could also experience increased vacancies and 

38 decreased prices. The impact of construction on socioeconomic conditions for each of the three 

39 power generating facilities would be SMALL. 

40 Following construction, a single unit gas-fired power plant at the KPS could provide up to 10 

41 jobs, based on scaled DEK estimates, or up to 44 jobs based on GEIS estimates. Additional 
Environmental Impacts of Alternatives 

Draft NUREG-1437, Supplement 40 8-34 February 2010 

1 estimated operations workforce requirements for this combination alternative would include 50 

2 operations workers for the wind farm option and 13 operations workers for the wood-fired 

3 option. Given the small numbers of operations workers at these facilities, socioeconomic 

4 impacts associated with the operation of the natural gas-fired power plant at the KPS, wind 

5 farm, and wood-fired power generating plant would be SMALL. 

6 Socioeconomic effects of an energy efficiency program would be SMALL. As noted in the GEIS, 

7 the program would likely employ additional workers. Lower-income families, in particular, could 

8 benefit from weatherization and insulation programs because low-income households 

9 experience home energy burdens four times greater than the average household (OMB, 2007). 

10 Transportation

11 Transportation impacts would be SMALL, because the number of employees commuting to the 

12 KPS, wind farm, and wood-fired power generating plant would be small. Any transportation 

13 effects from the energy efficiency alternative would be widely distributed across the State and 

14 would not be noticeable. 

15 Construction and operation of a natural gas-fired power plant, wind farm, and wood-fired power 

16 generating plant would increase the number of vehicles on roads in the vicinity of these 

17 facilities. During construction, cars and trucks would deliver workers, materials, and equipment 

18 to the worksite. The increase in vehicular traffic would peak during shift changes resulting in 

19 temporary levels of service impacts and delays at intersections. Pipeline construction and 

20 modification to existing natural gas pipeline systems could also have an impact. 

21 During plant operations, transportation impacts would almost disappear. Given the small 

22 number of workers at these facilities, impacts on local roads from the operation of the natural 

23 gas-fired power plant at the KPS, the wind farm, and wood-fired power generating plant would 

24 be SMALL. Transportation impacts at the wind farm and wood-fired power generating plant 

25 would also depend on current road capacities and average daily traffic volumes. 

26 Aesthetics

27 As previously discussed, aesthetic resources are the natural and manmade features that give a 

28 particular landscape its character and aesthetic quality. The aesthetics impact analysis focuses 

29 on the degree of contrast between the power plant and the surrounding landscape and the 

30 visibility of the power plant. 

31 A single natural gas-fired unit located at the KPS could be approximately 100 feet (30 m) tall, 

32 with an exhaust stack up to 175 feet (53 m) tall. The impact would be moderated by higher 

33 elevations and vegetation. Power plant infrastructure would generally be smaller and less 

34 noticeable than the KPS containment and turbine buildings. Mechanical draft cooling towers 

35 would generate condensate plumes and operational noise. Noise during power plant operations 

36 would be limited to industrial processes and communications. In addition to the power plant 

37 structures, construction of natural gas pipelines would have a short-term impact. Noise from the 

38 pipelines could be audible offsite near compressors. 

39 In general, aesthetic changes would be limited to the immediate vicinity of the KPS and the wind 

40 farm facilities. The wind farm would have the greatest aesthetic effect. Compared to a fossil-
Environmental Impact of Alternatives 

February 2010 8-35 Draft NUREG-1437, Supplement 40 

1 fueled power plant unit on 46 to 1,400 acres, the 32,000-acre (13,000 ha) wind farm (with wind 

2 turbines over 300 feet (100 m) tall) would dominate the view and would be the major focus of 

3 viewer attention. Therefore, overall aesthetic impacts from the construction and operation of 

4 combination alternative would be SMALL to MODERATE. 

5 In addition to seeing new power plant structures at KPS, the wind farm and wood-fired power 

6 generating plant may require the construction of transmission lines. The transmission lines 

7 would have a lasting visual effect on the landscape. 

8 Impacts from energy efficiency programs would be SMALL. American Transmission Corporation 

9 (ATC) would continue to use the existing transmission lines. Some noise impacts could occur in 

10 instances of energy efficiency upgrades to major building systems, though this impact would be 

11 intermittent and short-lived. 

12 In general, aesthetic changes would be limited to the immediate vicinity of the KPS, the wind 

13 farm, and wood-fired power generating plant. Impacts would likely be SMALL to MODERATE at 

14 KPS and other sites and would depend on the amount of new transmission line required. 

15 Historic and Archaeological Resources

16 Cultural resources are the indications of human occupation and use of the landscape as defined 

17 and protected by a series of Federal laws, regulations, and guidelines. Prehistoric resources are 

18 physical remains of human activities that predate written records; they generally consist of 

19 artifacts that may alone or collectively yield information about the past. Historic resources 

20 consist of physical remains that postdate the emergence of written records; in the United States, 

21 they are architectural structures or districts, archaeological objects, and archaeological features 

22 dating after 1492. Ordinarily, sites less than 50 years old are not considered historic, but 

23 exceptions can be made for such properties if they are of particular importance, such as 

24 structures associated with the development of nuclear power (e.g., Shippingport Atomic power 

25 Station) or Cold War themes. American Indian resources are sites, areas, and materials 

26 important to American Indians for religious or heritage reasons. Such resources may include 

27 geographic features, plants, animals, cemeteries, battlefields, trails, and environmental features. 

28 The cultural resource analysis encompassed the power plant site and adjacent areas that could 

29 potentially be disturbed by the construction and operation of alternative power plants. 

30 The analysis of land use impacts for the combination alternative focuses on the amount of land 

31 that would be affected by the construction and operation of a single natural gas-fired unit power 

32 plant at KPS, an offsite wind energy generating plant, a wood-fired facility, and demand-side 

33 energy conservation. The impact of constructing and operating a combination alternative at the 

34 KPS site would be SMALL, due to previous onsite survey work and Dominion’s commitment to 

35 develop a Cultural Resources Management Plan. As discussed in Section 8.2.6, depending on 

36 the resource richness of an alternative site ultimately chosen for the wind power alternative, 

37 impacts will range from SMALL to MODERATE. 

38 Impacts to historic and archaeological resources from implementing the energy efficiency 

39 programs would be SMALL. A conservation alternative would not affect land use or historical or 

40 cultural resources onsite or elsewhere in the State. 
Environmental Impacts of Alternatives 

Draft NUREG-1437, Supplement 40 8-36 February 2010 

1 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 natural gas-fired power plant, wind 

5 farm, and wood-fired power generating plant. Adverse health effects are measured in terms of 

6 the risk and rate of fatal or nonfatal adverse impacts on human health. Disproportionately high 

7 and adverse human health effects occur when the risk or rate of exposure to an environmental 

8 hazard for a minority or low-income population is significant and exceeds the risk or exposure 

9 rate for the general population or for another appropriate comparison group. The minority and 

10 low-income populations are subsets of the general public residing around the site, and all are 

11 exposed to the same hazards generated from various power plant operations. 

12 Minority and low-income populations could be affected by the construction and operation of a 

13 new natural gas-fired power plant, wind farm, and wood-fired power generating plant. The 

14 extent of disproportionate effect is difficult to determine since it would depend on the location of 

15 these power generating facilities. Some of these effects have been identified in resource areas 

16 discussed in this section. For example, increased demand for rental housing during construction 

17 could disproportionately affect low-income populations. However, demand for rental housing 

18 could be mitigated if the power generating facilities are constructed near a metropolitan area. 

19 Impacts on minority and low-income populations under the combination alternative could range 

20 from SMALL to MODERATE, due to the small number of workers needed to construct and 

21 operate the natural gas-fired power plant, wind farm, and wood-fired power generating plant. 

22 Weatherization programs could target low-income residents as a cost-effective energy efficiency 

23 option since low-income populations tend to spend a larger proportion of their incomes paying 

24 utility bills (according to the Office of Management and Budget, low income populations 

25 experience energy burdens more than four times as large as those of average households 

26 (OMB, 2007)). Impacts to minority and low-income populations from energy efficiency programs 

27 would be SMALL, depending on program design and enrollment. 

28 8.3.7 Waste Management 

29 During the construction stage of this alternative, land clearing and other construction activities 

30 would generate waste that can be recycled, disposed onsite or shipped to an offsite waste 

31 disposal facility. If the alternative were constructed at the KPS site or any previously disturbed 

32 site, the amounts of wastes produced during land-clearing would be reduced. 

33 During operational stage, spent SCR catalysts, which are used to control NOx emissions from 

34 the natural gas-fired plants, would make up the majority of the waste generated by this 

35 alternative. 

36 There would be a small amount of waste generated during the construction of the wind power 

37 facilities and minimal waste associated with its maintenance. 

38 As stated in the GEIS (NRC, 1996), wood-fired component of this alternative would produce 

39 considerable amount of fly ash, which can be successfully used as beneficial fertilizer and soil 

40 conditioner. 
Environmental Impact of Alternatives 

February 2010 8-37 Draft NUREG-1437, Supplement 40 

1 The NRC staff concludes that overall waste impacts of the combination alternative consisting of 

2 natural gas-fired plant located at the KPS site and the wind power (option 1), or of the natural 

3 gas-fired plant located at KPS and wood-fired power (option 2) would be SMALL. 

4 8.4 PURCHASED POWER 

5 In the ER (DEK, 2008), DEK indicated that it was unlikely that purchased power would be 

6 available in sufficient capacity over the 20-year period of extended operation in order to serve 

7 as an alternative to license renewal. DEK further indicated that it was likely that relying on 

8 purchased power would simply shift the responsibility to construct new facilities to replace KPS 

9 to other generators. In addition, DEK indicated that transmission constraints in northeastern 

10 Wisconsin make it unlikely that out-of-State purchased power could be imported in sufficient 

11 quantity to offset KPS’s capacity. The staff has reviewed these assertions and finds them to be 

12 reasonably reflective of the challenges facing purchased power as an alternative to license 

13 renewal. As a result, the staff has not separately evaluated purchased power as an alternative 

14 to license renewal. 

15 8.5 ALTERNATIVES CONSIDERED BUT DISMISSED 

16 In this section, the staff discusses the energy alternatives that it determined either would not 

17 individually meet the purpose and need identified in the GEIS or whose costs preclude 

18 consideration in greater depth. The staff considered several of these alternatives in the 

19 combination alternatives in Sections 8.2 and 8.3. 

20 8.5.1 Wind Power 

21 The American Wind Energy Association and the U.S. Department of Energy indicate that 

22 Wisconsin currently has 449 MW of installed wind capacity (AWEA Undated; 

23 http://www.windpoweringamerica.gov/wind_installed_capacity.asp). The greatest potential for 

24 wind power generation in Wisconsin is in the east-central and northeast part of the State, which 

25 includes the KPS site. Wind power potential ranges from class 3 to class 4 in this area, 

26 according to wind speed maps published by the Wisconsin Office of Energy Independence 

27 (2008). 

28 Despite Wisconsin’s good wind power potential, wind power is not yet suitable for stand-alone 

29 large base load capacity. When paired with energy storage or a readily dispatchable power 

30 source like hydropower, wind could serve as a means of providing base load power. Even if 

31 suitable, additional backup capacity could be found to support a completely wind-powered 

32 option, replacing KPS with wind turbines would require more than a doubling of Wisconsin’s 

33 current capacity by 2013. 

34 Given wind power’s intermittency and the lack of available backup, as well as the current level 

35 of implementation in Wisconsin, the NRC staff will not consider wind power as a stand-alone 

36 alternative to license renewal. However, given Wisconsin’s significant wind resource, the staff 

37 will consider wind power as a portion of a combination alternative. 
Environmental Impacts of Alternatives 

Draft NUREG-1437, Supplement 40 8-38 February 2010 

1 8.5.2 Wood-Fired Power 

2 Two generating stations in Wisconsin currently rely on wood for a portion of their fuel. In 2007, 

3 these facilities burned 315,811 tons of wood with a heat output of 3,437 billion British thermal 

4 units (Btu) (Wisconsin Office of Energy Independence, 2008). Further, wood currently 

5 constitutes the primary renewable energy source in the State. 

6 In 1999, DOE researchers estimated that Wisconsin has biomass fuel resources consisting of 

7 urban, mill, agricultural, and forest residues, as well as speculative potential for energy crops. 

8 Excluding potential energy crops, DOE researchers projected that Wisconsin had 

9 7,149,128 tons (6,485,579 MT) of plant-based biomass available at $50 per ton delivered 

10 (Walsh et al., 2000; costs are in 1995 dollars). Wood-fired power plants in Wisconsin report an 

11 average heat content of 5441.5 Btu/lb of wood fuel. Assuming a 33 percent conversion 

12 efficiency, using all plant-based biomass available in Wisconsin at $50 or less per ton (the 

13 maximum price the researchers considered) would generate roughly 7.6 terawatt-hours (TWh) 

14 of electricity. This is roughly two-thirds more electricity than KPS generated in 2008. However, 

15 most of this potential comes from agricultural residues, almost all of which (97 percent) are from 

16 corn production. Excluding agricultural residues (many of which are traditionally left on fields 

17 following harvest and provide fertilization for the following years crops), the total potential is 2 

18 TWh, or less than half of KPS’s 2008 production. 

19 Walsh et al. (2000) go on to note that these estimates of biomass capacity contain substantial 

20 uncertainty and that potential availability does not mean biomass will actually be available at the 

21 prices indicated or that resources will be usably free of contamination. Some of these plant 

22 wastes already have reuse value and would likely be more costly to deliver because of 

23 competition. Others, such as forest residues, may prove unsafe and unsustainable to harvest on 

24 a regular basis. 

25 As a result of limited resource availability, staff will not consider wood-fired as a stand-alone 

26 alternative to license renewal. The staff will, however, consider wood-fired as a portion of a 

27 combination alternative. 

28 8.5.3 Energy Conservation 

29 The Public Service Commission of Wisconsin commissioned a Statewide study of energy 

30 efficiency and customer-sited renewal energy potential in 2009 (Energy Center of Wisconsin, 

31 2009). The study’s base case results indicated that by 2018, the achievable potential of 

32 efficiency savings could amount to 13 percent of total electricity sales, 12.9 percent of peak 

33 demand, and 8.7 percent of natural gas sales in the State. These estimates are a small fraction 

34 of the total economic potential identified in the State. The study estimates that by 2012, the 

35 State could save 1200 gigawatt hours (GWh) or 250 MW in peak electricity demand. KPS’s 

36 operating license will expire in 2013, by which time an additional 1.6 percent of electricity 

37 demand and total energy could be saved. This amount is less than the power produced by KPS 

38 in the course of a year, and so energy efficiency will not be considered as a stand-alone 

39 alternative to license renewal. 
Environmental Impact of Alternatives 

February 2010 8-39 Draft NUREG-1437, Supplement 40 

1 The energy efficiency potential in the State is significant, however, and energy efficiency 

2 measures tend to have low environmental consequences. As a result, the staff will consider 

3 energy efficiency as a portion of a combination alternative. 

4 8.5.4 Solar Power 

5 Solar technologies use the sun’s energy to produce electricity. Wisconsin receives between 4 

6 and 4.5 kilowatt-hours (kWh) per square meter per day, or approximately 0.4 kWh of solar 

7 radiation per square foot per day, for solar collectors oriented at an angle equal to the 

8 installation’s latitude (NREL, 2009). At this level of incident solar radiation, photovoltaics are 

9 likely to be more effective than solar thermal power plants. Because flat-plate photovoltaics tend 

10 to be roughly 25 percent efficient, a solar-powered alternative would require roughly 3,200 acres 

11 (1,300 ha) of collectors to provide an amount of electricity equivalent to that generated by KPS 

12 in 2008. Space between collectors and associated infrastructure increase this land requirement. 

13 This amount of land, while large, is consistent with the land required for coal and natural gas 

14 fuel cycles. This amount of power generation, however, would occur only during the day and 

15 would necessitate some sort of power storage, introducing additional efficiency losses. As noted 

16 in the wind energy section, 8.4.1, energy storage technologies are in the early stages of 

17 development and are not yet large enough to provide enough backup capacity to replace KPS. 

18 Given the challenges in meeting base load requirements, the staff did not evaluate solar power 

19 as an alternative to license renewal of KPS. 

20 8.5.5 Hydroelectric Power 

21 According to researchers at Idaho National Energy and Environmental Laboratory, Wisconsin 

22 has an estimated 452.9 MWe of technically available, undeveloped hydroelectric resources at 

23 102 project sites throughout the State (INEEL, 1996). As such, the average potential project is 

24 small, with no potential sites having greater than 20-MW potential. 

25 The staff notes that the total available hydroelectric potential is smaller than the capacity of 

26 KPS, and thus will not consider hydroelectric power as an alternative to license renewal. 

27 8.5.6 Geothermal Power 

28 Geothermal energy has an average capacity factor of 90 percent and can be used for base load 

29 power where available. However, geothermal electric generation is limited by the geographical 

30 availability of geothermal resources (NRC, 1996). As illustrated by Figure 8.4 in the GEIS, no 

31 feasible location for geothermal capacity exists to serve as an alternative to KPS. The NRC staff 

32 concluded that geothermal energy is not a reasonable alternative to license renewal of KPS. 

33 8.5.7 Biofuels 

34 In addition to wood and municipal solid-waste fuels, discussed in 8.5.11, there are other 

35 concepts for biomass-fired electric generators, including direct burning of energy crops (crops 

36 grown specifically as fuel or feedstock for fuel), conversion to liquid biofuels, and biomass 

37 gasification. In the GEIS, the staff indicated that none of these technologies had progressed to 

38 the point of being competitive on a large scale or of being reliable enough to replace a base 
Environmental Impacts of Alternatives 

Draft NUREG-1437, Supplement 40 8-40 February 2010 

1 load plant such as KPS. After reevaluating current technologies, the staff finds that other 

2 biomass-fired alternatives are still unable to reliably serve as an alternative to the continued 

3 operation of KPS and does not consider biofuels to be a viable alternative to KPS license 

4 renewal. 

5 8.5.8 New Nuclear Power 

6 Sources in the nuclear industry have recently indicated that reactor projects currently under 

7 development are likely eight or nine years from completion, or possibly online in the 2016–2017 

8 timeframe (Nucleonics Week, 2008). This is three to four years after the expiration of the license 

9 for KPS. Further, potential plant owners or operators wishing to submit a new proposal 

10 specifically to offset the capacity of KPS would require additional time to develop an application. 

11 Given the relatively short time remaining on the current KPS operating license compared to the 

12 time to license and construct a new nuclear power plant, the staff has not evaluated new 

13 nuclear generation as an alternative to license renewal. 

14 8.5.9 Oil-fired Power 

15 EIA’s 2009 Annual Energy Outlook indicates that oil-fired power will not account for any 

16 additions to capacity in the United States (EIA, 2009a). The variable costs of oil-fired generation 

17 tend to be greater than those of the nuclear or coal-fired options, and oil-fired generation tends 

18 to have greater environmental impacts than natural gas-fired generation. The high cost of oil 

19 (even prior to the record-high prices of 2008) has prompted a steady decline in its use for 

20 electricity generation. Thus the staff did not consider oil-fired generation as an alternative KPS 

21 license renewal. 

22 8.5.10 Fuel Cells 

23 Fuel cells oxidize fuels without combustion and related environmental side effects. Power is 

24 produced electrochemically by passing a hydrogen-rich fuel over an anode and air (or oxygen) 

25 over a cathode and separating the two by an electrolyte. The only byproducts (depending on 

26 fuel characteristics) are heat, water, and CO2. Hydrogen fuel can come from a variety of 

27 hydrocarbon resources by subjecting them to steam under pressure. Natural gas is typically 

28 used as the source of hydrogen. 

29 At the present time, fuel cells are not economically or technologically competitive with other 

30 alternatives for base load electricity generation. EIA projects that fuel cells may cost $5,360 per 

31 installed kilowatts (kWs) (total overnight costs), or 2.5 times the construction cost of new coal32 fired generating capacity and 5.7 times the cost of new, advanced gas-fired, combined-cycle 

33 capacity (EIA, 2009c). In addition, fuel cell units are likely to be small in size (the EIA reference 

34 plant is 10 MWe). While it may be possible to use a distributed array of fuel cells to provide an 

35 alternative to KPS, it would be extremely costly to do so and would require 56 reference-size 

36 units. Accordingly, the staff does not consider fuel cells as an alternative to KPS license 

37 renewal. 
Environmental Impact of Alternatives 

February 2010 8-41 Draft NUREG-1437, Supplement 40 

1 8.5.11 Municipal Solid Waste 

2 Municipal solid waste combustors incinerate waste to produce steam, hot water, or electricity. 

3 Combustors use three types of technologies—mass burn, modular, and refuse-derived fuel. 

4 Mass burning is currently the method used most frequently in the United States and involves 

5 little to no sorting, shredding, or separation. Consequently, toxic or hazardous components 

6 present in the waste stream are combusted, and toxic constituents are exhausted to the air or 

7 become part of the resulting solid wastes. Currently, approximately 89 waste-to-energy plants 

8 operate in the United States. These plants generate approximately 2,700 MWe, or an average 

9 of approximately 30 MWe per plant (IWSA, 2007). Approximately 19 average-sized plants will 

10 be necessary to provide the same level of output as the other alternatives to KPS license 

11 renewal. 

12 The GEIS indicates that the overall level of construction impact from a waste-fired plant will be 

13 similar to that for a coal-fired power plant. The GEIS also indicates that waste-fired plants have 

14 the same or greater operational impacts than coal-fired technologies (including impacts on the 

15 aquatic environment, air, and waste disposal). The initial capital costs for municipal solid-waste 

16 plants are greater than for comparable steam-turbine technology at coal-fired facilities or at 

17 wood-fired facilities because of the need for specialized waste separation and handling 

18 equipment (NRC, 1996). 

19 Regulatory structures that once supported municipal solid waste incineration no longer exist. 

20 For example, the Tax Reform Act of 1986 made capital-intensive projects such as municipal 

21 waste combustion facilities more expensive relative to less capital-intensive waste disposal 

22 alternatives such as landfills. Also, the 1994 Supreme Court decision C&A Carbone, Inc. v. 

23 Town of Clarkstown, New York, struck down local flow control ordinances that required waste to 

24 be delivered to specific municipal waste combustion facilities rather than landfills that may have 

25 had lower fees. Additionally, environmental regulations have increased the capital cost 

26 necessary to construct and maintain municipal waste combustion facilities. 

27 Given the small average installed size of municipal solid waste plants and the unfavorable 

28 regulatory environment, the staff does not consider municipal solid waste combustion to be a 

29 feasible alternative to KPS license renewal. 

30 8.5.12 Delayed Retirement 

31 In the KPS ER, DEK indicated that few base load plants are likely to retire in the near future in 

32 Wisconsin. DEK identified roughly 315 MW of capacity operated by other generators in the 

33 State, which is significantly less than the 590 MW currently produced by KPS. Further, delaying 

34 retirement of older, coal-fired plants is likely to carry additional environmental impacts, as they 

35 typically have less-advanced emissions controls. As a result, the staff will not consider delayed 

36 retirement as an alternative to KPS license renewal. 
Environmental Impacts of Alternatives 

Draft NUREG-1437, Supplement 40 8-42 February 2010 

1 8.6 NO-ACTION ALTERNATIVE 

2 This section will examine the environmental effects that will occur if the NRC takes no action. 

3 No action in this case means that the NRC does not issue a renewed operating license for KPS 

4 and its license simply expires at the end of the current license term, in 2013. If the NRC takes 

5 no action, the plant will shutdown at or before the end of the current license. After shutdown, 

6 plant operators will initiate decommissioning according to 10 CFR 50.82. 

7 The staff notes that no action is the only alternative considered in-depth that does not satisfy the 

8 purpose and need for this draft SEIS, as it does not meet system needs beyond the term of the 

9 current license. The no-action alternative would not meet the energy needs currently met by 

10 KPS or that the alternatives evaluated in sections 8.1 through 8.3 would satisfy. Assuming that a 

11 need currently exists for the power generated by KPS, the no-action alternative would require 

12 the appropriate energy planning decision makers to rely on another alternative or conservation 

13 to replace or offset KPS’s capacity. 

14 In this section, the staff addresses only those impacts that arise directly as a result of plant 

15 shutdown. The staff has already addressed environmental impacts from decommissioning and 

16 related activities in several other documents. These documents include the Final Generic 

17 Environmental Impact Statement on Decommissioning of Nuclear Facilities, NUREG-0586, 

18 Supplement 1 (NRC, 2002); the license renewal GEIS (Chapter 7; NRC, 1996); and Chapter 7 

19 of this draft SEIS. These analyses either directly address or bound the environmental impacts of 

20 decommissioning whenever DEK ceases operating KPS. 

21 The staff notes that, even with a renewed operating license, KPS will eventually shut down, and 

22 the environmental effects addressed in this section will occur at that time. Since these effects 

23 have not otherwise been addressed in this draft SEIS, the staff will address the impacts in this 

24 section. As with decommissioning effects, it is likely that shutdown effects will be similar whether 

25 they occur at the end of the current license or at the end of a renewed license. The only 

26 difference is that the impacts will occur 20 years sooner if no action is taken. 

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

28 Kewaunee Power Station Operation 

No Action Continued KPS Operation 

Air Quality SMALL SMALL 

Groundwater SMALL SMALL 

Surface Water SMALL SMALL 

Ecology SMALL SMALL 

Human Health SMALL SMALL 

Socioeconomics SMALL SMALL TO MODERATE 

Waste Management SMALL SMALL 
Environmental Impact of Alternatives 

February 2010 8-43 Draft NUREG-1437, Supplement 40 

1 8.6.1 Air Quality 

2 When the plant stops operating, there would be a reduction in emissions from activities related 

3 to plant operation such as the use of diesel generators and employees’ vehicles. In Chapter 4, 

4 NRC staff determined that these emissions would have a SMALL impact on air quality during 

5 the renewal term. Therefore, if the emissions decrease, the impact to air quality would also 

6 decrease and would be SMALL. 

7 8.6.2 Groundwater Use and Quality 

8 The use of groundwater would diminish as plant personnel are removed from the site and 

9 operations cease. Some consumption of groundwater may continue as a small staff remains 

10 onsite to maintain facilities prior to decommissioning. Overall impacts would be smaller than 

11 during operations, but would remain SMALL. 

12 8.6.3 Surface Water Use and Quality 

13 The rate of consumptive use of surface water would decrease as the plant is shut down and the 

14 reactor cooling system continues to remove the heat of decay. Wastewater discharges would 

15 also be reduced considerably. Shutdown would reduce the already SMALL impact on surface 

16 water resources and quality. 

17 8.6.4 Aquatic and Terrestrial Resources 

18 Plant shutdown will minimally affect aquatic resources. In Chapter 4 of this draft SEIS, the NRC 

19 staff concludes that the impacts of continued operation on aquatic resources will be SMALL. No 

20 additional land disturbances on or offsite would occur. Maintenance of transmission line ROWs 

21 will continue, regardless of plant operation. Shutdown will reduce the already SMALL impacts to 

22 aquatic ecology. As such, the staff concludes that impacts to aquatic resources as a result of 

23 plant shutdown will be SMALL 

24 Shutdown will minimally affect terrestrial resources. In Chapter 4 of this draft SEIS, the staff 

25 concluded that the impacts of continued operation on terrestrial resources will be SMALL. No 

26 additional land disturbances onsite or offsite would occur. Maintenance of transmission line 

27 ROWs would continue through 20 years, regardless of plant operation. Shutdown would reduce 

28 the already SMALL impacts to terrestrial ecology. Accordingly, the staff concludes that impacts 

29 to terrestrial resources as a result of plant shutdown would be SMALL. 

30 8.6.5 Human Health 

31 Human health risks would decrease following plant shutdown. The plant, which is currently 

32 operating within regulatory limits, would release less radioactive gaseous and liquid material into 

33 the environment. Thus, members of the public would receive less radiation exposure. Also, after 

34 shutdown, the variety of potential accidents (radiological and industrial) at the plant would be 

35 reduced to a limited set associated with shutdown events and fuel handling and storage. In 

36 Chapter 4 of this draft SEIS, the staff concluded that the impacts of continued plant operation on 

37 human health would be SMALL. In Chapter 5, the staff concluded that the impacts of accidents 

38 during operation would be SMALL. Therefore, shutdown of the plant at the end of its license will 
Environmental Impacts of Alternatives 

Draft NUREG-1437, Supplement 40 8-44 February 2010 

1 decrease radioactive emissions and the variety of potential accidents. The staff concludes that 

2 the impacts to human health following plant shutdown would be SMALL. 

3 The no-action alternative would cause KPS to enter the decommissioning phase. Environmental 

4 impacts from the decommissioning activities of any reactor before or at the end of an initial or 

5 renewed license are evaluated in the Generic Environmental Impact Statement for 

6 Decommissioning of Nuclear Facilities: Supplement 1, Regarding the Decommissioning of 

7 Nuclear Power Reactors, NUREG-0586, Supplement 1 (NRC, 2002). The document concluded 

8 that the human health impacts from decommissioning a power reactor are SMALL. In Chapter 7 

9 of this draft SEIS, the staff used information contained in NUREG-0586, Supplement 1, its 

10 review of the applicant’s environmental report, the site audit, and the public scoping process to 

11 conclude that the impacts to human health during the decommissioning phase of KPS would be 

12 SMALL. 

13 The staff concludes that the impacts to human health for the no action alternative would be 

14 SMALL. 

15 8.6.6 Socioeconomics 

16 Land Use

17 Plant shutdown would not affect onsite land use. Plant structures and other facilities would 

18 remain in place until decommissioning. Most transmission lines connected to KPS would remain 

19 in service after the plant stops operating. Maintenance of most existing transmission lines would 

20 continue as before. Impacts on land use from plant shutdown would be SMALL. 

21 Socioeconomics

22 Plant shutdown would have an impact on socioeconomic conditions in the region around KPS. 

23 Plant shutdown would eliminate up to 735 jobs and would reduce tax revenue in the region. The 

24 loss of these contributions, which may not entirely cease until after decommissioning, would 

25 have a SMALL to MODERATE impact. See Appendix J to NUREG 0586, Supplement 1 

26 (NRC, 2002), for additional discussion of the potential socioeconomic impacts of plant 

27 decommissioning. 

28 Transportation

29 Traffic volumes on the roads in the vicinity of KPS would be reduced after plant shutdown. Most 

30 of the reduction in traffic volume would be associated with the loss of jobs at the plant. 

31 Deliveries to the plant would be reduced until decommissioning. Transportation impacts would 

32 be SMALL as a result of plant shutdown. 

33 Aesthetics

34 Plant structures and other facilities would remain in place until decommissioning, and plumes 

35 from the plant’s cooling towers would disappear entirely. Noise caused by plant operation would 

36 cease. Aesthetic impacts of plant closure would be SMALL. 
Environmental Impact of Alternatives 

February 2010 8-45 Draft NUREG-1437, Supplement 40 

1 Historic and Archaeological Resources

2 Plant shutdown will likely have no noticeable immediate impacts on historic and archaeological 

3 resources. Decommissioning methods would be described in a post-shutdown decommissioning 

4 activities report, which is required to be submitted to NRC within two years following cessation 

5 of operations. NRC requirements ensure that the decommissioning activities would be subject to 

6 a Section 106 review in accordance with the National Historic Preservation Act (NHPA). It is 

7 unlikely that plant staff will begin deconstruction or remediation before decommissioning. 

8 Because existing transmission lines will remain energized, transmission line ROW maintenance 

9 would continue. In Chapter 4 of this draft SEIS, the NRC concluded that the impacts of 

10 continued plant operation on historic and archaeological resources could be SMALL. 

11 Impacts from the no-action alternative would also be SMALL, since KPS would be 

12 decommissioned with no alternative power plant to replace it. A separate environmental and 

13 Section 106 review would be conducted for decommissioning. That assessment will address the 

14 protection of historic and archaeological resources. 

15 Environmental Justice

16 Termination of power plant operations would not disproportionately affect minority and low17 income populations outside of the immediate vicinity of KPS, because minority and low-income 

18 populations are generally concentrated in urban areas. Impacts to all other resource areas 

19 would be SMALL to MODERATE. Thus, impacts from plant shutdown would be SMALL. See 

20 Appendix J of NUREG 0586, Supplement 1 (NRC, 2002), for additional discussion of these 

21 impacts. 

22 8.6.7 Waste Management 

23 If the no-action alternative were implemented the generation of high-level waste would stop and 

24 the generation of low-level and mixed waste would decrease. Impacts from implementation of 

25 the no-action alternative are expected to be SMALL.

26 8.7 ALTERNATIVES SUMMARY 

27 In this chapter, we considered the following alternatives to KPS license renewal: 

28 ● A gas-fired combined-cycle plant at the KPS site and an undetermined alternate site; 

29 ● A coal-fired plant at the KPS site and an undetermined alternative site, and; 

30 ● Two combinations of alternatives including gas-fired capacity, energy conservation and 

31 either wind power (option 1), or wood-fired power (option 2). 

32 Finally, the staff considered the effects of no action by the NRC. Impacts for all alternatives are 

33 summarized in Table 8.5. The impacts of license renewal for KPS are similar to or smaller than 

34 the impacts of the alternatives considered in this chapter in all resource areas, with the 

35 exception of no action. No action, however, would necessitate additional action on the part of 

36 other entities to either replace or offset the power produced by KPS, and thus would result in 

37 additional impacts similar to those discussed in the other sections of this chapter. 
Environmental Impacts of Alternatives 

Draft NUREG-1437, Supplement 40 8-46 February 2010 

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

KPS 

License 

Renewal 

Gas-fired 

at KPS 

Site 

Gas-fired at 

Alternate 

Site 

Coal-Fired 

at KPS 

Site 

CoalFired at 

Alternate 

Site 

Combination 

Option 1 

Combination 

Option 2 

No-Action 

Alternative 

Air Quality SMALL MODERATE MODERATE MODERATE MODERATE MODERATE MODERATE SMALL 

Groundwater SMALL SMALL SMALL SMALL SMALL SMALL SMALL SMALL 

Surface Water SMALL SMALL SMALL to 

MODERATE SMALL SMALL SMALL to MODERATE SMALL SMALL 

Ecology SMALL SMALL to 

MODERATE 

SMALL to 

MODERATE MODERATE MODERATE SMALL to LARGE 

SMALL to 

LARGE SMALL 

Human Health SMALL SMALL SMALL SMALL SMALL SMALL to 

MODERATE 

SMALL to 

MODERATE SMALL 

Socioeconomics SMALL TO 

MODERATE 

SMALL to 

MODERATE 

SMALL to 

MODERATE 

SMALL to 

LARGE 

SMALL to 

LARGE 

SMALL to 

LARGE 

SMALL to 

MODERATE 

SMALL to 

MODERATE 

Waste 

Management SMALL SMALL SMALL MODERATE MODERATE SMALL SMALL SMALL 

2 8.8 REFERENCES 

3 10 CFR 51. U.S. Code of Federal Regulations, Title 10, Energy, Part 50, “Environmental 

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

5 40 CFR 50. U.S. Code of Federal Regulations, Title 40, Protection of Environment, Part 50, 

6 “Domestic Licensing of Production and Utilization Facilities.” 

7 40 CFR 51. U.S. Code of Federal Regulations, Title 40, Protection of Environment, Part 51, 

8 “Requirements for Preparation, Adoption, and Submittal of Implementation Plans.” 

9 40 CFR 60. U.S. Code of Federal Regulations, Title 40, Protection of Environment, Part 60, 

10 “Standards of Performance for New Stationary Sources.” 

11 40 CFR 75, U.S. Code of Federal Regulations, Title 40, Protection of Environment, Part 75, 

12 “Continuous Emission Monitoring.” 

13 64 FR 35714, Federal Register, Volume 64, No. 126, pp. 35714-35774. Washington, D.C. (July 

14 1, 1999) 

15 American Wind Energy Association (AWEA). Undated. “Resources: Wind Energy Projects (As 

16 of 12/31/2008).” Available URL: http://www.awea.org/projects/ (accessed September 12, 2009). 

17 Clean Air Act. 42 USC 7401, et seq. (CAA). United States Code, Title 42, The Public Health and 

18 Welfare, Chapter 85, “Air Pollution Prevention and Control.” 

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

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

21 Kewaunee Power Station. Docket No. 50-305. August 2008. ADAMS Accession No. 

22 ML082341039. 

23 Energy Center of Wisconsin. 2009. Energy Efficiency and Customer-Sited Renewable Resource 

24 Potential in Wisconsin for the Years 2012 and 2018. Available URL: 
Environmental Impact of Alternatives 

February 2010 8-47 Draft NUREG-1437, Supplement 40 

1 http://www.ecw.org/ecwresults/WI-Potential-Aug09.pdf (Alternate URL: 

2 http://psc.wi.gov/aboutus/pscreports/reports-index.htm) (accessed September 12, 2009). 

3 Energy Information Administration (EIA). 2008. Cost and Quality of Fuels for Electric Plants 

4 2006 and 2007. DOE/EIA-0191(2007). Washington, D.C. Available URL: 

5 http://tonto.eia.doe.gov/FTPROOT/electricity/019107.pdf (accessed September 14, 2009). 

6 Energy Information Administration (EIA). 2009a. Annual Energy Outlook 2009 with Projections 

7 to 2030. DOE/EIA-0383(2009). Washington, D.C. Available URL: 

8 http://tonto.eia.doe.gov/FTPROOT/forecasting/0383(2009).pdf (accessed September 12, 2009). 

9 Energy Information Administration (EIA). 2009b. “Net Generation by Energy Source.” Table 1.1 

10 from Electric Power Monthly for June 2009. Accessed at: 

11 http://www.eia.doe.gov/cneaf/electricity/epm/table1_1.html (accessed September 14, 2008). 

12 Energy Information Administration (EIA). 2009c. Assumptions to the Annual Energy Outlook 

13 2009 with Projections to 2030. DOE/EIA 0554 (2009). Washington, D.C. Available URL: 

14 http://tonto.eia.doe.gov/FTPROOT/forecasting/0554(2009).pdf (accessed September 14, 2009). 

15 Environmental Protection Agency (EPA). 1998. Compilation of Air Pollutant Emission Factors, 

16 Volume 1: Stationary Point and Area Sources: AP 42, Fifth Edition. “Section 1.1: Bituminous 

17 and Subbituminous Coal Combustion: Final Section Supplement E.” Washington, D.C. 

18 Environmental Protection Agency (EPA). 1999. “Regional Haze Regulations.” 40 CFR 51, 

19 Federal Register, Volume 64, No. 126, pp. 35714-35774. Washington, D.C. (July 1, 1999) 

20 Environmental Protection Agency (EPA). 2000a. “Regulatory Finding on Emissions of 

21 Hazardous Air Pollutants from Electric Utility Steam Generating Units.” Federal Register, 

22 Volume 65, No. 245, pp. 79825-79831. Washington, D.C. (December 20, 2000). 

23 Environmental Protection Agency (EPA). 2000b. “Notice of Regulatory Determination on Wastes 

24 from the Combustion of Fossil Fuels.” Federal Register, Volume 65, pp.32214-32237. 

25 Washington, D.C. (May 22, 2000). 

26 Environmental Protection Agency (EPA). 2007. “Clean Air Mercury Rule.” Available URL: 

27 http://www.epa.gov/air/mercuryrule/ (accessed June, 2009). ADAMS Accession No. 

28 ML082880732. 

29 Environmental Protection Agency (EPA). 2008a. New Source Review. Available URL: 

30 http://www.epa.gov/nsr/. ADAMS Accession No. ML083450073. 

31 Environmental Protection Agency (EPA). 2008b. “Basic concepts of Environmental Science. 

32 Module 6: Fabric filters”. Available URL: 

33 http://www.epa.gov/apti/bces/module6/matter/control/control.htm#fabric (accessed June 2009). 

34 ADAMS Accession No. ML091760654. 

35 Environmental Protection Agency (EPA). 2009a. EPA Green Book Nonattainment Areas for 

36 Criteria Pollutants. Available URL: http://www.epa.gov/air/oaqps/greenbk/index.html (accessed 

37 May 2009). 

38 Environmental Protection Agency (EPA). 2009b Clean Air Interstate Rule, Wisconsin. Available 

39 URL: http://www.epa.gov/CAIR/wi.html (accessed June 2009). ADAMS Accession No. 

40 ML092010055. 
Environmental Impacts of Alternatives 

Draft NUREG-1437, Supplement 40 8-48 February 2010 

1 General Electric Company (GE). 2007. “Gas Turbine and Combined Cycle Products.” May 

2 2007. Available URL: http://www.gepower.com/prod_serv/products/gas_turbines_cc/

3 en/downloads/gasturbine_cc_products.pdf (accessed January 6, 2009). ADAMS Accession No. 

4 ML082880731. 

5 Idaho National Engineering and Environmental Laboratory (INEEL). 1996. “U.S. Hydropower 

6 Resource Assessment for Wisconsin.” DOE/ID-10430(WI). Idaho Falls, ID. Available URL: 

7 http://hydropower.inl.gov/resourceassessment/pdfs/states/wi.pdf (accessed September 12, 

8 2009). 

9 Integrated Waste Services Association (IWSA). 2007. “Waste-to-Energy and the Production Tax 

10 Credit.” Washington, D.C. Available URL: http://www.wte.org/docs/FactSheetPTC.pdf (accessed 

11 May 24, 2007). ADAMS Accession No. ML083050223. 

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

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

14 ADAMS Accession Nos. ML040690705 and ML040690738. 

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

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

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

18 NUREG-1437, Volume 1, Addendum 1, Washington, D.C. 

19 U.S. Nuclear Regulatory Commission (NRC). 2002. Generic Environmental Impact Statement 

20 on Decommissioning of Nuclear Facilities: Supplement 1, Regarding the Decommissioning of 

21 Nuclear Power Reactors. NUREG-0586, Supplement 1, Volumes 1 and 2. Washington, D.C. 

22 National Renewable Energy Laboratory (NREL). 2009. “United States Atlas of Renewable 

23 Resources.” Interactive Map. Available URL: http://mapserve2.nrel.gov/website/Resource_Atlas/

24 viewer.htm (accessed September 12, 2009). 

25 Nucleonics Week. 2008. U.S. New Reactors More Likely Online in 2016 and Beyond, NEI 

26 Official Says. Volume 49, No. 15. April 10, 2008. 

27 U.S. Office of Management and Budget (OMB). 2007. “Detailed Information on the Low Income 

28 Home Energy Assistance Program Assessment.” Available URL: http://www.whitehouse.gov/

29 omb/expectmore/detail/10001059.2003.html (accessed July 10, 2007). ADAMS Accession No. 

30 ML082880730. 

31 Oak Ridge National Laboratory (ORNL). 2007. “Bioenergy Conversion Factors.” Available URL: 

32 http://bioenergy.ornl.gov/papers/misc/energy_conv.html (accessed November 6, 2007). ADAMS 

33 Accession No. ML0830502. 

34 Walsh, M.E., R.L. Perlack, A. Turhollow, D. de la Torre Ugarte, D.A. Becker, R.L. Graham, S.A. 

35 Slinsky, and D.E. Ray. 2000. “Biomass Feedstock Availability in the United States: 1999 State 

36 Level Analysis.” Available URL: http://bioenergy.ornl.gov/resourcedata/index.html (accessed 

37 May 22, 2007). ADAMS Accession No. ML083050223. 

38 Wisconsin Department of Natural Resources (WDNR). 2008. Factsheet on Rule to Control 

39 Mercury Emissions from Coal-Fired Power Plants. ADAMS Accession No. ML092010055. 

40 Wisconsin Department of Natural Resources (WDNR). 2009. “Global Climate Change. Reports 

41 and Documents.” Available URL: http://dnr.wi.gov/air/aq/global/climatechange/reports.html

42 (accessed June, 2009). 
Environmental Impact of Alternatives 

February 2010 8-49 Draft NUREG-1437, Supplement 40 

1 Wisconsin Office of Energy Independence. 2008. Wisconsin Energy Statistics. Available URL: 

2 http://energyindependence.wi.gov/subcategory.asp?linksubcatid=2825&linkcatid=2847&linkid=1

3 451&locid=160 (accessed September 12, 2009). 

February 2010 9-1 Draft NUREG-1437, Supplement 40 

1 9.0 CONCLUSION

2 This supplemental environmental impact statement (SEIS) contains the preliminary 

3 environmental review of Dominion Energy Kewaunee, Inc. (DEK) application for the renewed 

4 operating license for Kewaunee Power Station (KPS) as required by Title 10, Part 51, of the 

5 Code of Federal Regulations (10 CFR Part 51) that implement the National Environmental 

6 Policy Act (NEPA). This chapter presents the conclusions and recommendations from the 

7 site-specific environmental review of KPS and summarizes site-specific environmental issues of 

8 license renewal that were identified during the review. The environmental impacts of license 

9 renewal are summarized in Section 9.1; a comparison of the environmental impacts of license 

10 renewal and energy alternatives is presented in Section 9.2; unavoidable impacts of license 

11 renewal and energy alternatives and resource commitments are discussed in Section 9.3; and 

12 conclusions and U.S. Nuclear Regulatory Commission (NRC) recommendations are presented 

13 in Section 9.4.

14 9.1 ENVIRONMENTAL IMPACTS OF LICENSE RENEWAL 

15 Our review of site-specific environmental issues in this SEIS leads the staff to conclude that 

16 issuing a renewed license would have SMALL impacts for the 23 Category 2 issues applicable 

17 to license renewal of KPS. 

18 The requirements for the assessment of refurbishing in a license renewal of operating nuclear 

19 power plants include the preparation of an integrated plant assessment (IPA) under 

20 10 CFR 54.21. The IPA must identify and list systems, structures, and components subject to an 

21 aging management review. Items that are subject to aging and might require refurbishment 

22 include, for example, the reactor vessel, piping, supports, and pump casings, as well as those 

23 that are not subject to periodic replacement. In the case of KPS, the IPA did not identify the 

24 need of major refurbishment or replacement actions to maintain the functionality of important 

25 systems, structures, and components during the KPS license renewal period. Also, the IPA did 

26 not identify the need for modifications to any of the KPS facilities associated with the license 

27 renewal. 

28 Currently, no threatened or endangered aquatic species are known to occur within Lake 

29 Michigan on or in the vicinity of the KPS site or within any streams crossed by in-scope 

30 transmission line right of ways (ROWs); therefore, license renewal of KPS would have no effect 

31 on any Federally or State-listed aquatic species, and mitigation measures need not be 

32 considered. 

33 Operation of the KPS site and its associated transmission lines is not expected to adversely 

34 affect any threatened or endangered species during the license renewal term; therefore, the 

35 staff concludes that adverse impacts to threatened or endangered species during the period of 

36 extended operation would be SMALL. There are several mitigation measures currently in place 

37 at the KPS site and along its associated transmission lines which NRC finds to be adequate. 

38 Mitigation measures include: nest construction and placement for the peregrine falcon, 

39 environmental review checklists, environmental evaluation forms, and best management 

40 practices. 
Conclusion 

Draft NUREG-1437, Supplement 40 9-2 February 2010 

1 9.2 COMPARISON OF THE ENVIRONMENTAL IMPACTS OF LICENSE RENEWAL 

2 AND ALTERNATIVES 

3 In the conclusion to Chapter 8, the staff determined that impacts from license renewal are 

4 generally similar to, or smaller than the impacts of alternatives to license renewal. In comparing 

5 likely environmental impacts from gas-fired, coal-fired, two combinations of alternatives 

6 including gas-fired capacity, energy conservation and either wind power (option 1), or 

7 wood-fired power (option 2), and environmental impacts from license renewal, the staff found 

8 that the no action alternative would result in the lowest environmental impact. The no action 

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

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

11 to those discussed in Chapter 8. On the basis of its analysis, the staff found that the impacts of 

12 license renewal are reasonable in light of the impacts from alternatives to the license renewal. 

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 the emission and release 

20 of various chemical and radiological constituents from power plant operations. Nonradiological 

21 emissions resulting from power plant operations are expected to comply with Environmental 

22 Protection Agency (EPA) emissions standards, though the alternative of operating a 

23 fossil-fueled power plant in some areas may worsen existing attainment issues. Chemical and 

24 radiological emissions would not exceed the National Emission Standards for Hazardous Air 

25 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 any 

31 standards or administrative control limits. Construction and operation of non-nuclear power 

32 generating facilities would also result in unavoidable exposure to hazardous and toxic chemicals 

33 to workers and the general public. 

34 Also unavoidable would be the generation of spent nuclear fuel and waste material, including 

35 low-level radioactive waste, hazardous waste, and nonhazardous waste. Hazardous and 

36 nonhazardous wastes would also be generated at non-nuclear power generating facilities. 

37 Wastes generated during plant operations would be collected, stored, and shipped for suitable 

38 treatment, recycling, or disposal in accordance with applicable Federal and State regulations. 

39 Due to the costs of handling these materials, power plant operators would be expected to 

40 conduct all activities and optimize all operations in a way that would generate the smallest 

41 amount of waste practical. 
Conclusion 

February 2010 9-3 Draft NUREG-1437, Supplement 40 

1 9.3.2 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 during which 

5 continued power generating activities would take place. 

6 Power plant operations would necessitate short-term use of the environment and commitments 

7 of resources, and would also commit certain resources (e.g., land and energy) indefinitely or 

8 permanently. Certain short-term resource commitments would be substantially greater under 

9 most energy alternatives, including license renewal, than under the No Action alternative due to 

10 the continued generation of electrical power, as well as continued use of generating sites and 

11 associated infrastructure. During operations, all energy alternatives would entail similar 

12 relationships between local short-term uses of the environment and the maintenance and 

13 enhancement of long-term productivity. 

14 Air emissions from power plant operations would 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 would 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 would require an increase in energy and would consume 

25 space at treatment, storage, or disposal facilities. Regardless of the location, the use of land to 

26 meet waste disposal needs would reduce the long-term productivity of the land. 

27 Power plant facilities would be 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 Irreversible and irretrievable commitments of resources for electrical power generation would 

32 include the commitment of land, water, energy, raw materials, and other natural and manmade 

33 resources required for power plant operations. This section describes the irreversible and 

34 irretrievable commitments of resources that have been identified in this SEIS. A commitment of 

35 resources is irreversible when primary or secondary impacts limit the future options for a 

36 resource. An irretrievable commitment refers to the use or consumption of resources neither 

37 renewable nor recoverable for future use. In general, the commitment of capital, energy, labor, 

38 and material resources would also be irreversible. 
Conclusion 

Draft NUREG-1437, Supplement 40 9-4 February 2010 

1 The implementation of any of the energy alternatives considered in this SEIS would entail the 

2 irreversible and irretrievable commitments of energy, water, chemicals, and, in some cases, 

3 fossil fuels. These resources would be committed during the license renewal term and over the 

4 entire life cycle of the power plant and would essentially be unrecoverable. 

5 Energy expended would be in the form of fuel for equipment, vehicles, and power plant 

6 operations and electricity for equipment and facility operations. Electricity and fuels would be 

7 purchased from offsite commercial sources. Water would be obtained from existing water supply 

8 systems. These resources are readily available, and the amounts required are not expected to 

9 deplete available supplies or exceed available system capacities. 

10 The irreversible and irretrievable commitments of material resources include materials that 

11 cannot be recovered or recycled, materials that are rendered radioactive and cannot be 

12 decontaminated, and materials consumed or reduced to unrecoverable forms of waste; 

13 however, none of the resources used by these power generating facilities is in short supply, 

14 and, for the most part, are readily available. 

15 Various materials and chemicals, including acids and caustics, would be required to support 

16 operations activities. These materials would be derived from commercial vendors, and their 

17 consumption is not expected to affect local, regional, or national supplies. 

18 The treatment, storage, and disposal of spent nuclear fuel, low-level radioactive waste, 

19 hazardous waste, and nonhazardous waste would require the irretrievable commitment of 

20 energy and fuel and would result in the irreversible commitment of space in disposal facilities. 

21 

22 9.4 RECOMMENDATION 

23 Based on (1) the analysis and findings in the GEIS; (2) information provided in the 

24 environmental report (ER) submitted by DEK; (3) consultation with Federal, State, and local 

25 agencies; (4) a review of pertinent documents and reports; and (5) consideration of public 

26 comments received during scoping, the preliminary recommendation of the NRC staff is that the 

27 adverse environmental impacts of license renewal for KPS are not so great that preserving the 

28 option of license renewal for energy planning decisionmakers would be unreasonable. 
February 2010 10-1 Draft NUREG-1437, Supplement 40 

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 contract support from Pacific Northwest National 

5 Laboratory. 

6 Table 10-1. List of Preparers. Pacific Northwest National Laboratory provided contract support 

7 for the severe accident mitigation alternatives (SAMA) analysis, presented in Chapter 5 and 

8 Appendix F. 

Name Affiliation Function or Expertise 

Nuclear Regulatory Commission 

Briana Balsam Nuclear Reactor Regulation Ecology, Project Support 

Dennis Beissel Nuclear Reactor Regulation Hydrology 

Richard Bulavinetz Nuclear Reactor Regulation Aquatic Ecology 

Jennifer Davis Nuclear Reactor Regulation Historic and Archaeological 

Resources 

Nathan Goodman Nuclear Reactor Regulation Terrestrial Ecology 

Samuel Hernandez Nuclear Reactor Regulation Project Manager 

Stephen Klementowicz Nuclear Reactor Regulation Radiation Protection 

Ekaterina Lenning Nuclear Reactor Regulation Air Quality 

Dennis Logan Nuclear Reactor Regulation Ecology 

Sarah Lopas Nuclear Reactor Regulation Nonradiological Waste 

Robert Palla Nuclear Reactor Regulation Severe Accident Mitigation 

Alternatives 

Vanice Perin Nuclear Reactor Regulation Project Manager 

Jeffrey Rikhoff Nuclear Reactor Regulation Socioeconomics; Land Use; 

Environmental Justice 

Andrew Stuyvenburg Nuclear Reactor Regulation Alternatives 

Allison Travers Nuclear Reactor Regulation Hydrology 

SAMA Contractor(a)

Steve Short Pacific Northwest National Laboratory Severe Accidents Mitigation 

Alternatives 

Bruce Schmitt Pacific Northwest National Laboratory Severe Accidents Mitigation 

Alternatives 

Tye Blackburn Pacific Northwest National Laboratory Severe Accidents Mitigation 

Alternatives 

(a) 9 Pacific Northwest National Laboratory is operated by Batelle for the U.S. Department of Energy

February 2010 Draft NUREG-1437, Supplement 40 

APPENDIX A

COMMENTS RECEIVED ON THE ENVIRONMENTAL REVIEW 

February 2010 A-1 Draft NUREG-1437, Supplement 40 

1 A. COMMENTS RECEIVED ON THE ENVIRONMENTAL REVIEW

2 A.1. Comments Received During Scoping 

3 The scoping process related to the review of the Kewaunee Power Station (KPS) license 

4 renewal application submitted by Dominion Energy Kewaunee, Inc. (DEK), began on October 9, 

5 2008, with the publication of the U.S. Nuclear Regulatory Commission’s (NRC’s) Notice of Intent 

6 to conduct scoping in the Federal Register (73 FR 59678). The scoping process included two 

7 public meetings held at the Town Hall in Carlton, Wisconsin, on October 22, 2008. 

8 Approximately 60 members of the public attended the meetings. After the NRC’s prepared 

9 statements pertaining to the license renewal process, the meetings were open for public 

10 comments. Attendees provided oral statements that were recorded and transcribed by a 

11 certified court reporter. All written statements submitted at the public meeting were appended to 

12 the transcript. Transcripts of the entire meeting are an attachment to the Scoping Meeting 

13 Summary dated November 17, 2008 (NRC, 2008a). In addition to the comments received during 

14 the public meetings, comments were received by letter and by electronic mail and were 

15 addressed by the NRC staff. 

16 Each commenter was given a unique identifier so that every comment could be traced back to 

17 its author. Table A-1 identifies individuals providing comments applicable to the environmental 

18 review and their Commenter ID, and each person’s set of comments. The individuals are listed 

19 in the order in which they spoke at the public meeting, and in alphabetical order for the 

20 comments received by letter or e-mail. To maintain consistency with the Scoping Summary 

21 Report, the unique identifier used in that report for each set of comments is retained in this 

22 appendix. Specific comments were categorized and consolidated by topic. Comments with 

23 similar and specific objectives were combined to capture the common essential issues raised by 

24 participants. Comments fall into one of the following general groups: 

25 ● Specific comments that address environmental issues within the purview of the NRC 

26 environmental regulations related to license renewal. These comments address 

27 Category 1 (generic), or Category 2 (site-specific) issues or issues not addressed in 

28 the GEIS or Category 2 (site-specific) issues. They also address alternatives to license 

29 renewal and related Federal actions. 

30 ● General comments (1) in support of or opposed to nuclear power or license renewal or 

31 (2) on the renewal process, the NRC’s regulations, and the regulatory process. These 

32 comments may or may not be specifically related to the KPS license renewal 

33 application. 

34 ● Comments that do not identify new information for the NRC to analyze as part of its 

35 environmental review. 

36 ● Comments that address issues that do not to fall within or are specifically excluded 

37 from the purview of NRC environmental regulations related to license renewal. These 

38 comments typically address issues such as the need for power, emergency 

39 preparedness, security, current operational safety issues, and safety issues related to 

40 operation during the renewal period. 
Appendix A 

Draft NUREG-1437, Supplement 40 A-2 February 2010 

1 Table A-1. Commenters on the Scope of the Environmental Review. Each commenter is 

2 identified along with their affiliation and how their comment was submitted. 

Commenter ID Commenter Affiliation (If Stated) Comment Source; ML No(s). 

KPS-A Dave Hardtke Local Citizen 

Afternoon Scoping Meeting; 

Evening Scoping Meeting; 

ML083190734; 

ML083190744 

KPS-B Stanley Lacrosse Local Citizen 

Afternoon Scoping 

Meeting; Written Comments; 

ML083190734; 

ML083100095; 

ML090440072 

KPS-C Ken Paplham Board Supervisor, Town of Carlton Afternoon Scoping Meeting; 

ML083190734 

KPS-D Francis Wojta Local Citizen Afternoon Scoping Meeting; 

ML083190734 

KPS-E Rich Langan Congressman Steve Kagen’s Office Afternoon Scoping Meeting; 

ML083190734 

KPS-F Bob Garfinkel Kewaunee County Board; Literacy 

Partners of Kewaunee County 

Afternoon Scoping Meeting; 

ML083190734 

KPS-G Jennifer Brown Kewaunee County Economic 

Development Corporation 

Afternoon Scoping Meeting; 

ML083190734 

KPS-H Lori Hucek Kewaunee County Emergency 

Management 

Afternoon Scoping Meeting; 

ML083190734 

KPS-I Jim Soletzki State of Wisconsin Assembly 

Representative 

Afternoon Scoping Meeting; 

Written Comment; ML083100092 

KPS-J Mr. Carrole Local Citizen Evening Scoping Meeting; 

ML083190744 

KPS-K Steve Tadisch Local Citizen Evening Scoping Meeting; 

ML083190744 

KPS-L Bob Ziegelbauer State Representative, 25th Assembly 

District; Manitowoc County Executive 

Letter; ML083100586; 

ML083100094 

KPS-M Nancy Crowley Manitowoc County Emergency 

Services Coordinator Letter; ML083100093 

KPS-N Gregory Veith IUOE Local 310 President; Dominion 

Energy Kewaunee, Inc. E-mail; ML083380455 

3 Comments received during scoping applicable to this environmental review are presented in this 

4 section along with the NRC response. Comments general or outside the scope of the 

5 environmental review for KPS are not included here. Those comments can be found in the 

6 Scoping Summary Report (NRC, 2009a). 

7 Scoping comments are grouped in the following categories: 

8 ● Socioeconomics 
Appendix A 

February 2010 A-3 Draft NUREG-1437, Supplement 40 

1 ● Uranium Fuel Cycle and Waste Management 

2 A.1.1. Socioeconomics (Taxes and Distribution of Revenues) 

3 Comment: The nuclear plant also pays over $6 million in utility taxes to the State of Wisconsin 

4 every year. Wisconsin is the only State in which that utility does not stay in the municipality 

5 where the plant is located. Why is that? All property owners in the town of Carlton are currently 

6 paying full taxes as well, and deserve to be compensated. (KPS-B-1) 

7 Comment: One reason the people of the Township of Carlton are upset is the distribution of the 

8 money from the utility tax which the Kewaunee Nuclear Power Plant pays. The plant occupies 

9 1000 acres of what was once prime agricultural land. It purchased said land from 13 “small 

10 farms” which includes 1 mile of lake frontage where it is possible to walk out to the water’s 

11 shore. Now the rest of the taxpayers have had to pay extra property taxes to help make up for 

12 the lost valuation of those farms. It is simply a matter of getting compensated for what the town 

13 has lost. (KPS-B-2) 

14 Comment: Okay. Ms. Lopas you said that your committee oversees the, like land use and the 

15 water and the natural resources and all that. I have a question about land use. I’m from the town 

16 of Carlton. I live about three miles north of the nuclear plant. The way I understand it right now 

17 the utility taxes that we get from having that plant here just about equals the taxes that we would 

18 have gotten from homes that would have been built on that property. That means that in my 

19 opinion that means that nothing is gained by having the nuclear waste being stored here on this 

20 property which is what is going on right now. Above ground is the waste storage. The pools are 

21 full. So my question is what, what's going to happen when the plant closes and then the utility 

22 tax no longer applies? The waste is still going to be there. We're not getting anything for that 

23 waste. What do we have to gain by extending the license, having more and more waste being 

24 piled up there, high level waste. That's part of my concern. (KPS-A-1) 

25 Comment: You know, it, it's a shame to listen and we have to listen and it's not fair because I 

26 can tell you right now the perception of our town of Carlton by the public service commission, 

27 the NRC and all our elected officials as being a tax free township is not true. We pay more taxes 

28 than our neighboring town. And this is not right for the simple reason we had 480 signatures out 

29 of a possibly I think there's maybe a little over 600 people that are voting in this town and we 

30 had 480 signatures against letting them put the caskets on top of the ground unless we get 

31 compensated. And our town officials gave them the building permit. They scared them into it. 

32 Giving them a line. And this is what's all wrong because they ruined our zoning book because 

33 they said they didn't need a variance, they didn't need a conditional use, they didn't need that so 

34 they turned around and gave them the building permit and now they don't even, they don't know 

35 us no more. They're supposed to work without trying to get a little more money out of the State. 

36 The State gets six million, very close, for utility tax but none of it stays. We have to share it with 

37 the county for 19 percent. 

38 And I have to sort of correct Cindy a little bit. If they could put this town back the way it was 

39 without the nuclear plant we would pay less taxes. And this is what really makes it bad because 

40 in 1968 when they broke ground they bought this land real cheap. And the State says the 

41 assessor will be within ten percent of 100 so the assessor has to keep raising the rest of us to 

42 make up the difference so that's why our taxes are higher than the Town of Franklin or the Town 
Appendix A 

Draft NUREG-1437, Supplement 40 A-4 February 2010 

1 of Kewaunee. And I don't think this is right and that's why I'm opposing it and all the 480 

2 signatures are opposing relicensing that plant until this gets settled. 

3 I've got them all, all our officials, even the governor. They want to take the moratorium off to 

4 build a nuclear plant because it's the safest, the cleanest. Like I wrote in a letter to them when I 

5 sent them all the signatures. Where are you going to put the waste. We've stored it for 34 years 

6 under water and we finally got 50,000 and then Dominion devaluated the plant and we lost, how 

7 much? $37,000. Now you just said just a few minutes ago that they update, update, update. It's 

8 running at full capacity. How come you can devaluate it? I mean that's not your doing, but it, 

9 that's lost us $37,000. (KPS-B-3) 

10 Comment: I would like to like to make a little comment on that. It's only pocket change for 

11 Dominion. But at the same time -- all this volunteer that we have to take is on our fire 

12 departments. And the fire departments don't get a penny to do exactly what Dominion wants to 

13 get in so that everything is perfect. Us guys never get a penny. We don't even get paid for the 

14 gas in the, in the trucks that do all the running. So I don't -- The volunteer, the volunteer fire 

15 departments don't get paid. (KPS-B-4) 

16 Comment: I'd like to differ with that. They do get paid. Any type of response that they have with 

17 us whether it's training or for real they bill us. We pay them from our county's budget that we get 

18 reimbursed from the plant. If a person has to take off of work we pay their wages that day 

19 because they have responded to a training or an exercise or a real event. That is not true. 

20 (KPS-H-2)

21 Comment: If NRC can come over here and overrule our zoning because they are that big and 

22 they can step on us, it's like I told our State senator, we have only 600 voting people in the town 

23 and you don't give a damn about us. And that was Herb Cole. And it's the same with Kagen's 

24 office and it's the same with every one of them. We met with them all. And Gary Visor is the only 

25 one that is trying to fight for us. But the State of Wisconsin is the only State that takes all the 

26 utility tax and sends back what they want.(KPS-J-1) 

27 There's no incentive for Yucca Mountain to have something done when the rods can be stored 

28 at the facility when they get 95 percent of the money. We get the five percent of the money 

29 where I think if we got compensated at the very least maybe Yucca Mountain would say hey this 

30 is goes here we should get that. That's just the way I feel.(KPS-D-1) 

31 Response: Chapter 2 of this SEIS includes a discussion of the regional tax structure and the 

32 distribution of present revenues to each jurisdiction and district, however, the NRC has no role 

33 in how States and local jurisdictions tax their utilities, assess power plant value, or how tax 

34 money is distributed. 

35 A.1.2. Uranium Fuel Cycle and Waste Management 

36 Comment: I'm Ken Paplham. I'm on the town board here for 34 years as supervisor. And back 

37 in January of '93 the town board passed a resolution that there would be no outdoor storage at 

38 the power plant. We passed a resolution at that time. And now we're getting these stored 

39 outside and I think the municipality should be compensated from the Federal government of 

40 $250,000 a year plus $40,000 for each containment that's stored there as long as they're stored 
Appendix A 

February 2010 A-5 Draft NUREG-1437, Supplement 40 

1 there. I don't know why these municipalities have to put up with this storage when we had a 

2 resolution back in '93 that there was going to be no storage. I know the plant is in problems with 

3 Yucca Mountain but so I think something has to be done. Why should we live with that and like 

4 Cindy said right out in the open and Yucca Mountain is going to be a mile under the ground or in 

5 the, in a shaft there so. (KPS-C-1)

6 Comment: I am sending this letter to our officials on behalf of the citizens and taxpayers from 

7 the town of Carlton, in Kewaunee County. State and Federal officials need to take a good look 

8 at an alternative storage facility in order to keep the Kewaunee Nuclear Power Plant in 

9 operation. The storage the plant has in existence will soon be depleted; by the year 2011 

10 operation may have to be suspended until a suitable solution is found. We have come to know 

11 that nuclear energy is the most affordable, cleanest, most reliable, and safest way to achieve 

12 the emission savings that our nation has to strive for. That is why it is important to address this 

13 matter with the attention it deserves. 

14 The nuclear plants new owners, Dominion, recently came to the town meeting seeking approval 

15 to construct the dry storage facility for spent fuel rods on site. This is due to the fact that the 

16 pools which currently store the spent rods are reaching their maximum capacity. It had been 

17 promised by the Wisconsin Public Service that the rods were to be moved to Yucca Mountain, 

18 yet they are unfairly being forced to be stored in the town without being fully compensated. The 

19 nuclear plant has paid millions, if not billions, of dollars to the Federal Government over more 

20 than a 30 year span for a place to store the spent rods. And yet, regrettable, nothing has ever 

21 happened. Every spent rod since operation began in 1974 is still stored at the plant site. 

22 The dry storage location needs serious consideration. If nuclear power is less expensive than 

23 coal or natural gas, as well as cleaner, all the more important to work our hardest to maintain 

24 operation of the Kewaunee nuclear plant. We need our State and U.S. senators as well as 

25 Representatives to help do what is necessary and fair for the property owners here in the town 

26 of Carlton. The need for this dry storage is present and understood; let us work together for the 

27 benefit of everyone to create a workable solution. (KPS-B-5) 

28 Comment: “We the undersigned believe that if Dominion (Kewaunee Nuclear Power Plant) is 

29 allowed to construct the dry storage facility on site which is being proposed the land owners of 

30 the town of Carlton should be compensated accordingly. Meaning until the spent rods are 

31 moved to an alternate location, only then would it be fair if compensation were to cease.” (KPS32 B-6)

33 The complete petition is available at accession number ML083100095.

34 Comment: We have sent this letter to our officials on behalf of the citizens and taxpayers from 

35 the Town of Carlton, in Kewaunee County. State and Federal officials need to take a good look 

36 at an alternative storage facility in order to keep the Kewaunee Nuclear Power Plant in 

37 operation. The storage the plant has in existence will soon be depleted; by the year 2011 

38 operation may have to be suspended until a suitable solution is found. We have come to know 

39 that nuclear energy is the most affordable, cleanest, most reliable, and safest way to achieve 

40 the emission savings that our nation has to strive for. That is why it is important to address this 

41 matter with the attention it deserves.
Appendix A 

Draft NUREG-1437, Supplement 40 A-6 February 2010 

1 Another concern is the “promise” once made that the spent fuel rods from this plant would be 

2 moved to Yucca Mountain, that has failed to happen as of yet. We are all concerned for our 

3 well-being and also that of our families and neighbors, the entire community. We believe this is 

4 God’s country and need to protect what we have for our future generations, our grandchildren 

5 and great-grandchildren. 

6 The nuclear plants new owners, Dominion, recently came to the town meeting seeking approval 

7 to construct a dry storage facility for spent fuel rods on site. This is due to the fact that the pools 

8 which currently store the spent fuel rods are reaching their maximum capacity. It has been 

9 promised by the Wisconsin Public Service that the rods were to be moved to Yucca Mountain, 

10 yet they are unfairly being forced to be stored in the town without being fully compensated. The 

11 nuclear plant has paid millions, if not billions of dollars to the Federal government over more 

12 than a 30 year span for a place to store the spent rods. And yet, regrettably, nothing has ever 

13 happened. Every spent rod since operation began in 1974 is still stored at the plant site. 

14 The dry storage location needs serious consideration. If nuclear power is less expensive than 

15 coal or natural gas, as well as cleaner, all the more important to work our hardest to maintain 

16 operation of the Kewaunee nuclear plant. We need our State and U.S. senators as well as 

17 Representatives to help do what is necessary and fair for the property owners here in the town 

18 of Carlton. The need for this dry storage is presenting and understood; let us work together for 

19 the benefit of everyone to create a workable solution. (KPS-B-7) 

20 Comment: Resolution of Conditional Approval

21 The town board of the town of Carlton, Kewaunee County, Wisconsin, meeting in 

22 a regularly scheduled session on the 12 day January, 1993, upon consideration 

23 of the matter and upon vote duly taken, hereby resolves that: 

24 The town board of the town of Carlton, Kewaunee County, Wisconsin, approves 

25 and supports the proposal before the State of Wisconsin to modify the addendum 

26 payment formula of utility tax if, and only if, all affected utilities are prohibited by 

27 law from moving or removing any spent fuel currently stored in pools, or to be 

28 stored in pools in the future, unless such removal is for the sole purpose of 

29 immediate transport out of the town of Carlton. 

30 The basis for this Resolution is that the town board strongly believes that the 

31 renumeration to the town of Carlton from and on behalf of the nuclear power 

32 plant in the Town is unfairly and disproportionately low, in light of the 

33 environmental and health risks to the residents, livestock, and land of the town of 

34 Carlton and surrounding communities. (KPS-B-8) 

35 The above Resolution is available at accession number ML090440072. The town of Carlton 

36 board meeting proceedings dated May 13, June 10, and July 10, 2008, were attached to the 

37 resolution, and are also available at ML090440072. 

38 Comment: How can it be just as safe above ground with a fence around it compared to being 

39 under the ground about a mile under the ground with a 5,000 I believe, 5,000 foot high mountain 

40 on top of it? How can it be just as safe sitting out there a few miles from my house and who 

41 knows how long it's going to sit there? (KPS-A-2)
Appendix A 

February 2010 A-7 Draft NUREG-1437, Supplement 40 

1 Comment: My name is Stanley Lacrosse and I've lived in this town for 54 years and I've heard 

2 nothing but lies all the way through. I've attended every meeting. And what I'm against, strongly 

3 oppose licensing this plant until we get these issues solved for the simple reason we have these 

4 caskets up there. We have to take your word for it, the NRC word for it that they're safe. And 

5 you say they'll be moved. That's not true. They'll never move because I got the CRS report 

6 updates since October of 2008 and it says right in there possibly the year 2020 they might start 

7 receiving. But it also states that if everyone goes there there's not enough room. So you know 

8 the furthest one away will never go. (KPS-B-9) 

9 Comment: Yeah, I'm Francis Wojta. I'm just a dairy farmer down the road. I'm probably just an 

10 average joe farmer. But, whoops, I just, you know, the NRC takes care of the licensing process, 

11 the DOE takes care of the energy process of it. And I know it's, the Federal government is a big 

12 bureaucracy. And if somehow they could get together because we say our concerns to you well 

13 that's the department, DOE, you have to talk to those people. And we never, the local people 

14 never get clear cut answers, you know. You started out with public service they said no rods 

15 would be stored here. Dominion came, we have rods stored here. They're a good partner I feel 

16 and they do everything safely. We feel safe with the plant but now we're storing nuclear rods. 

17 Part of the, part of our tax money goes to pay for the electric bill, goes to Washington for fuel 

18 storage which is supposed to go to Yucca Mountain. So Yucca Mountain gets 95 percent of our 

19 tax money to build Yucca Mountain that was supposed to be done in 1998. Now they're saying 

20 it's supposed to be done in 2018, okay. Or whatever date it's supposed to be done. We aren't 

21 sure of that, okay. Here the rods sit here. There's no incentive for Yucca Mountain to have 

22 something done when the rods can be stored at the facility when they get 95 percent of the 

23 money. We get the five percent of the money where I think if we got compensated at the very 

24 least maybe Yucca Mountain would say hey this is goes here we should get that. That's just the 

25 way I feel. (KPS-D-2) 

26 Comment: I just want to inform you a little bit that 26 plants already have gotten billions of 

27 dollars from the Department of Energy. One just got 56 million last March. So it's, the 

28 Department of Energy is paying it out but it is not coming from the, the nuclear fund. It has come 

29 from us taxpayers. (KPS-C-2) 

30 Comment: I'm from Congressman Kagen's office. Okay. When we talk about suing the Federal 

31 government what happens is that anybody who is served by a nuclear power plant there's a 

32 surcharge put on your electric bill. I live in Ashwaubenon and a couple of communities away. It's 

33 served by and I pay a surcharge. That surcharge goes into a big pot of dollars to the 

34 Department of Energy. The Department of Energy holds these dollars for the formulation of a 

35 place like Yucca Mountain. Now some of these nuclear plants are running out of room. So 

36 they're saying what do you want us to do about this Federal government you're not taking our 

37 garbage. We want the garbage taken out. And the Federal government, DOE is saying sorry we 

38 can't accept it just yet. So what happens here now is that okay we're going to sue you. Well yes, 

39 that's fine, we're not suing the NRC we're going to sue the DOE because the DOE is charged 

40 with formulating Yucca Mountain here. So Congress said okay if you're going to sue we're not 

41 going to let this money come from the Yucca Mountain fund. We're going to put a pot of dollars 

42 over here in another pot from the general treasury of the United States. And if any nuclear plant 

43 is successful in suing the Federal government the money will not come out of Yucca Mountain 

44 fund it will come out of the general treasury fund. So what happens now is that that money that's 
Appendix A 

Draft NUREG-1437, Supplement 40 A-8 February 2010 

1 coming out of the general treasury fund is not as, has never been issued or given out to 

2 municipalities. It has only been given back to the nuclear plant that has successfully sued the 

3 government and the only use of this money is for constructing dry cask storages, okay. So that's 

4 the long and the short of it. It's only going to be used for construction of casks and it's not going 

5 to go back to the municipality that is, right where the light waste is located. So I hope that kind of 

6 gives everybody a little bit of heads up on when we are able to sue successfully sue Uncle Sam. 

7 (KPS-E) 

8 Comment: Yeah, let's just clear the issue up here. This isn't against Carlton against Dominion. 

9 Dominion is a good electrical provider and that. We need, we need power. Nuclear power is, we 

10 hope it's safe. The big problem with nuclear power is the waste issue. Dominion's good as far as 

11 civil projects and helping people out and being a good neighbor, okay. We're not against that. 

12 We want to get the issue of the, the waste solved and we just don't like to have it here, you 

13 know. (KPS-D-3) 

14 Comment: I just want to ask a question here. Do anyone of these people that they would take 

15 one of those dry casks in their village or the city of Green Bay. Or like I asked Senator Cole if I 

16 put one in his parking lot -- over in the ballpark. You know what the answer is? You know what 

17 the answer is? No, no not in my backyard. And Mr. Soletzki said the same thing. Human error. 

18 Human error is all it takes just remember that. This is what we're all worried about is that human 

19 error. Mr. Munsin said it's so safe. I told him I'll tell you what if it's that safe how about putting it 

20 in writing so I can have it recorded in the courthouse that it's good for a hundred years, so then I 

21 don't have to worry about my grandkids and my great grandkids. You know I've been here first. 

22 (KPS-B-10) 

23 Comment: I think that's what's broken in the system. You stand up there and say it's not your 

24 issue. We go to the DOE. DOE is not in control of those rods yet. They belong to Dominion. And 

25 so we're stuck with them. So who do we talk to? Dominion says they, they aren't going to settle 

26 anything with us. You said you aren't in control. The DOE says they aren't in control but now 

27 whose taking responsibility for them? (A-3) 

28 Comment: Well, I've got the CRS report here. And it's an updated one for October 9th. And 

29 Yucca Mountain might be ready by the year 2020. It says might be. But it also says that every, 

30 every nuclear plant is getting reimbursed from DOE because they're being sued so they'll get it. 

31 So this is the big thing right now is when Dominion put in for theirs there was no reason why 

32 they couldn't have put in for compensation for this because that would have been an expense 

33 for them. (KPS-J-2) 

34 Comment: I'm Steve Tadisch. I'm a resident here. And we're talking about this high level waste 

35 storage. How is that going to affect an addition to the plant or any new plants in the State or the 

36 United States? Are they going to give new licenses even though Yucca Mountain is not going to 

37 be running at the time or are they going to just prorate it kind of and -- then hope that it's 

38 running? The only thing is I was going to say it also says that those spent fuel rods have to be in 

39 the water for five years -- before it can go in the casks. (KPS-K) 

40 Comment: Okay. Ms. Lopas you said that your committee oversees the, like land use and the 

41 water and the natural resources and all that. I have a question about land use. I’m from the town 

42 of Carlton. I live about 3 miles north of the nuclear plant. The way I understand it right now the 
Appendix A 

February 2010 A-9 Draft NUREG-1437, Supplement 40 

1 utility taxes that we get from having that plant here just about equals the taxes that we would 

2 have gotten from homes that would have been built on that property. That means that in my 

3 opinion that means that nothing is gained by having the nuclear waste being stored here on this 

4 property which is what is going on right now. Above ground is the waste storage. The pools are 

5 full. So my question is what, what's going to happen when the plant closes and then the utility 

6 tax no longer applies? The waste is still going to be there. We're not getting anything for that 

7 waste. What do we have to gain by extending the license, having more and more waste being 

8 piled up there, high level waste. That's part of my concern. (KPS-A-1) 

9 Comment: I've got them all, all our officials, even the governor. They want to take the 

10 moratorium off to build a nuclear plant because it's the safest, the cleanest. Like I wrote in a 

11 letter to them when I sent them all the signatures. Where are you going to put the waste. We've 

12 stored it for 34 years under water and we finally got 50,000 and then Dominion devaluated the 

13 plant and we lost, how much? $37,000. Now you just said just a few minutes ago that they 

14 update, update, update. It's running at full capacity. How come you can devaluate it? I mean 

15 that's not your doing, but it, that's lost us $37,000. (KPS-B-3) 

16 Comment: Okay. My name is Dave Hardtke. I have a question on the financial environmental 

17 issue with this plant. If they are allowed to continue to operate we are sitting on a growing pile of 

18 nuclear waste. And when this plant shuts down, and it's going to shut down someday, I have 

19 kids and grandchildren in the area, who is going to make up the financial loss to the town when 

20 this plant shuts down because we will not be getting any money from the utility tax at that point. 

21 And we are sitting on a pile of growing waste out here and some day our kids are going to have 

22 to pay the price for it. So I am against the, the license renewal right now. (A-4) 

23 Response: The safety and environmental effects of spent fuel storage on site have been 

24 evaluated by the NRC and, as set forth in the Waste Confidence Rule (10 CFR 51.23), the NRC 

25 generically determined that such storage could be accomplished without significant 

26 environmental impacts. In the Waste Confidence Rule, the Commission determined that spent 

27 fuel can be safely stored onsite for at least 30 years beyond the plant’s life, including license 

28 renewal. Onsite spent fuel storage is considered a Category 1 issue, which was evaluated in the 

29 GEIS, NUREG-1437; therefore, accidents would be included within the analysis of the Category 

30 1 issue of onsite spent fuel storage. The GEIS is based upon the assumption that storage of the 

31 spent fuel onsite is not permanent. The GEIS considered a variety of spent fuel and waste 

32 storage scenarios, including onsite storage of these materials for up to 30 years following 

33 expiration of the operating license, transfer of these materials to a different plant, and transfer of 

34 these materials to an independent spent fuel storage installation (ISFSI). For each potential 

35 scenario, the GEIS determined that existing regulatory requirements, operating practices, and 

36 radiological monitoring programs were sufficient to ensure that impacts resulting from spent fuel 

37 and waste storage practices would be SMALL, and therefore were a Category 1 issue. 

38 Furthermore, requirements for dry cask storage are outside the scope of license renewal. 

39 During dry cask storage, spent nuclear fuel must be "encased" in NRC-approved casks. An 

40 NRC-approved cask is one that has undergone a technical review of its safety aspects and 

41 been found to meet all of the NRC's requirements. These requirements are specified in 10 CFR 

42 Part 72. The comments provide no new and significant information and, therefore, will not be 

43 evaluated further. 
Appendix A 

Draft NUREG-1437, Supplement 40 A-10 February 2010 

1 A.2. References 

2 U.S. Nuclear Regulatory Commission (NRC). 2008a: “Summary of Public License Renewal 

3 Overview and Environmental Scoping Meetings related to the review of the Kewaunee Power 

4 Station (KPS) license renewal application submitted by Dominion Energy Kewaunee, Inc,” 

5 November 17, 2008. ADAMS Accession No. ML083090452. 

6 U.S. Nuclear Regulatory Commission (NRC). 2009a. “Issuance of Environmental Scoping 

7 Summary Report Associated with the Staff’s Review of the Application by Dominion Energy 

8 Kewaunee, Inc., for Renewal of the Operating License for Kewaunee Power Station,” April 6, 

9 2009. ADAMS Accession No. ML090770880. 
February 2010 Draft NUREG-1437, Supplement 40 

APPENDIX B 

NATIONAL ENVIRONMENTAL POLICY ACT ISSUES FOR 

LICENSE RENEWAL OF NUCLEAR POWER PLANTS

February 2010 B-1 Draft NUREG-1437, Supplement 40 

1 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 

4 B, Subpart A, to Title 40 of the Code of Federal Regulations (CFR) Part 51. Data supporting this 

5 table are contained in NUREG-1437, Generic Environmental Impact Statement for License 

6 Renewal of Nuclear Plants. 

Issue Type of Issue Finding 

Surface Water Quality, Hydrology, and Use 

Impacts of 

refurbishment on 

surface water quality 

Generic 

SMALL. Impacts are expected to be negligible during 

refurbishment because best management practices are 

expected to be employed to control soil erosion and spills. 

Impacts of 

refurbishment on 

surface water use 

Generic SMALL. Water use during refurbishment will not increase 

appreciably or will be reduced during plant outage. 

Altered current 

patterns at intake and 

discharge structures 

Generic 

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

problem at operating nuclear power plants and are not expected 

to be a problem during the license renewal term. 

Altered salinity 

gradients Generic 

SMALL. Salinity gradients have not been found to be a problem 

at operating nuclear power plants and are not expected to be a 

problem during the license renewal term. 

Altered thermal 

stratification of lakes Generic 

SMALL. Generally, lake stratification has not been found to be a 

problem at operating nuclear power plants and is not expected 

to be a problem during the license renewal term. 

Temperature effects 

on sediment transport 

capacity 

Generic 

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

operating nuclear power plants and are not expected to be a 

problem during the license renewal term. 

Scouring caused by 

discharged cooling 

water 

Generic 

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

operating nuclear power plants and has caused only localized 

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

the license renewal term. 

Eutrophication Generic 

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

operating nuclear power plants and is not expected to be a 

problem during the license renewal term. 

Discharge of chlorine 

or other biocides Generic 

SMALL. Effects are not a concern among regulatory and 

resource agencies, and are not expected to be a problem during 

the license renewal term. 

Discharge of sanitary 

wastes and minor 

chemical spills 

Generic 

SMALL. Effects are readily controlled through National Pollutant 

Discharge Elimination System (NPDES) permit and periodic 

modifications, if needed, and are not expected to be a problem 

during the license renewal term. 
Appendix B 

Draft NUREG-1437, Supplement 40 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 make-up 

water from a small 

river with low flow) 

Site-specific 

SMALL OR MODERATE. The issue has been a concern at 

nuclear power plants with cooling ponds and at plants with 

cooling towers. Impacts on instream and riparian communities 

near these plants could be of moderate significance in some 

situations. See § 51.53(c)(3)(ii)(A). 

Aquatic Ecology 

Refurbishment Generic 

SMALL. During plant shutdown and refurbishment there will be 

negligible effects on aquatic biota because of a reduction of 

entrainment and impingement of organisms or a reduced 

release of chemicals. 

Accumulation of 

contaminants in 

sediments or biota 

Generic 

SMALL. Accumulation of contaminants has been a concern at a 

few nuclear power plants but has been satisfactorily mitigated 

by replacing copper alloy condenser tubes with those of another 

metal. It is not expected to be a problem during the license 

renewal term. 

Entrainment of 

phytoplankton and 

zooplankton 

Generic 

SMALL. Entrainment of phytoplankton and zooplankton has not 

been found to be a problem at operating nuclear power plants 

and is not expected to be a problem during the license renewal 

term. 

Cold shock Generic 

SMALL. Cold shock has been satisfactorily mitigated at 

operating nuclear plants with once-through cooling systems, 

has not endangered fish populations or been found to be a 

problem at operating nuclear power plants with cooling towers 

or cooling ponds, and is not expected to be a problem during 

the license renewal term. 

Thermal plume barrier 

to migrating fish Generic 

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

at operating nuclear power plants and are not expected to be a 

problem during the license renewal term. 

Distribution of aquatic 

organisms Generic 

SMALL. Thermal discharge may have localized effects but is 

not expected to affect the larger geographical distribution of 

aquatic organisms. 

Premature emergence 

of aquatic insects Generic 

SMALL. Premature emergence has been found to be a 

localized effect at some operating nuclear power plants but has 

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

the license renewal term. 
Appendix B 

February 2010 B-3 Draft NUREG-1437, Supplement 40 

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. 
Appendix B 

Draft NUREG-1437, Supplement 40 B-4 February 2010 

Issue Type of Issue Finding 

Impingement of fish 

and shellfish Generic 

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

at operating nuclear power plants with this type of cooling 

system and is not expected to be a problem during the license 

renewal term. 

Heat shock Generic 

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

operating nuclear power plants with this type of cooling system 

and is not expected to be a problem during the license renewal 

term. 

Groundwater Use and Quality 

Impacts of 

refurbishment on 

groundwater use and 

quality 

Generic 

SMALL. Extensive dewatering during the original construction 

on some sites will not be repeated during refurbishment on any 

sites. Any plant wastes produced during refurbishment will be 

handled in the same manner as in current operating practices 

and are not expected to be a problem during the license 

renewal term. 

Groundwater use 

conflicts (potable 

and service water; 

plants that use 

<100 gpm) 

Generic SMALL. Plants using less than 100 gallons per minute (gpm) 

are not expected to cause any ground-water use conflicts. 

Groundwater use 

conflicts (potable and 

service water, and 

dewatering plants that 

use >100 gpm) 

Site-specific 

SMALL, MODERATE, OR LARGE. Plants that use more than 

100 gpm may cause ground-water use conflicts with nearby 

ground-water users. See § 51.53(c)(3)(ii)(C). 

Groundwater use 

conflicts (plants using 

cooling towers 

withdrawing makeup 

water from a small 

river) 

Site-specific 

SMALL, MODERATE, OR LARGE. Water use conflicts may 

result from surface water withdrawals from small water bodies 

during low flow conditions which may affect aquifer recharge, 

especially if other groundwater or upstream surface water users 

come on line before the time of license renewal. See § 

51.53(c)(3)(ii)(A). 

Groundwater use 

conflicts (Ranney 

wells) 

Site-specific 

SMALL, MODERATE, OR LARGE. Ranney wells can result in 

potential ground-water depression beyond the site boundary. 

Impacts of large ground-water withdrawal for cooling tower 

makeup at nuclear power plants using Ranney wells must be 

evaluated at the time of application for license renewal. See § 

51.53(c)(3)(ii)(C). 

Groundwater quality 

degradation (Ranney 

wells) 

Generic 

SMALL. Ground-water quality at river sites may be degraded by 

induced infiltration of poor-quality river water into an aquifer that 

supplies large quantities of reactor cooling water. However, the 

lower quality infiltrating water would not preclude the current 

uses of groundwater and is not expected to be a problem during 

the license renewal term. 
Appendix B 

February 2010 B-5 Draft NUREG-1437, Supplement 40 

Issue Type of Issue Finding 

Groundwater quality 

degradation (saltwater 

intrusion) 

Generic SMALL. Nuclear power plants do not contribute significantly to 

saltwater intrusion. 

Groundwater quality 

degradation (cooling 

ponds in salt 

marshes) 

Generic 

SMALL. Sites with closed-cycle cooling ponds may degrade 

ground-water quality. Because water in salt marshes is 

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

Groundwater quality 

degradation (cooling 

ponds at inland sites) 

Site-specific 

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

cooling ponds may degrade ground-water quality. For plants 

located inland, the quality of the groundwater in the vicinity of 

the ponds must be shown to be adequate to allow continuation 

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

Terrestrial Ecology 

Refurbishment 

impacts Site-specific 

SMALL, MODERATE, OR LARGE. Refurbishment impacts are 

insignificant if no loss of important plant and animal habitat 

occurs. However, it cannot be known whether important plant 

and animal communities may be affected until the specific 

proposal is presented with the license renewal application. See 

§ 51.53(c)(3)(ii)(E). 

Cooling tower impacts 

on crops and 

ornamental vegetation 

Generic 

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

humidity associated with cooling tower operation have not been 

found to be a problem at operating nuclear power plants and 

are not expected to be a problem during the license renewal 

term. 

Cooling tower impacts 

on native plants Generic 

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

humidity associated with cooling tower operation have not been 

found to be a problem at operating nuclear power plants and 

are not expected to be a problem during the license renewal 

term. 

Bird collisions with 

cooling towers Generic 

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

at operating nuclear power plants and are not expected to be a 

problem during the license renewal term. 

Cooling pond impacts 

on terrestrial 

resources 

Generic SMALL. Impacts of cooling ponds on terrestrial ecological 

resources are considered to be of small significance at all sites. 

Power line right of 

way management 

(cutting and herbicide 

application) 

Generic SMALL. The impacts of right of way (ROW) maintenance on 

wildlife are expected to be of small significance at all sites. 

Bird collisions with 

power lines Generic SMALL. Impacts are expected to be of small significance at all sites. 
Appendix B 

Draft NUREG-1437, Supplement 40 B-6 February 2010 

Issue Type of Issue Finding 

Impacts of 

electromagnetic fields 

on flora and fauna 

Generic 

SMALL. No significant impacts of electromagnetic fields on 

terrestrial flora and fauna have been identified. Such effects are 

not expected to be a problem during the license renewal term. 

Floodplains and 

wetland on power line 

ROW 

Generic 

SMALL. Periodic vegetation control is necessary in forested 

wetlands underneath power lines and can be achieved with 

minimal damage to the wetland. No significant impact is 

expected at any nuclear power plant during the license renewal 

term. 

Threatened and Endangered Species 

Threatened or 

endangered species Site-specific 

SMALL, MODERATE, OR LARGE. Generally, plant 

refurbishment and continued operation are not expected to 

adversely affect threatened or endangered species. However, 

consultation with appropriate agencies would be needed at the 

time of license renewal to determine whether threatened or 

endangered species are present and whether they would be 

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

Air Quality 

Air quality during 

refurbishment (nonattainment and 

maintenance areas) 

Site-specific 

SMALL, MODERATE, OR LARGE. Air quality impacts from 

plant refurbishment associated with license renewal are 

expected to be small. However, vehicle exhaust emissions 

could be cause for concern at locations in or near 

nonattainment or maintenance areas. The significance of the 

potential impact cannot be determined without considering the 

compliance status of each site and the numbers of workers 

expected to be employed during the outage. See § 

51.53(c)(3)(ii)(F). 

Air quality effects of 

transmission lines Generic 

SMALL. Production of ozone and oxides of nitrogen is 

insignificant and does not contribute measurably to ambient 

levels of these gases. 

Land Use 

Onsite land use Generic 

SMALL. Projected onsite land use changes required during 

refurbishment and the renewal period would be a small fraction 

of any nuclear power plant site and would involve land that is 

controlled by the applicant. 

Power line ROW Generic 

SMALL. Ongoing use of power line ROWs would continue with 

no change in restrictions. The effects of these restrictions are of 

small significance. 

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. 
Appendix B 

February 2010 B-7 Draft NUREG-1437, Supplement 40 

Issue Type of Issue Finding 

Occupational radiation 

exposures during 

refurbishment 

Generic 

SMALL. Occupational doses from refurbishment are expected 

to be within the range of annual average collective doses 

experienced for pressurized-water reactors and boiling-water 

reactors. Occupational mortality risk from all causes including 

radiation is in the mid-range for industrial settings. 

Microbiological 

organisms 

(occupational health) 

Generic 

SMALL. Occupational health impacts are expected to be 

controlled by continued application of accepted industrial 

hygiene practices to minimize worker exposures. 

Microbiological 

organisms (public 

health)(plants using 

lakes or canals, or 

cooling towers or 

cooling ponds that 

discharge to a small 

river) 

Site-specific 

SMALL, MODERATE, OR LARGE. These organisms are not 

expected to be a problem at most operating plants except 

possibly at plants using cooling ponds, lakes, or canals that 

discharge to small rivers. Without site-specific data, it is not 

possible to predict the effects generically. See § 

51.53(c)(3)(ii)(G). 

Noise Generic 

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

plants and is not expected to be a problem at any plant during 

the license renewal term. 

Electromagnetic 

fields—acute effects 

(electric shock) 

Site-specific 

SMALL, MODERATE, OR LARGE. Electrical shock resulting 

from direct access to energized conductors or from induced 

charges in metallic structures have not been found to be a 

problem at most operating plants and generally are not 

expected to be a problem during the license renewal term. 

However, site-specific review is required to determine the 

significance of the electric shock potential at the site. See § 

51.53(c)(3)(ii)(H). 

Electromagnetic 

fields—chronic effects Uncategorized 

UNCERTAIN. Biological and physical studies of 60-Hz 

electromagnetic fields have not found consistent evidence 

linking harmful effects with field exposures. However, research 

is continuing in this area and a consensus scientific view has 

not been reached. 

Radiation exposures 

to public (license 

renewal term) 

Generic SMALL. Radiation doses to the public will continue at current 

levels associated with normal operations. 

Occupational radiation 

exposures (license 

renewal term) 

Generic 

SMALL. Projected maximum occupational doses during the 

license renewal term are within the range of doses experienced 

during normal operations and normal maintenance outages, and 

would be well below regulatory limits. 

Socioeconomic Impacts 
Appendix B 

Draft NUREG-1437, Supplement 40 B-8 February 2010 

Issue Type of Issue Finding 

Housing impacts Site-specific 

SMALL, MODERATE, OR LARGE. Housing impacts are 

expected to be of small significance at plants located in a 

medium or high population area and not in an area where 

growth control measures that limit housing development are in 

effect. Moderate or large housing impacts of the workforce 

associated with refurbishment may be associated with plants 

located in sparsely populated areas or in areas with growth 

control measures that limit housing development. See § 

51.53(c)(3)(ii)(I). 

Public services: public 

safety, social 

services, and tourism, 

and recreation 

Generic 

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

and recreation are expected to be of small significance at all 

sites. 

Public services: public 

utilities Site-specific 

SMALL OR MODERATE. An increased problem with water 

shortages at some sites may lead to impacts of moderate 

significance on public water supply availability. See § 

51.53(c)(3)(ii)(I). 

Public services: 

education 

(refurbishment) 

Site-specific 

SMALL, MODERATE, OR LARGE. Most sites would experience 

impacts of small significance but larger impacts are possible 

depending on site- and project-specific factors. See § 

51.53(c)(3)(ii)(I). 

Public services: 

education (license 

renewal term) 

Generic SMALL. Only impacts of small significance are expected 

Offsite land use 

(refurbishment) Site-specific 

SMALL OR MODERATE. Impacts may be of moderate 

significance at plants in low population areas. See § 

51.53(c)(3)(ii)(I). 

Offsite land use 

(license renewal term) Site-specific 

SMALL, MODERATE, OR LARGE. Significant changes in land 

use may be associated with population and tax revenue 

changes resulting from license renewal. See § 51.53(c)(3)(ii)(I). 

Public services: 

transportation Site-specific 

SMALL, MODERATE, OR LARGE. Transportation impacts 

(level of service) of highway traffic generated during plant 

refurbishment and during the term of the renewed license are 

generally expected to be of small significance. However, the 

increase in traffic associated with the additional workers and the 

local road and traffic control conditions may lead to impacts of 

moderate or large significance at some sites. See § 

51.53(c)(3)(ii)(J). 

Historic and 

archaeological 

resources 

Site-specific 

SMALL, MODERATE, OR LARGE. Generally, plant 

refurbishment and continued operation are expected to have no 

more than small adverse impacts on historic and archaeological 

resources. However, the National Historic Preservation Act 

requires the Federal agency to consult with the State Historic 

Preservation Officer to determine whether there are properties 

present that require protection. See § 51.53(c)(3)(ii)(K). 

Aesthetic impacts 

(refurbishment) Generic SMALL. No significant impacts are expected during refurbishment. 
Appendix B 

February 2010 B-9 Draft NUREG-1437, Supplement 40 

Issue Type of Issue Finding 

Aesthetic impacts 

(license renewal term) Generic SMALL. No significant impacts are expected during the license renewal term. 

Aesthetic impacts of 

transmission lines 

(license renewal term) 

Generic SMALL. No significant impacts are expected during the license 

renewal term. 

Postulated Accidents 

Design basis 

accidents Generic 

SMALL. The Nuclear Regulatory Commission (NRC) staff has 

concluded that the environmental impacts of design basis 

accidents are of small significance for all plants. 

Severe accidents Site-specific 

SMALL. The probability weighted consequences of atmospheric 

releases, fallout onto open bodies of water, releases to 

groundwater, and societal and economic impacts from severe 

accidents are small for all plants. However, alternatives to 

mitigate severe accidents must be considered for all plants that 

have not considered such alternatives. See § 51.53(c)(3)(ii)(L). 

Uranium Fuel Cycle and Waste Management 

Offsite radiological 

impacts (individual 

effects from other 

than the disposal of 

spent fuel and high 

level waste) 

Generic 

SMALL. Off-site impacts of the uranium fuel cycle have been 

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

on information in the Generic Environmental Impact Statement 

(GEIS), impacts on individuals from radioactive gaseous and 

liquid releases including radon-222 and technetium-99 are 

small. 
Appendix B 

Draft NUREG-1437, Supplement 40 B-10 February 2010 

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 

roentgen equivalent man (rem), or 12 cancer fatalities, for each 

additional 20-year power reactor operating term. Much of this, 

especially the contribution of radon releases from mines and 

tailing piles, consists of tiny doses summed over large 

populations. This same dose calculation can theoretically be 

extended to include many tiny doses over additional thousands 

of years as well as doses outside the U.S. The result of such a 

calculation would be thousands of cancer fatalities from the fuel 

cycle, but this result assumes that even tiny doses have some 

statistical adverse health effect, which will not ever be mitigated 

(for example no cancer cure in the next thousand years), and 

that these doses projected over thousands of years are 

meaningful. However, these assumptions are questionable. In 

particular, science cannot rule out the possibility that there will 

be no cancer fatalities from these tiny doses. For perspective, 

the doses are very small fractions of regulatory limits, and even 

smaller fractions of natural background exposure to the same 

populations. 

Nevertheless, despite all the uncertainty, some judgment as to 

the regulatory NEPA implications of these matters should be 

made and it makes no sense to repeat the same judgment in 

every case. Even taking the uncertainties into account, the 

Commission concludes that these impacts are acceptable in 

that these impacts would not be sufficiently large to require the 

NEPA conclusion, for any plant, that the option of extended 

operation under 10 CFR Part 54 should be eliminated. 

Accordingly, while the commission has not assigned a single 

level of significance for the collective effects of the fuel cycle, 

this issue is considered Category 1 [Generic]. 
Appendix B 

February 2010 B-11 Draft NUREG-1437, Supplement 40 

Issue Type of Issue Finding 

Offsite radiological 

impacts (spent fuel 

and high level waste 

disposal) 

Generic 

For the high level waste and spent fuel disposal component of 

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

releases of radionuclides for the current candidate repository 

site. However, if we assume that limits are developed along the 

lines of the 1995 National Academy of Sciences (NAS) report, 

"Technical Bases for Yucca Mountain Standards," and that in 

accordance with the Commission's Waste Confidence Decision, 

10 CFR 51.23, a repository can and likely will be developed at 

some site, which will comply with such limits, peak doses to 

virtually all individuals will be 100 millirem per year or less. 

However, while the Commission has reasonable confidence that 

these assumptions will prove correct, there is considerable 

uncertainty since the limits are yet to be developed, no 

repository application has been completed or reviewed, and 

uncertainty is inherent in the models used to evaluate possible 

pathways to the human environment. The NAS report indicated 

that 100 millirem per year should be considered as a starting 

point for limits for individual doses, but notes that some 

measure of consensus exists among national and international 

bodies that the limits should be a fraction of the 100 millirem per 

year. The lifetime individual risk from 100 millirem annual dose 

limit is about 3 x 10-3. 

Estimating cumulative doses to populations over thousands of 

years is more problematic. The likelihood and consequences of 

events that could seriously compromise the integrity of a deep 

geologic repository were evaluated by the Department of 

Energy in the "Final Environmental Impact Statement: 

Management of Commercially Generated Radioactive Waste," 

October 1980. The evaluation estimated the 70-year 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, EPA's 

generic repository standards in 40 CFR Part 191 generally 

provide an indication of the order of magnitude of cumulative 

risk to population that could result from the licensing of a Yucca 

Mountain repository, assuming the ultimate standards will be 

within the range of standards now under consideration. The 

standards in 40 CFR Part 191 protect the population by 

imposing amount of radioactive material released over 10,000 

years. (continued) 
Appendix B 

Draft NUREG-1437, Supplement 40 B-12 February 2010 

Issue Type of Issue Finding 

Offsite radiological 

impacts (spent fuel 

and high level waste 

disposal) (continued) 

Generic 

The cumulative release limits are based on EPA's population 

impact goal of 1,000 premature cancer deaths worldwide for a 

100,000 metric ton (MTHM) repository. 

Nevertheless, despite all the uncertainty, some judgment as to 

the regulatory NEPA implications of these matters should be 

made and it makes no sense to repeat the same judgment in 

every case. Even taking the uncertainties into account, the 

Commission concludes that these impacts are acceptable in 

that these impacts would not be sufficiently large to require the 

NEPA conclusion, for any plant, that the option of extended 

operation under 10 CFR Part 54 should be eliminated. 

Accordingly, while the Commission has not assigned a single 

level of significance for the impacts of spent fuel and high level 

waste disposal, this issue is considered in Category 1 [Generic]. 

Nonradiological 

impacts of the 

uranium fuel cycle 

Generic 

SMALL. The nonradiological impacts of the uranium fuel cycle 

resulting from the renewal of an operating license for any plant 

are found to be small. 

Low-level waste 

storage and disposal Generic 

SMALL. The comprehensive regulatory controls that are in 

place and the low public doses being achieved at reactors 

ensure that the radiological impacts to the environment will 

remain small during the term of a renewed license. The 

maximum additional onsite land that may be required for lowlevel 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 longterm disposal of low-level waste from any individual plant at 

licensed sites are small. In addition, the Commission concludes 

that there is reasonable assurance that sufficient low-level 

waste disposal capacity will be made available when needed for 

facilities to be decommissioned consistent with NRC 

decommissioning requirements. 

Mixed waste storage 

and disposal Generic 

SMALL. The comprehensive regulatory controls and the 

facilities and procedures that are in place ensure proper 

handling and storage, as well as negligible doses and exposure 

to toxic materials for the public and the environment at all 

plants. License renewal will not increase the small, continuing 

risk to human health and the environment posed by mixed 

waste at all plants. The radiological and nonradiological 

environmental impacts of long-term disposal of mixed waste 

from any individual plant at licensed sites are small. In addition, 

the Commission concludes that there is reasonable assurance 

that sufficient mixed waste disposal capacity will be made 

available when needed for facilities to be decommissioned 

consistent with NRC decommissioning requirements. 

Onsite spent fuel Generic 

SMALL. The expected increase in the volume of spent fuel from 

an additional 20 years of operation can be safely 

accommodated onsite with small environmental effects through 

dry or pool storage at all plants. if a permanent repository or 

monitored retrievable storage is not available. 
Appendix B 

February 2010 B-13 Draft NUREG-1437, Supplement 40 

Issue Type of Issue Finding 

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 of uranium (MWd/MTU) and the cumulative 

impacts of transporting high-level waste to a single repository, 

such as Yucca Mountain, Nevada, are found to be consistent 

with the impact values contained in 10 CFR 51.52(c), Summary 

Table S–4 – Environmental Impact of Transportation of Fuel 

and Waste to and from One Light-Water-Cooled Nuclear Power 

Reactor. If fuel enrichment or burnup conditions are not met, the 

applicant must submit an assessment of the implications for the 

environmental impact values reported in § 51.52. 

Decommissioning 

Radiation doses Generic 

SMALL. Doses to the public will be well below applicable 

regulatory standards regardless of which decommissioning 

method is used. Occupational doses would increase no more 

than 1 man-rem caused by buildup of long-lived radionuclides 

during the license renewal term. 

Waste management Generic 

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

renewal period would generate no more solid wastes than at the 

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

Class C or greater than Class C wastes would be expected. 

Air quality Generic 

SMALL. Air quality impacts of decommissioning are expected to 

be negligible either at the end of the current operating term or at 

the end of the license renewal term. 

Water quality Generic 

SMALL. The potential for significant water quality impacts from 

erosion or spills is no greater whether decommissioning occurs 

after a 20-year license renewal period or after the original 40-

year operation period, and measures are readily available to 

avoid such impacts. 

Ecological resources Generic 

SMALL. Decommissioning after either the initial operating 

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

to have any direct ecological impacts. 

Socioeconomic 

impacts Generic 

SMALL. Decommissioning would have some short-term 

socioeconomic impacts. The impacts would not be increased by 

delaying decommissioning until the end of a 20-year relicense 

period, but they might be decreased by population and 

economic growth. 

Environmental Justice 
Appendix B 

Draft NUREG-1437, Supplement 40 B-14 February 2010 

Issue Type of Issue Finding 

Environmental Justice Uncategorized 

NONE. The need for and the content of an analysis of 

environmental justice will be addressed in plant-specific 

reviews. 

1 References 

2 40 CFR Part 51. Code of Federal Regulations, Title 40, Protection of Environment, Part 51, 

3 “Environmental Protection Regulations for Domestic Licensing and Related Regulatory 

4 Functions.” 

5 Department of Energy (DOE). 1980. "Final Environmental Impact Statement: Management of 

6 Commercially Generated Radioactive Waste," October 1980. 

7 National Academy of Sciences (NAS) report, "Technical Bases for Yucca Mountain Standards," 

8 and that in accordance with the Commission's Waste Confidence Decision, 10 CFR 51.23.
 

February 2010 Draft NUREG-1437, Supplement 40 

APPENDIX C 

APPLICABLE REGULATIONS, LAWS, AND AGREEMENTS

Appendix C 

February 2010 C-1 Draft NUREG-1437, Supplement 40 

1 APPLICABLE REGULATIONS, LAWS, AND AGREEMENTS 

2 The Atomic Energy Act authorizes States to establish programs to assume U.S. Nuclear 

3 Regulatory Commission (NRC) regulatory authority for certain activities. For example, through 

4 the Agreement State Program, started on August 11, 2003, Wisconsin assumed regulatory 

5 responsibility over certain byproduct, source, and small quantities of special nuclear material. 

6 The Wisconsin Department of Natural Resources (WDNR) is responsible for implementing the 

7 laws of the state and where applicable, the laws of the federal government. 

8 In addition to implementing some Federal programs, State legislatures develop their own laws. 

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

10 and groundwater. State legislation may address solid waste management programs, locally rare 

11 or endangered species, and historic and cultural resources. 

12 The Clean Water Act (CWA) allows for primary enforcement and administration through State 

13 agencies, provided the State program is at least as stringent as the Federal program and must 

14 conform to the CWA and delegation of authority for the Federal national pollutant discharge 

15 elimination system (NPDES) program from the EPA to the state. The primary mechanism to 

16 control water pollution is the requirement that direct dischargers to obtain an NPDES permit or 

17 in the case of states where the authority has been delegated from the EPA, a SPDES permit, 

18 pursuant to the CWA. 

19 One important difference between Federal regulations and certain State regulations is the 

20 definition of waters regulated by the State. Certain State regulations may include underground 

21 waters while the CWA only regulates surface waters. 

22 State Environmental Requirements 

23 Certain environmental requirements, including some discussed earlier, may have been 

24 delegated to State authorities for implementation, enforcement, or oversight. Table C-1 provides 

25 a list of representative State environmental requirements that may affect license renewal 

26 applications for nuclear power plants. 
Appendix C 

Draft NUREG-1437, Supplement 40 C-2 February 2010 

1 Table C-1. State Environmental Requirements. Kewaunee Power Station (KPS) is subject to 

2 State requirements regarding their environmental program. Those requirements are briefly 

3 described below. See Section 1.9 for KPS’s compliance status with these requirements. 

Law/Regulation Requirements 

Air Quality Protection 

Federal Clean Air Act (42 USC 

7401 et seq.), Ch. 285 

Wisconsin Statutes 

Operation permit is required for air emissions and is issued by WDNR. Note: 

Dominion Energy Kewaunee (DEK) is considering conversion of this permit to a 

“Type A Registration Operation Permit,” Air Pollution Control Permit Number ROPA01, issued by the WDNR. 

Water Resources Protection 

Clean Water Act (CWA) (33 

USC 1251 et seq.), Ch. 283 

Wisconsin Statutes 

The NPDES permit is required for plant industrial, sanitary, and stormwater 

discharges to Lake Michigan and the unnamed tributary. The NPDES permit requires 

the compliance of each point source with authorized discharge levels, monitoring 

requirements, and other appropriate requirements. The WDNR is the responsible 

State agency for NPDES permitting. 

CWA, Ch. 281 Wisconsin 

Statutes 

Permit to construct and operate sanitary sewage treatment system. 

CWA (33 USC 1251 et seq.), 

Ch. 283 Wisconsin Statutes 

General Wisconsin Pollutant Discharge Elimination System (WPDES) industrial 

storm water discharge permit for storm water runoff from industrial facilities. 

CWA, Chs. 280 and 281 

Wisconsin Statutes 

Registration for non-transient non-community water supply for KPS. 

WDNR, Ch. 283 Wisconsin 

Statutes 

Permit for construction of water intake and discharge structures in Lake Michigan for 

KPS’s cooling water system. 

U.S. Army Corps of Engineers, 

33 USC 403 

Permit for construction of water intake and discharge structures in Lake Michigan for 

KPS’s cooling water system. 

WDRN, Ch. 281 Wisconsin 

Statutes 

High-capacity well approval for wells with combined capacity >100,000 gallons per 

day (gpd). 

Wisconsin Department of 

Commerce (WDC), Ch. 101.09 

Wisconsin Statutes 

Registration for aboveground storage tanks. 

Federal Resource 

Conservation and Recovery 

Act (42 USC 6901 et seq.), 

Ch. 101.09 Wisconsin Statutes 

Registration for underground storage tanks. 

Waste Management 

CWA, Ch. 281 Wisconsin 

Statutes 

Permit to construct and operate sanitary sewage treatment system. 

CWA, Ch. 283 Wisconsin 

Statutes 

A land spreading of Wastewater Treatment Facility pretreatment sludge permit is 

required by the WPDES. 

4 Operating Permits and Other Requirements 

5 Several operating permit applications may be prepared and submitted, and regulator approval 

6 and permits would be received prior to license renewal approval by the NRC. Table C-2 lists 

7 representative Federal, State, and local permits. 
 Appendix C 

February 2010 C-3 Draft NUREG-1437, Supplement 40 

1 Table C-2. Federal, State, and Local Permits and Other Requirements. KPS is subject to 

2 other requirements regarding various aspects of their environmental program. Those 

3 requirements are briefly described below.

License, Permit, or Other Required 

Approval 

Responsible 

Agency Authority Relevance and Status 

Waste Management and Pollution Prevention 

Transportation of radioactive waste to 

disposal facility in South Carolina. 

South Carolina 

Department of 

Health and 

Environment 

Control 

South Carolina 

Radioactive 

Waste 

Transportation 

and Disposal Act 

(S.C. Code of 

Laws 13-7-110 et 

seq.) 

KPS is a radioactive waste 

generator. The radioactive waste is 

sent to disposal facility in South 

Carolina. 

License to ship radioactive material to 

processing facility in Tennessee. 

Tennessee 

Department of 

Environment and 

Conservation 

Tennessee Code 

Annotated 68- 

202-206 

KPS radioactive material is 

shipped to processing facility in 

Tennessee. 

Site access permit for disposal of 

radioactive material in Utah. 

Utah Department 

of Environmental 

Quality 

R313-26 of Utah 

Radiation Control 

Rules 

KPS radioactive material is 

disposed in Utah in land disposal 

site. 

Emergency Planning and Response 

Shipment of hazardous materials. U.S. Department of 

Transportation 

(DOT) 

KPS hazardous 

materials 

shipments 

registration 

062706 552 

0750Q 

KPS hazardous materials 

shipments to comply with DOT 

packing, labeling, and routing 

requirements. 

Biotic Resource Protection 

Threatened and Endangered Species 

Consultation: Required between the 

responsible Federal agencies and 

affected States to ensure that the 

project is not likely to: (1) jeopardize 

the continued existence of any species 

listed at the Federal or State level as 

endangered or threatened; or (2) 

result in destruction of critical habitat 

of such species. 

WDNR 

Endangered 

Resources Review 

Endangered and 

Threatened 

Species Laws 

(State Statute 

29.604 & 

Administrative 

Rule NR 27) 

Review explains what rare 

species, natural communities, or 

natural features tracked in the 

Natural Heritage Inventory 

database are found in or near the 

proposed project area. Includes 

any additional steps to assure 

compliance with the Wisconsin 

Endangered Species Law. 

Threatened and Endangered Species 

Consultation: Required between the 

responsible Federal agencies and 

affected States to ensure that the 

project is not likely to: (1) jeopardize 

the continued existence of any species 

listed at the Federal or State level as 

endangered or threatened; or, (2) 

result in destruction of critical habitat 

of such species. 

U.S. Fish and 

Wildlife Service 

(USFWS) 

Endangered 

Species Act, 

Section 7 (16 

USC 1536) 

NRC consulted with USFWS. The 

Federal agency issuing a license is 

required to consult with USFWS 

regarding the impact of license 

renewal on threatened or 

endangered species or their critical 

habitat. 

State must concur with the DEK’s 

request for certification of KPS license 

renewal. 

Wisconsin 

Department of 

Administration 

Federal Coastal 

Zone 

Management Act 

(16 USC 1451 et 

seq.) 

Requires applicant to provide 

certification to the NRC that the 

license renewal would be 

consistent with the federally 

approved state coastal zone 
Appendix C 

Draft NUREG-1437, Supplement 40 C-4 February 2010 

License, Permit, or Other Required 

Approval 

Responsible 

Agency Authority Relevance and Status 

management program. 

Cultural Resources Protection 

Archaeological and Historical 

Resources Consultation: Required 

before a Federal agency approves a 

project in an area where 

archaeological or historic resources 

might be located. 

Wisconsin 

Historical 

Society 

National Historic 

Preservation Act, 

Section 106 (16 

USC 470f) 

NRC consulted with State, Tribal 

Historic Preservation Officers, and 

Indian Tribes representatives 

regarding impacts of license 

renewal. Federal agency issuing a 

license is required to consider 

cultural impacts and consult with 

State Historic Preservation Officer. 
 

February 2010 Draft NUREG-1437, Supplement 40 

1 APPENDIX D 

2 CONSULTATION CORRESPONDENCES

Appendix D 

February 2010 D-1 Draft NUREG-1437, Supplement 40 

1 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. Consultation Correspondences. The following is a list of the consultation 

9 documents sent between the U.S. Nuclear Regulatory Commission (NRC) and other agencies 

10 in accordance with National Environmental Policy Act (NEPA) requirements. 

Author Recipient Date of Letter 

U.S. Nuclear Regulatory Commission 

(D. Pelton) 

U.S. Fish and Wildlife Service 

(L. Clemency) 

September 30, 2008 

U.S. Nuclear Regulatory Commission 

(D. Pelton) Advisory Council on Historic Preservation 

(D. Klima) 

October 8, 2008 

U.S. Nuclear Regulatory Commission 

(D. Pelton) 

Wisconsin Historical Society 

(S. Baker) 

October 10, 2008 

U.S. Nuclear Regulatory Commission 

(D. Petlon) 

Wisconsin Coastal Management Program 

(K. Angel) 

October 10, 2008 

U.S Nuclear Regulatory Commission 

(D. Pelton) 

Wisconsin Department of Natural 

Resources (R. Kazmierczak) 

October 10, 2008 

U.S Nuclear Regulatory Commission 

(D. Pelton) 

Menominee Indian Tribe of Wisconsin 

(L. Boivin) 

October 16, 2008(a) 

U.S. Fish and Wildlife Service 

(L. Clemency) 

U.S. Nuclear Regulatory Commission 

(D. Pelton) 

October 28, 2008 

(a) 11 Similar letters went to 23 other Native American Tribes listed in Section 1.8 and Appendix E. 

12 Consultation Correspondences 

13 The following pages contain copies of the letters listed in Table D-1. Figures contained in pages 

14 D-5 and D-6 were included with each letter. 
Appendix D 

Draft NUREG-1437, Supplement 40 D-2 February 2010 

1 
Appendix D 

February 2010 D-3 Draft NUREG-1437, Supplement 40 

1 
Appendix D 

Draft NUREG-1437, Supplement 40 D-4 February 2010 

1 
Appendix D 

February 2010 D-5 Draft NUREG-1437, Supplement 40 

1 
Appendix D 

Draft NUREG-1437, Supplement 40 D-6 February 2010 

1 
Appendix D 

February 2010 D-7 Draft NUREG-1437, Supplement 40 

1 
Appendix D 

Draft NUREG-1437, Supplement 40 D-8 February 2010 

1 
Appendix D 

February 2010 D-9 Draft NUREG-1437, Supplement 40 

1 
Appendix D 

Draft NUREG-1437, Supplement 40 D-10 February 2010 

1 
Appendix D 

February 2010 D-11 Draft NUREG-1437, Supplement 40 

1 
Appendix D 

Draft NUREG-1437, Supplement 40 D-12 February 2010 

1 
Appendix D 

February 2010 D-13 Draft NUREG-1437, Supplement 40 

1 
Appendix D 

Draft NUREG-1437, Supplement 40 D-14 February 2010 

1 
Appendix D 

February 2010 D-15 Draft NUREG-1437, Supplement 40 

1 
Appendix D 

Draft NUREG-1437, Supplement 40 D-16 February 2010 

1 
Appendix D 

February 2010 D-17 Draft NUREG-1437, Supplement 40 

1 
Appendix D 

Draft NUREG-1437, Supplement 40 D-18 February 2010 

1 
Appendix D 

February 2010 D-19 Draft NUREG-1437, Supplement 40 

1 

February 2010 Draft NUREG-1437, Supplement 40 

APPENDIX E 

CHRONOLOGY OF ENVIRONMENTAL REVIEW

February 2010 E-1 Draft NUREG-1437, Supplement 40 

1 CHRONOLOGY OF ENVIRONMENTAL REVIEW CORRESPONDENCE 

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

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

4 Kewaunee Power Station (KPS). All documents, with the exception of those containing 

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

6 Room found on the Internet at the following Web address: http://www.nrc.gov/reading-rm.html. 

7 From this site, the public can gain access to the NRC’s Agency wide Document Access and 

8 Management System (ADAMS), which provides text and image files of NRC’s public documents 

9 in ADAMS. The ADAMS accession number for each document is included below. 

10 

11 Environmental Review Correspondence 

12 August 12, 2008 Dominion Energy Kewaunee, Inc. (DEK); letter from DEK forwarding 

13 the application for renewal of operating license for Kewaunee Power 

14 Station, requesting an extension of operating license for an additional 

15 20 years. (ADAMS Accession No. ML082341020) 

16 August 25, 2008 Letter to DEK, “Receipt and Availability of the License Renewal 

17 Application for the Kewaunee Power Station.” (ADAMS Accession No. 

18 ML082120504) 

19 August 29, 2008 Dominion Energy Kewaunee, Inc., “Notice of U.S Nuclear Regulatory 

20 Commission (D. Pelton) Receipt and Availability of Application for 

21 Renewal of Kewaunee Power Station, Facility Operating License No. 

22 DPR-43 for an Additional 20-Year Period” (73 FR 51023), Federal 

23 Register, August 29, 2008. 

24 September 2, 2008 NRC press release “announcing the availability of the license renewal 

25 application for Kewaunee Power Station for public inspection.” 

26 (ADAMS Accession No. ML082460767) 

27 September 25, 2008 Letter to DEK, “Determination of Acceptability and Sufficiency for 

28 Docketing, Proposed Review Schedule, and Opportunity for a Hearing 

29 Regarding an Application from Dominion Energy Kewaunee, Inc., for 

30 Renewal of the Operating License for the Kewaunee Power Station.” 

31 (ADAMS Accession No. ML082610303) 

32 September 30, 2008 Letter to Louise Clemency, U.S. Fish and Wildlife Service, “Request 

33 for List of State Protected Species within the Area under Evaluation 

34 for the Kewaunee Power Station License Renewal Application 

35 Review” (ADAMS No. ML082610748) 

36 October 1, 2008 Dominion Energy Kewaunee, Inc.; Kewaunee Power Station, “Notice 

37 of Acceptance for Docketing of the Application and Notice of 

38 Opportunity for Hearing; Regarding Renewal of Facility Operating 
Appendix E 

Draft NUREG-1437, Supplement 40 E-2 February 2010 

1 License No. DPR-43 for an Additional 20-Year Period;” (73 FR 

2 57154), Federal Register, October 1, 2008.

3 October 2, 2008 Letter to DEK, “Notice of Intent to Prepare an Environmental Impact 

4 Statement and Conduct Scoping Process for License Renewal for 

5 Kewaunee Power Station.” (ADAMS Accession No. ML082520774) 

6 October 8, 2008 Notice of public meeting “To discuss the license renewal process and 

7 environmental scoping for Kewaunee Power Station, license renewal 

8 application review.” (ADAMS Accession No. ML082750112) 

9 October 8, 2008 Letter to Don L. Klima, Advisory Council on Historic Preservation, 

10 “Kewaunee Power Station License Renewal Application Review.” 

11 (ADAMS Accession No. ML082610168) 

12 October 9, 2008 Dominion Energy Kewaunee, Inc.; Kewaunee Power Station, “Notice 

13 of Intent to Prepare an Environmental Impact Statement and Conduct 

14 Scoping Process” (73 FR 59678),” Federal Register, October 9, 2008. 

15 October 10, 2008 Letter to Kathleen Angel, Wisconsin Coastal Management Program, 

16 “Kewaunee Power Station License Renewal Application Review.” 

17 (ADAMS Accession No. ML082680027) 

18 October 10, 2008 Letter to Sherman Baker, Wisconsin Historical Society, “Kewaunee 

19 Power Station License Renewal Application Review.” (ADAMS 

20 Accession No. ML082670685) 

21 October 10, 2008 Letter to Ronald Kazmierczak, Wisconsin Department of Natural 

22 Resources, “Kewaunee Power Station License Renewal Application 

23 Review.” (ADAMS Accession No. ML082661119) 

24 October 16, 2008 Press release “announcing the Kewaunee Power Station license 

25 renewal scoping meeting.” (ADAMS Accession No. ML082900265) 

26 October 16, 2008 Letter to Terrence Virden, Bureau of Indian Affairs, “Request for 

27 Scoping Comments Concerning the Kewaunee Power Station License 

28 Renewal Application Review.” (ADAMS Accession No. ML082800098) 

29 October 16, 2008 Letter to Laurie Boivin, Menominee Indian Tribe of Wisconsin, 

30 “Request for Scoping Comments Concerning the Kewaunee Power 

31 Station License Renewal Application Review.” (ADAMS Accession 

32 No. ML082800098) 

33 October 16, 2008 Letter to Steve Ortiz, Prairie Band Potawatomi Nation, “Request for 

34 Scoping Comments Concerning the Kewaunee Power Station License 

35 Renewal Application Review.” (ADAMS Accession No. ML082800098) 
Appendix E 

February 2010 E-3 Draft NUREG-1437, Supplement 40 

1 October 16, 2008 Letter to Eugene Bigboy, Sr., Bad River Band of Lake Superior Tribe 

2 of Chippewa Indians, “Request for Scoping Comments Concerning 

3 the Kewaunee Power Station License Renewal Application Review.” 

4 (ADAMS Accession No. ML082800098) 

5 October 16, 2008 Letter to Jeffery D. Parker, Bay Mills Indian Community, “Request for 

6 Scoping Comments Concerning the Kewaunee Power Station License 

7 Renewal Application Review.” (ADAMS Accession No. ML082800098) 

8 October 16, 2008 Letter to John A. Miller, Pokagon Band of Potawatomi Indians, 

9 “Request for Scoping Comments Concerning the Kewaunee Power 

10 Station License Renewal Application Review.” (ADAMS Accession 

11 No. ML082800098) 

12 October 16, 2008 Letter to Rose Gurnoe-Soulier, Red Cliff Band of Lake Superior 

13 Chippewa Indians of Wisconsin, “Request for Scoping Comments 

14 Concerning the Kewaunee Power Station License Renewal 

15 Application Review.” (ADAMS Accession No. ML082800098) 

16 October 16, 2008 Letter to Robert Chicks, Stockbridge Munsee Community of 

17 Wisconsin, “Request for Scoping Comments Concerning the 

18 Kewaunee Power Station License Renewal Application Review.” 

19 (ADAMS Accession No. ML082800098) 

20 October 16, 2008 Darwin McCoy, Sault Ste. Marie Tribe of Chippewa Indians of 

21 Michigan, “Request for Scoping Comments Concerning the 

22 Kewaunee Power Station License Renewal Application Review.” 

23 (ADAMS Accession No. ML082800098) 

24 October 16, 2008 Hazel Hindsley, St. Croix Chippewa Indians of Wisconsin, “Request 

25 for Scoping Comments Concerning the Kewaunee Power Station 

26 License Renewal Application Review.” (ADAMS Accession No. 

27 ML082800098) 

28 October 16, 2008 Richard G. Hill, Oneida Tribe of Indians Wisconsin, “Request for 

29 Scoping Comments Concerning the Kewaunee Power Station License 

30 Renewal Application Review.” (ADAMS Accession No. ML082800098) 

31 October 16, 2008 Frank Ettawageshik, Little Traverse Bay Bands of Odawa Indians, 

32 “Request for Scoping Comments Concerning the Kewaunee Power 

33 Station License Renewal Application Review.” (ADAMS Accession 

34 No. ML082800098) 

35 October 16, 2008 Larry Romanelli, Little River Band of Ottawa Indians, “Request for 

36 Scoping Comments Concerning the Kewaunee Power Station License 

37 Renewal Application Review.” (ADAMS Accession No. ML082800098) 
Appendix E 

Draft NUREG-1437, Supplement 40 E-4 February 2010 

1 October 16, 2008 James Williams, Jr., Lac Vieux Desert Band of Lake Superior 

2 Chippewa Indians, “Request for Scoping Comments Concerning the 

3 Kewaunee Power Station License Renewal Application Review.” 

4 (ADAMS Accession No. ML082800098) 

5 October 16, 2008 Louis Taylor, Lac Courte Oreilles Band of Lake Superior Chippewa 

6 Indians of Wisconsin, “Request for Scoping Comments Concerning 

7 the Kewaunee Power Station License Renewal Application Review.” 

8 (ADAMS Accession No. ML082800098) 

9 October 16, 2008 Victoria A. Doud, Lac du Flambeau Band of Lake Superior Chippewa 

10 Indians of Wisconsin, “Request for Scoping Comments Concerning 

11 the Kewaunee Power Station License Renewal Application Review.” 

12 (ADAMS Accession No. ML082800098) 

13 October 16, 2008 Phillip Shopodock, Forest County Potawatomi Community of 

14 Wisconsin, “Request for Scoping Comments Concerning the 

15 Kewaunee Power Station License Renewal Application Review.” 

16 (ADAMS Accession No. ML082800098) 

17 October 16, 2008 Robert Kewaygoshkum, Grand Traverse Band of Ottawa and 

18 Chippewa Indians, “Request for Scoping Comments Concerning the 

19 Kewaunee Power Station License Renewal Application Review.” 

20 (ADAMS Accession No. ML082800098) 

21 October 16, 2008 Kenneth Meshigaud, Hannahville Indian Community, “Request for 

22 Scoping Comments Concerning the Kewaunee Power Station License 

23 Renewal Application Review.” (ADAMS Accession No. ML082800098) 

24 October 16, 2008 Wilfred Cleveland, Ho-Chuck Nation, “Request for Scoping Comments 

25 Concerning the Kewaunee Power Station License Renewal 

26 Application Review.” (ADAMS Accession No. ML082800098) 

27 October 16, 2008 Laura Spurr, Huron Potawatomi, Inc., “Request for Scoping 

28 Comments Concerning the Kewaunee Power Station License 

29 Renewal Application Review.” (ADAMS Accession No. ML082800098) 

30 October 16, 2008 Susan J. LaFernier, Keweenaw Bay Indian Community, “Request for 

31 Scoping Comments Concerning the Kewaunee Power Station License 

32 Renewal Application Review.” (ADAMS Accession No. ML082800098) 

33 October 16, 2008 Arlyn Ackley, Sokagon Chippewa Community, Mole Lake Band of 

34 Lake Superior Chippewa Indians, “Request for Scoping Comments 

35 Concerning the Kewaunee Power Station License Renewal 

36 Application Review.” (ADAMS Accession No. ML082800098) 
Appendix E 

February 2010 E-5 Draft NUREG-1437, Supplement 40 

1 October 16, 2008 John Barret, Citizen Potawatomi Nation, “Request for Scoping 

2 Comments Concerning the Kewaunee Power Station License 

3 Renewal Application Review.” (ADAMS Accession No. ML082800098) 

4 October 27, 2008 Letter to DEK, “Request for Additional Information Regarding the 

5 Review of the License Renewal Application for Kewaunee Power 

6 Station.” (ADAMS Accession No. ML082560558) 

7 October 28, 2008 Letter from Louise Clemency, U.S. Fish and Wildlife Service, “Re: 

8 Request for Species List License Renewal Application Review 

9 Kewaunee Power Station Kewaunee County, Wisconsin.” (ADAMS 

10 Accession No. ML083390643) 

11 November 17, 2008 Summary of Public License Renewal Overview and Environmental 

12 Scoping Meetings Related to the Review of the Kewaunee Power 

13 Station License Renewal Application. (ADAMS Accession No. 

14 ML083090452) 

15 November 25, 2008 Letter from DEK, “Dominion Energy Kewaunee, Inc. Kewaunee Power 

16 Station Response to Request for Additional Information License 

17 Renewal Application.” (ADAMS Accession No. ML083520612) 

18 December 3, 2008 Letter to DEK, “Project Manager Change for the License Renewal 

19 Review for Kewaunee Power Station.” (ADAMS Accession No. 

20 ML083370231) 

21 December 9, 2008 Letter to DEK, “Revision of Schedule for the Conduct of the Review of 

22 the Kewaunee Power Station License Renewal Application.” (ADAMS 

23 Accession No. ML083370245) 

24 January 8, 2009 “Request for Additional Information Regarding Severe Accident 

25 Mitigation Alternatives for Kewaunee Power Station.” (ADAMS 

26 Accession No. ML083250719) 

27 February 3, 2009 Summary of Conference Call with Dominion Energy Kewaunee, Inc., 

28 to Discuss the Severe Accident Mitigation Alternatives Requests for 

29 Additional Information for Kewaunee Power Station. (ADAMS 

30 Accession No. ML090290287) 

31 March 9, 2009 Letter from DEK, “Dominion Energy Kewaunee, Inc. Kewaunee Power 

32 Station Response to Request for Additional Information Regarding 

33 Severe Accident Mitigation Alternatives for Kewaunee Power Station 

34 License Renewal Application.” (ADAMS Accession No. 

35 ML0906900458) 

36 April 6, 2009 Letter to DEK, “Issuance of Environmental Scoping Summary Report 

37 Associated with the Staff’s Review of the Application by Dominion 
Appendix E 

Draft NUREG-1437, Supplement 40 E-6 February 2010 

1 Energy Kewaunee, Inc., for Renewal of the Operating License for 

2 Kewaunee Power Station.” (ADAMS Accession No. ML090770880) 

3 April 11, 2009 Letter to DEK, “Environmental Site Audit Regarding Kewaunee Power 

4 Station License Renewal Application.” (ADAMS Accession No. 

5 ML090750720) 

6 April 20, 2009 “Reissuing of the Environmental Scoping Summary Report Associated 

7 with the Staff’s Review of the Application by Dominion Energy 

8 Kewaunee, Inc., for Renewal of the Operating License for Kewaunee 

9 Power Station (ADAMS Accession No. ML091100093). 

10 June 1, 2009 Letter from DEK, “Dominion Energy Kewaunee, Inc. Kewaunee Power 

11 Station Response to Follow-Up Questions Regarding the Severe 

12 Accident Mitigation Alternatives for Kewaunee Power Station.” 

13 (ADAMS Accession No. ML091600037) 

14 July 6, 2009 Letter from DEK, “Response to Request to Docket Information 

15 Related to the Environmental Site Audit for Kewaunee Power Station.” 

16 (ADAMS Accession No. ML0919705124) 

17 July 8, 2009 Summary of Conference Calls With Dominion Energy Kewaunee, Inc., 

18 to Discuss Response to Follow-Up Question Regarding Severe 

19 Accident Mitigation Alternatives Request for Additional Information For 

20 Kewaunee Power Station. (ADAMS Accession No. ML091820565) 

21 July 8, 2009 Letter to DEK, “Environmental Project Manager Change for the 

22 License Renewal of Kewaunee Power Station.” (ADAMS Accession 

23 No. ML091880344) 

24 July 10, 2009 Letter to DEK, “Request for Additional Information Regarding the 

25 Environmental Review of the License Renewal Application for 

26 Kewaunee Power Station.” (ADAMS Accession No. ML091890017) 
February 2010 Draft NUREG-1437, Supplement 40 

APPENDIX F 

U.S. NUCLEAR REGULATORY COMMISSION STAFF 

EVALUATION OF SEVERE ACCIDENT MITIGATION 

ALTERNATIVES FOR KEWAUNEE POWER STATION IN 

SUPPORT OF LICENSE RENEWAL APPLICATION REVIEW

February 2010 F-1 Draft NUREG-1437, Supplement 40 

1 U.S. NUCLEAR REGULATORY COMMISSION STAFF EVALUATION OF 

2 SEVERE ACCIDENT MITIGATION ALTERNATIVES FOR KEWAUNEE 

3 POWER STATION IN SUPPORT OF LICENSE RENEWAL 

4 APPLICATION REVIEW 

5 F.1 Introduction 

6 Dominion Energy Kewaunee, Inc. (DEK) submitted an assessment of severe accident mitigation 

7 alternatives (SAMAs) for Kewaunee Power Station (KPS) as part of the environmental report 

8 (ER) (DEK, 2008a). This assessment was based on the most recent KPS probabilistic risk 

9 assessment (PRA) available at that time, a plant-specific offsite consequence analysis 

10 performed using the MELCOR Accident Consequence Code System 2 (MACCS2) computer 

11 code, and insights from the KPS individual plant examination (IPE) (WPSC, 1992) and individual 

12 plant examination of external events (IPEEE) (WPSC, 1994a). In identifying and evaluating 

13 potential SAMAs, DEK considered SAMAs that addressed the major contributors to core 

14 damage frequency (CDF) and large early release frequency (LERF) at KPS, as well as SAMA 

15 candidates for other operating plants, which have submitted license renewal applications. DEK 

16 identified 189 potential SAMA candidates. This list was reduced to 64 SAMAs by eliminating 

17 SAMAs that are not applicable at KPS due to design differences, have been effectively 

18 implemented at KPS, have estimated costs that would exceed the dollar value associated with 

19 completely eliminating all severe accident risk at KPS, or have a very low benefit because they 

20 are associated with a non-risk-significant system. DEK assessed the costs and benefits 

21 associated with each of the potential SAMAs and concluded in the ER that several of the 

22 candidate SAMAs evaluated are potentially cost-beneficial. 

23 Based on a review of the SAMA assessment, the U.S. Nuclear Regulatory Commission (NRC) 

24 issued a request for additional information (RAI) to DEK by letter dated January 8, 2009 (NRC, 

25 2009a). Key questions concerned: additional details regarding the plant-specific PRA model and 

26 changes to the model since the IPE; identification of candidate SAMAs from the available plant27 specific fire and seismic risk analyses; additional information regarding the Level 2 PRA 

28 analysis and Level 3 PRA inputs; the screening of specific candidate SAMAs; and further 

29 information on the cost-benefit analyses of several specific candidate SAMAs and low-cost 

30 alternatives. DEK submitted additional information by letter dated March 9, 2009 (DEK, 2009a). 

31 In response to the RAIs, DEK provided: information regarding PRA models and recent changes; 

32 additional justification for the treatment of external events; additional information on the Level 2 

33 and 3 PRA analysis and inputs; and additional information regarding selection, screening and 

34 cost-benefit analysis of several specific SAMAs. DEK responded to six follow-up questions from 

35 the NRC staff (NRC, 2009b) by letters dated June 1, 2009 (DEK, 2009b), and July 28, 2009 

36 (DEK, 2009c). DEK’s responses addressed the NRC staff’s concerns and resulted in the 

37 identification of additional potentially cost-beneficial SAMAs. 
Appendix F 

Draft NUREG-1437, Supplement 40 F-2 February 2010 

1 An assessment of SAMAs for KPS is presented below. 

2 F.2. Estimate of Risk for Kewaunee Power Station 

3 DEK's estimates of offsite risk at KPS are summarized in Section F.2.1. The summary is 

4 followed by the NRC staff's review of DEK’s risk estimates in Section F.2.2. 

5 F.2.1. Kewaunee’s Risk Estimates 

6 Two distinct analyses are combined to form the basis for the risk estimates used in the SAMA 

7 analysis: (1) the KPS Level 1 and 2 PRA model, which is an updated version of the IPE (WPSC, 

8 1992), and (2) a supplemental analysis of offsite consequences and economic impacts 

9 (essentially a Level 3 PRA model) developed specifically for the SAMA analysis. The SAMA 

10 analysis is based on the most recent KPS Level 1 and 2 PRA model available at the time of the 

11 ER, referred to as version K101AASAMA. The scope of the KPS PRA does not include external 

12 events. 

13 The baseline CDF for the purpose of the SAMA evaluation is approximately 7.7 x 10-5 per year 

14 as determined from the sum of the minimal cutsets. When determined from the sum of the event 

15 tree sequences, the CDF is 8.1 x 10-5 per year. The latter value was used in the SAMA 

16 analysis. The CDF is based on the risk assessment for internally-initiated events, which includes 

17 internal flooding. DEK did not include the contribution from external events within the KPS risk 

18 estimates; however, it did account for the potential risk reduction benefits associated with 

19 external events by doubling the estimated benefits for internal events. This is discussed further 

20 in Sections F.2.2 and F.6.2. 

21 The breakdown of CDF by initiating event is provided in Table F.2-1. This information was 

22 summarized from that provided in Table F-1 of the ER and in response to an RAI (DEK, 2009a). 

23 As shown in this table, events initiated by internal flooding are the dominant contributors to 

24 CDF, contributing a total of 4.5 x 10-5 per year or 58 percent of the total internal events CDF. 

25 Although not separately reported, station blackout (SBO) sequences contribute roughly 3.3 x 

26 10-6 per year (4.3 percent of the total internal events CDF), while anticipated transient without 

27 scram (ATWS) sequences contribute less than 1 percent to the total internal events CDF. 

28 The Level 2 KPS PRA model is based on the IPE model, with updates in 2004 and May 2007. 

29 The Level 1/Level 2 interface utilizes plant damage states (PDS) determined from “bridge trees”. 

30 These bridge trees extend the Level 1 analysis to include systems relevant to the Level 2 

31 analysis. Each PDS is then evaluated through the Level 2 containment event tree (CET) (ER 

32 Figure F-1). The CET probabilistically evaluates the progression of the damaged core with 

33 respect to release to the environment. The CET end states then are examined for 

34 considerations of timing and magnitude of release and assigned to release categories using a 

35 release category diagram (ER Figure F-2). 

36 The result of the Level 2 model is a set of 14 release categories, also referred to as source term 

37 categories (STCs), with their respective frequency and release characteristics. The release 

38 categories and their characteristics are provided in Table F-6 and F-10 of the ER. The 

39 categories were defined based on the timing, duration, and magnitude of the release and 

40 whether the containment remains intact, fails, or is bypassed. The frequency of each release 
Appendix F 

February 2010 F-3 Draft NUREG-1437, Supplement 40 

1 category was obtained by summing the frequency of the individual CET end states assigned to 

2 each release category. The release characteristics for the 14 release categories were based on 

3 analyses using the Modular Accident Analysis Program (MAAP) computer code. 

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

5 

Initiating Event CDF1 

(Per Year) 

% Contribution to 

CDF 

Internal Floods 4.5 x 10-5 58 

Transient with Main Feedwater Available 6.5 x 10-6 8 

Loss of Component Cooling Water 6.0 x 10-6 8 

Steam Generator Tube Rupture (SGTR) 4.7 x 10-6 6 

Loss of Offsite Power 3.9 x 10-6 5 

Stuck Open Pressurizer PORV 2.0 x 10-6 3 

Loss of Service Water 1.9 x 10-6 3 

Loss of Main Feedwater 1.6 x 10-6 2 

Small LOCA 1.2 x 10-6 2 

Vessel Failure 9.5 x 10-7 1 

Loss of Instrument Air 8.0 x 10-7 1 

All Others 2.5 x 10-6 3 

Total CDF (internal events) 7.7 x 10-5 100 

6 

7 The offsite consequences and economic impact analyses use the MACCS2 code to determine 

8 the offsite risk impacts on the surrounding environment and public. Inputs for these analyses 

9 include plant-specific and site-specific input values for core radionuclide inventory, source term 

10 and release characteristics, site meteorological data, projected population distribution (within an 

11 80-kilometer (50-mile) radius) for the year 2033, emergency response evacuation modeling, and 

12 economic data. The magnitude of the onsite impacts (in terms of clean-up and decontamination 

13 costs and occupational dose) is based on information provided in NEI 05-01 (NEI, 2005), which 

14 in turn is based on NUREG/BR-0184 (NRC, 1997a). 

15 In the ER, DEK estimated the dose to the population within 50 miles (80 km) of the KPS site to 

16 be approximately 0.302 person-sievert (Sv) (30.2 person-rem) per year. The breakdown of the 

17 total population dose by containment release mode is summarized in the following table: 
Appendix F 

Draft NUREG-1437, Supplement 40 F-4 February 2010 

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

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

3 generator) and late containment failures without containment spray dominate the 

4 population dose risk at Kewaunee Power Station. 

Containment Release Mode Population Dose 

(Person-Rem Per 

Year) 

% Contribution 

Late Containment Failure without containment sprays 8.6 29 

ISLOCA with scrubbing 0.2 <1 

ISLOCA without scrubbing 0.9 3 

SGTR with failure of secondary side isolation 19.5 64 

SGTR with successful secondary side isolation 0.9 3 

Other 0.1 1 

Total 30.2 100 

5 One person-rem = 0.01 person-Sv 

6 F.2.2. Review of Dominion Energy Kewaunee, Inc.’s Risk Estimates 

7 DEK’s determination of offsite risk at KPS is based on the following three major elements of 

8 analysis: 

9 ● the Level 1 and Level 2 risk models that form the bases for the 1992 IPE submittal 

10 (WPSC, 1992) and the external events analyses of the 1994 IPEEE submittal (WPSC, 

11 1994a), 

12 ● the major modifications to the IPE model that have been incorporated in the 

13 K101AASAMA PRA model, and 

14 ● the MACCS2 analyses performed to translate fission product source terms and release 

15 frequencies from the Level 2 PRA model into offsite consequence measures. 

16 Each of these analyses was reviewed to determine the acceptability of DEK’s risk estimates for 

17 the SAMA analysis, as summarized below. 

18 The NRC staff's review of the KPS IPE is described in an NRC report dated January 15, 1997 

19 (NRC, 1997b). Based on a review of the IPE submittal and responses to RAIs, the NRC staff 

20 concluded that the IPE submittal met the intent of Generic Letter (GL) 88-20; that is, the 

21 licensee’s IPE process is capable of identifying the most likely severe accidents and severe 

22 accident vulnerabilities. While the NRC Staff Evaluation Report (SER) and the attached 

23 Technical Evaluation Report (TER) did not specifically highlight any weaknesses in the IPE, in a 

24 subsequent submittal relative to risk-informed in-service inspection (NMC, 2005), the licensee 

25 indicated that six weaknesses were identified in the IPE review. In response to an RAI, DEK 
Appendix F 

February 2010 F-5 Draft NUREG-1437, Supplement 40 

1 addressed each weakness and confirmed that they are not applicable to the model used for the 

2 SAMA analysis (DEK, 2009a). 

3 The IPE identified nine severe accident vulnerabilities associated with core damage and six 

4 improvements to address the first five of these vulnerabilities (WPSC, 1994a). Improvements to 

5 address the remaining four vulnerabilities were being given further consideration at the time of 

6 the IPE submittal. In a subsequent IPE submittal, all but one of the original six improvements 

7 were stated to have been implemented. The one improvement not implemented was to change 

8 the normal position of two safety injection motor operated valves from open to closed, thereby 

9 reducing the ISLOCA frequency. While this was included in the IPE, it was subsequently found 

10 that the CDF contribution of failing to open was higher than the CDF reduction from having the 

11 valves closed. Accordingly, implementation of this change was not considered appropriate. The 

12 status of the remaining four vulnerabilities was also given (WPSC, 1994b). SAMAs in the 

13 current evaluation address these remaining four vulnerabilities. No vulnerabilities or 

14 improvements associated with containment performance were identified (WPSC, 1992). 

15 The CDF value from the 1996 KPS revised IPE (1.1 x 10-4 per year) is at the high end of the 

16 range of the CDF values reported in the IPEs for Westinghouse two-loop plants. Figure 11.6 of 

17 NUREG-1560 (NRC, 1997c) shows that the IPE-based total internal events CDF for two-loop 

18 Westinghouse plants ranges from 5 x 10-5 per year to 1.2 x 10-4 per year (NRC, 1997c). It is 

19 recognized that other plants have updated the values for CDF subsequent to the IPE submittals 

20 to reflect modeling and hardware changes. The internal events CDF result for KPS used for the 

21 SAMA analysis is somewhat higher than that for other plants of similar vintage and 

22 characteristics due to the relatively high internal flooding contribution to CDF, as described 

23 below. 

24 There have been nine revisions to the PRA model between the 1992 IPE submittal and the 

25 model used for the SAMA analysis. A description of changes made from one model to another 

26 is provided in Section F.2 of the ER and is summarized in Table F.2-3. The CDF and LERF 

27 values have varied widely over these revisions. 

28 In response to an RAI concerning the major reasons for these changes, DEK indicated that the 

29 principal reason for the changes was due to internal flood modeling (DEK, 2009a). According to 

30 DEK, the flood model in the 8/2003 PRA was not substantially different from that in the IPE, and 

31 resulted in a flood CDF of 3.6 x 10-7 per year. The 12/2004 PRA incorporated what was 

32 considered to be a conservative model that bounded actual flooding conditions until a best 

33 estimate model could be developed. This model had a flooding CDF contribution of 6.8 x 10-4 

34 per year with the majority of the frequency due to (1) rupture of the condenser expansion joint, 

35 with flood water propagating to the safeguards alley via floor drains and under doors, and (2) 

36 break of safety injection piping from the refueling water storage tank, with flood water 

37 propagating to the safeguards alley through a failed door. In 2005, design changes were made 

38 to mitigate these flooding contributors. Credit for these design changes, as well as planned 

39 internal flood modifications, was included in the K101AASAMA model and reduced the internal 

40 flood CDF to 4.5 x 10-5 per year. 
Appendix F 

Draft NUREG-1437, Supplement 40 F-6 February 2010 

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

Version Description/changes from previous model CDF 

(per year) 

LERF 

(per year) 

IPE 

11.0 ORIGINAL IPE 

6.6 x 10-5 NC 

Revised IPE 

6/1996 

Revised in response to RAIs, including new Human Reliability 

Analysis 

1.1 x 10-4 NC 

1/1997 - Credited operator to refill RWST 

- Modeled alternate cooling for air compressors 

3.9 x 10-5 2.2 x 10-6 

4/1998 Removed asymmetric modeling 3.6 x 10-5 1.9 x 10-6 

12/2001 - Incorporated plant failure and initiating event data 

- Included consideration of replacement SGs 

- Converted from GRAFTER code to WinNUPRA code 

- Reviewed in 6/2002 WOG Group peer review 

4.1 x 10-5 4.8 x 10-6 

8/2003 - Reevaluated important human error probabilities 

- Updated Level 2 success criteria for power uprate 

- Updated medium LOCA and ISLOCA models 

- Incorporated WOG RCP seal LOCA model 

- Revised steam line break analysis to include pressurized 

thermal shock 

- Added quantitative shutdown model 

- Resolved numerous peer review comments 

3.0 x 10-5 5.3 x 10-6 

12/2004 - Revised internal flooding model 

- Added need to stop safety injection following steam line break 

- Added dependence of letdown on component cooling water 

- Added power recovery and 480 VAC bus cross-ties 

- Updated success criteria for power uprate 

7.2 x 10-4 5.0 x 10-6 

K101A 

6/2006 

- Incorporated new internal flooding model which included plant 

changes to address flooding concerns 

- Incorporated revised diesel-generator reliability data 

- Incorporated reactor coolant system cooldown and 

depressurization following RCP seal LOCA to avoid core damage 

2.7 x 10-4 5.7 x 10-6 

K101AA 

12/2006 

- Incorporated flood barriers to protect RHR pumps 

- Incorporated operator actions to address flooding of battery 

room, auxiliary feedwater (AFW) room, and switchgear room 

ventilation 

- Incorporated procedure changes addressing service water 

isolation and removed other isolation conservatisms 

1.3 x 10-4 7.0 x 10-6 

K101AASAMA 

5/2007 

One time only model for SAMA. Updates were carried through to 

future revisions as specified 

- Revised service water model for internal flooding sequences 

- Incorporated credit for planned internal flooding design changes 

(described below) 

- Restructured Level 1 event trees to support revised Level 2 

model 

7.7 x 10-5 

(8.1 x 10-5) 

9.5 x 10-6 

(9.9 x 10-6) 
Appendix F 

February 2010 F-7 Draft NUREG-1437, Supplement 40 

Version Description/changes from previous model CDF 

(per year) 

LERF 

(per year) 

K101AB 

5/2007 

Update to K101AA 

- Revised service water model for internal flooding sequences 

Note: No internal flooding modifications included 

1.1 x 10-4 5.7 x 10-6 

K107A 

8/2007 

Subjected to independent review 1/2008 

- Updated basic event database 

- Updated internal flooding model to remove conservatisms 

- Restructured Level 1 event trees to support revised Level 2 

model 

Note: No internal flooding modifications included 

7.6 x 10-5 9.8 x 10-6 

K107Aa 

7/2008 

Updated model to “as installed” configuration of internal flooding 

modifications included in K101AASAMA model. 

4.8 x 10-5 6.4 x 10-6 

K107AaILRT 

7/15/2008 

Re-evaluated significant operator actions 4.2 x 10-5 

(4.3 x 10-5) 

4.9 x 10-6 

(4.9 x 10-6) 

1 NC - Not Calculated 

2 Values in parentheses are sum of sequence frequencies 

3 The planned internal flood modifications were discussed with the NRC on November 30, 2006 

4 (DEK, 2006). At the time of the SAMA analysis, three of the four planned modifications had 

5 been implemented, and the fourth modification, involving relocating two electrical safety-related 

6 supply circuit breakers (breakers 15206 and 16206), had not yet been completed. In response 

7 to an RAI, DEK indicated that relocation of breaker 16206 is currently planned for the next 

8 available opportunity, but relocation of breaker 15206, which is stated to have a much lower 

9 benefit, is no longer planned (DEK, 2009a). However, another design change, involving 

10 rerouting a wire for a Turbine Building basement fan coil unit, was completed in 2008 but not 

11 included in the K101AASAMA model. DEK indicated that credit for rerouting this wire would 

12 more than offset the impact of raising the breakers (DEK, 2009a). 

13 Subsequent to the SAMA analysis, DEK submitted an unrelated risk-informed license 

14 amendment request regarding containment integrated leak rate testing (DEK, 2008b) that 

15 provided information on a more recent version of the PRA (i.e., the K107Aa PRA model of July 

16 2008). The July 2008 PRA update has a significantly lower CDF (4.8 x 10-5 per year) than that 

17 for the SAMA model. In response to an RAI, DEK provided information on PRA model changes 

18 subsequent to the K101AASAMA PRA (DEK, 2009a). A description of these changes is 

19 included in Table F.2-3. The majority of the CDF reduction from the SAMA model to the K107Aa 

20 model is attributed to the database update and the incorporation of credit for rerouting a wire 

21 connecting the supply breaker for the turbine building basement fan coil unit B and auxiliary 

22 relays (DEK, 2009a). Other changes in the model, principally incorporating several specific 

23 ventilation design features and requirements, had a smaller impact on CDF. It is also noted that 

24 the current model does not include credit for raising of either breaker 15206 or 16206. The 

25 impact of this new PRA version on the results of the SAMA evaluation is discussed in Section 

26 3.2 below. 

27 The NRC staff considered the peer reviews performed for the KPS PRA and the potential 

28 impact of the review findings on the SAMA evaluation. In the ER, DEK described the June 2002 

29 peer review by the (former) Westinghouse Owner’s Group (WOG) of the 12/2001 PRA model. 
Appendix F 

Draft NUREG-1437, Supplement 40 F-8 February 2010 

1 The peer review identified five Level A and 49 Level B Facts & Observations (F&Os) (DEK, 

2 2008a). DEK stated in the ER that all Level A F&Os (important and necessary to address before 

3 the next regular PRA update) and all but two Level B F&Os (important and necessary to 

4 address but disposition may be deferred until the next PRA update) have been dispositioned, 

5 and that those items requiring model and/or documentation changes have been addressed in 

6 the PRA used for the SAMA analysis (K101AASAMA). One unresolved F&O pertains to not 

7 documenting the basis for not including room cooling as a required support system. In the 

8 SAMA model, room cooling is required unless a calculation shows it is not needed. The second 

9 unresolved F&O pertains to loss of room cooling as a separate initiating event. In response to 

10 an RAI, DEK discusses loss of room-cooling events and points out that the equipment needed 

11 during power operation is in different plant locations from that needed to respond to a reactor 

12 trip or accident. Consequently, the same room- cooling failures would not be expected to impact 

13 both functions. DEK concluded that loss of room cooling need not be treated as an initiator. In 

14 the SAMA model, room cooling is considered as a support function and this has led to the 

15 identification of a number of room cooling related SAMAs. The NRC staff considers this 

16 modeling approach sufficient for the purposes of the SAMA analysis. 

17 In the aforementioned integrated leak rate testing submittal (DEK, 2008b), DEK described a 

18 review of the July 2008 revised KPS PRA (K107Aa) against Regulatory Guide (RG) 1.200, 

19 Revision 1, and the supporting requirements (SRs) of the ASME PRA Standard (ASME, 2003). 

20 In response to an RAI, DEK provided additional information on this review and the impact of its 

21 findings on the SAMA analysis (DEK, 2009a). DEK summarized the unmet SRs, described how 

22 the unmet SRs were reviewed to determine if they would have an impact on the risk insights of 

23 the SAMA analysis, and concluded that resolution of the unmet SRs is not expected to alter the 

24 findings of the SAMA analysis. 

25 In the ER and in response to an RAI, DEK described the PRA update process in use at KPS. 

26 The model is updated at least every 3 years to maintain it consistent with the as-built, as27 operated plant, to incorporate improved thermal-hydraulic results, and to incorporate PRA 

28 improvements. The entire process of logging and tracking potential model changes, making the 

29 model changes, documenting the changes, independent review of the changes and 

30 management approval of the updated model and its documentation are governed by DEK 

31 procedures. 

32 Given that the KPS internal events PRA model has been peer reviewed and the peer review 

33 findings were all addressed, and that DEK has satisfactorily addressed NRC staff questions 

34 regarding the PRA, the NRC staff concludes that the internal events Level 1 PRA model is of 

35 sufficient quality to support the SAMA evaluation. 

36 As indicated above, the KPS PRA does not include external events. In the absence of such an 

37 analysis, DEK used the KPS IPEEE to identify the highest risk accident sequences and the 

38 potential means of reducing the risk posed by those sequences (DEK 2009a, 2009b). This is 

39 discussed below and in Section F.3.2. 

40 The KPS IPEEE was submitted in June 1994 (WPSC, 1994a), in response to Supplement 4 of 

41 Generic Letter 88-20 (NRC, 1991). This submittal included a seismic PRA, a fire PRA, and a 

42 screening analysis for other external events. While no fundamental weaknesses or 

43 vulnerabilities to severe accident risk in regard to the external events were identified, several 
Appendix F 

February 2010 F-9 Draft NUREG-1437, Supplement 40 

1 opportunities for seismic risk reduction were identified from the seismic IPEEE/USI A-46 

2 reviews, walkdowns, and relay chatter evaluations, and implemented as discussed below. In a 

3 letter dated October 5, 1999, the NRC staff concluded that the submittal met the intent of 

4 Supplement 4 to Generic Letter 88-20, and that the licensee’s IPEEE process is capable of 

5 identifying the most likely severe accidents and severe accident vulnerabilities (NRC, 1999). 

6 The seismic PRA included in the KPS IPEEE consisted of a Level 1 seismic PRA with a 

7 qualitative and quantitative evaluation of containment structures and containment safeguard 

8 systems. The seismic PRA approach employed was a composite of seismic PRA and seismic 

9 margins assessment (SMA) methods. Plant seismic walkdowns and screening were conducted 

10 using the SMA procedures and guidance (EPRI, 1991). For the components screened out using 

11 high confidence in low probability of failure (HCLPF) requirements for the 0.30g peak ground 

12 acceleration Review Level Earthquake (RLE), “surrogate elements” were included in the PRA 

13 model. Inclusion of these surrogate elements is necessary to incorporate in the seismic risk 

14 estimates the failure of relatively robust elements at higher ground accelerations. While the 

15 NRC review of the seismic PRA concluded that the use of “surrogate elements” resulted in an 

16 identification and ranking of dominant sequences that was not meaningful, the overall 

17 conclusion was that the resulting CDF of 1.1 x 10-5 per year was likely to be realistic or 

18 conservative, and that there are, with reasonable confidence, no significant vulnerabilities. The 

19 seismic outliers and the “bad actor” relays identified in the IPEEE were all resolved by 

20 modifications so that they would not contribute to seismic risk, and therefore were not included 

21 in the model (DEK, 2008a; NRC, 1998). The containment performance analysis included a 

22 review and walkdown of the containment structures and components (penetrations, hatches, 

23 isolation valves, freestanding steel shell, and attached piping and conduit). All met the screening 

24 criteria and were therefore evaluated using the surrogate element approach, leading to a single 

25 containment structural failure sequence. Fragilities for containment safeguard systems (spray, 

26 air-cooling, and isolation) were determined based on walkdown results. Models for failures of 

27 these systems were then input into a simplified Level 2 analysis based on the IPE model. 

28 Subsequent to the IPEEE, changes made to the seismic PRA, including credit for seismically29 rugged air accumulators and more realistic human error probabilities, led to a slight reduction in 

30 seismic CDF to 1.04 x 10-5 per year. 

31 To provide additional insight into the appropriate seismic CDF to use for the SAMA evaluation, 

32 the NRC staff developed an independent estimate of the seismic CDF for KPS using the 

33 simplified-hybrid approximation method described in a paper by Robert P. Kennedy, entitled 

34 “Overview of Methods for Seismic PRA and Margin Analysis Including Recent Innovations” 

35 (Kennedy, 1999) and using both updated 2008 seismic hazard curve data from the U.S. 

36 Geologic Survey (USGS, 2008) and LLNL seismic hazard curve data (NRC, 1994). The NRC 

37 staff’s independent calculations indicate the seismic CDF for KPS to be in the range of 6 x 10-6 

38 per year to 1 x 10-5 per year depending on seismic hazard curve and plant fragility 

39 assumptions. Based on these estimates of the seismic CDF, the NRC staff concludes that the 

40 seismic CDF given in the ER is appropriate for use in the SAMA assessment. 

41 The KPS IPEEE fire analysis employed a combination of fire PRA methodology with the Electric 

42 Power Research Institute’s fire-induced vulnerability evaluation (FIVE) methodology. Fire zones 

43 were initially screened out if a fire did not cause an initiating event or did not involve mitigating 

44 equipment modeled in the PRA. Quantitative screening was then performed using fire 

45 frequencies based on the FIVE methodology and the assumption that fire destroyed everything 
Appendix F 

Draft NUREG-1437, Supplement 40 F-10 February 2010 

1 in the zone. The sequence was then quantified using the PRA internal events model. If the CDF 

2 was greater than 1 x 10-6 per year the zone was subjected to more detailed analysis. The 

3 potential impact on containment performance and isolation was evaluated following the core 

4 damage evaluation. 

5 The fire model was revised in response to an RAI on potential weaknesses that were noted in 

6 the staff’s evaluation of the IPEEE fire analysis. This revision included adding the control room 

7 and cable spreading room to the fire zones evaluated, revising the human error probabilities 

8 (HEPs), and updating the initiating event frequencies and severity factors (DEK, 2008a; WPSC 

9 1995, 1998). The total fire CDF from the revised IPEEE analysis was estimated to be 1.8 x 10-4 

10 per year. 

11 In general, the fire PRA model has not been updated since the completion of the IPEEE review. 

12 However, when HEPs and plant failure data were updated for the internal events model, these 

13 updates were carried into the fire model. In addition, the fire propagation modeling for the 

14 auxiliary feedwater (AFW) pump B room, a dominant fire area, was updated, resulting in a fire 

15 CDF of about 1.4 x 10-4 per year. The important fire areas and their contributions to the fire 

16 CDF are listed in Table F.2-4. 

17 In the ER, DEK identifies a number of conservatisms in the fire analysis. These are: 

18 ● Initiating-event frequencies are based on old data that does not reflect 

19 current housekeeping practices. 

20 ● Fire-coping strategies credited only one train and did not rely on offsite 

21 power. 

22 ● If a cable tray is damaged, all cables in the tray are assumed to be 

23 damaged. 

24 ● Fire propagation analysis is highly conservative. 

25 ● Except for AFW Pump Room B, the most severe fire was assumed to occur 

26 with a frequency equal to the total fire initiating event frequency for the 

27 room. 

28 In response to an RAI, DEK indicated the fire zones to which each of the conservatisms was 

29 applicable. Most of the conservatisms are applicable to all fire zones and all are applicable to 

30 the dominant fire zones (CDF greater than 1 x 10-6 per year). 

31 DEK further states in the ER that changes to plant procedures made subsequent to the 

32 completion of the IPEEE would reduce the fire CDF by at least a factor of five from the IPEEE. 

33 In response to an RAI, DEK provided a reassessment of the top 100 cutsets from the fire risk 

34 analysis in which these fire procedures were credited, i.e., OP-KW-AOP-FP-001, “Abnormal 

35 Operating Procedure—Fire”, and OP-KW-AOP-FP-002, “Fire in Alternate Zone.” The 

36 reassessment supports a reduction in CDF of slightly more than a factor of 5. DEK concluded 

37 that the fire CDF would be 3.6 x 10-5 per year, based on applying the factor of 5 reduction to the 

38 IPEEE fire CDF of 1.8 x 10-4 per year. However, the staff notes that the assessment that led to 

39 this factor of 5 reduction used the updated fire PRA model with a CDF of about 1.4 x 10-4 per 

40 year as the baseline. Thus, the adjusted fire CDF should be 2.8 x 10-5 per year. DEK agrees 
Appendix F 

February 2010 F-11 Draft NUREG-1437, Supplement 40 

1 that this is the correct value to use and that the value used in SAMA analysis is conservative. 

2 The fire CDF for the dominant fire zones after making this adjustment are given in Table F.2-4 

3 (DEK, 2009b). 
Appendix F 

Draft NUREG-1437, Supplement 40 F-12 February 2010 

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

CDF (Per Year) 

Event ID Description PostIPEEE 

SAMA 

 Analysis 

IE-FIR14 Fire in Diesel Generator Room A 4.2 x 10-5 4.9 x 10-6 

IE-FIR5 Fire in Relay Room 3.3 x 10-5 5.6 x 10-6 

IE-FIR8 Fire Near Buses 51 and 52 2.4 x 10-5 2.9 x 10-6 

IE-FIR4 Fire in Diesel Generator Room B 1.8 x 10-5 1.8 x 10-6 

IE-FIR6 Auxiliary Feedwater Pump A Oil fire 1.2 x 10-5 1.3 x 10-6 

IE-FIR10 Fire in Bus 5 Switches in ECCA 5.5 x 10-6 5.5 x 10-6 

IE-FIR11 Fire in Bus 6 Switches in ECCA 5.2 x 10-6 5.2 x 10-6 

Total (All Fire Zones) 1.4 x 10-4 2.8 x 10-5 

2 

3 Considering the above conservatisms and procedure assessment and the response to the staff 

4 RAIs, the staff concludes that the fire CDF of 3.6 x 10-5 per year is reasonable for the SAMA 

5 analysis. 

6 The IPEEE analysis of high winds, floods, and other (HFO) external events followed the 

7 screening and evaluation approaches described in Supplement 4 of Generic Letter 88-20 (NRC, 

8 1991) and did not identify any significant sequences or vulnerabilities (WPSC, 1994a). Based on 

9 this result, the licensee concluded that these other external hazards would be negligible 

10 contributors to overall core damage and did not consider any plant specific SAMAs for these 

11 events. 

12 The NRC SER on the IPEEE (NRC, 1999) identified an open item pertaining to the protection of 

13 the vents on the underground diesel oil storage tanks against tornado-generated missiles. In 

14 response to an RAI, DEK indicated that these vents had been lowered so as to be less 

15 vulnerable to tornado missiles, thereby meeting the IPEEE requirements. A future modification 

16 is, however, planned to further minimize the tornado risk. 

17 Based on the aforementioned results, the external events CDF is approximately 60 percent of 

18 the internal events CDF from the K101AASAMA PRA (based on a fire CDF of 3.6 x 10-5 per 

19 year, a seismic CDF of 1 x 10-5 per year, a negligible HFO contribution, and an internal events 

20 CDF of 8.1 x 10-5 per year). Accordingly, the total CDF from internal and external events would 

21 be approximately 1.6 times the internal events CDF from the K101AASAMA PRA. In the SAMA 

22 analysis submitted in the ER, DEK doubled the benefit that was derived from the internal events 

23 model to account for the combined contribution from internal and external events. The NRC staff 

24 agrees with the licensee’s overall conclusion concerning the impact of external events, and 

25 concludes that the licensee’s use of a multiplier of 2 to account for external events is reasonable 

26 for the purposes of the SAMA evaluation. 

27 The NRC staff reviewed the general process used by DEK to translate the results of the Level 1 

28 PRA into containment releases, as well as the results of the Level 2 analysis, as described in 

29 the ER and in response to an NRC staff RAI (DEK, 2009a). The current Level 2 KPS PRA is 
Appendix F 

February 2010 F-13 Draft NUREG-1437, Supplement 40 

1 based on the IPE model with updates in 2004 and 2007, the latter using the results from the 

2 K101AASAMA Level 1 PRA. The 2004 update incorporated a design change that ensured that 

3 water on the containment floor would spill into the reactor sump after reaching a level of 29 

4 inches, thereby providing a flooded reactor cavity that could reduce the impact of core-concrete 

5 interactions in a severe accident. In addition, the 2004 update incorporated the results of 

6 reanalysis of accident sequences using a later version of the MAAP code and reflected a 6 

7 percent power uprate at KPS. The 2007 update included consideration of induced SGTR 

8 sequences, separation of SGTR sequences into those that had a large early release and those 

9 that did not, and resolution of comments from the WOG peer certification. 

10 Each plant damage state is analyzed through the Level 2 CET to evaluate the 

11 phenomenological progression of the sequence. The CET end states are then assigned to one 

12 of 14 release categories based on characteristics that determine the timing and magnitude of 

13 fission product release using a release category diagram (Figure F-2 of the ER). The frequency 

14 of each release category was obtained by summing the frequency of the individual accident 

15 progression CET endpoints into the release category. 

16 Source term release characteristics were developed for each release category based on results 

17 of plant-specific calculations using the MAAP computer program, Version 4.0.5. The release 

18 categories and their frequencies and release characteristics are presented in Table F-6 of the 

19 ER. The MAAP case selected to represent each release category was the sequence with the 

20 highest frequency that bounded the release fractions for the release category. In response to an 

21 RAI, DEK stated that when the Level 2 sequences were reanalyzed in 2007, the previously 

22 analyzed sequences for each release category were reviewed to ensure that they still reflected 

23 the expected accident progression for the associated release category, and if not, new cases 

24 were run (DEK, 2009a). DEK indicated that in most cases the previously selected sequence still 

25 represented the new source term category. The exception was release category 4 for which a 

26 flood scenario was selected for the revised analysis since floods are the dominant contributor. 

27 The NRC staff’s review of the Level 2 IPE concluded that it appeared to have considered the 

28 most important severe accident phenomena and it identified no significant problems or errors 

29 (NRC, 1997b). Based on the NRC staff’s review of the Level 2 methodology and in particular the 

30 changes made since the IPE, and the fact that the Level 2 model was reviewed as part of the 

31 WOG peer review and a subsequent self-assessment, the NRC staff concludes that the Level 2 

32 PRA provides an acceptable basis for evaluating the benefits associated with various SAMAs. 

33 As indicated in the ER, the reactor core radionuclide inventory used in the consequence 

34 analysis was determined from the results of an end-of-cycle ORIGEN2 code calculation. The 

35 results for a power level of 1772 MWt (the uprated power level) were increased by 0.6 percent 

36 for potential measurement error. In response to an RAI, the licensee indicated that KPS does 

37 not have any current plans that would cause fuel burnup/management to change during the 

38 renewal period. 

39 The NRC staff reviewed the process used by DEK to extend the containment performance 

40 (Level 2) portion of the PRA to an assessment of offsite consequences (essentially a Level 3 

41 PRA). This included consideration of the source terms used to characterize fission product 

42 releases for the applicable source term categories and the major input assumptions used in the 

43 offsite consequence analyses. The MACCS2 code was utilized to estimate offsite 
Appendix F 

Draft NUREG-1437, Supplement 40 F-14 February 2010 

1 consequences. Plant-specific input to the code includes the source terms for each source term 

2 category and the reactor core radionuclide inventory (both discussed above), site-specific 

3 meteorological data, projected population distribution within an 80-kilometer (50-mi) radius for 

4 the year 2033, emergency evacuation modeling, and economic data. This information is 

5 provided in Attachment F of the ER. 

6 All releases were modeled as occurring at the top of the containment approximately 180 feet 

7 above grade, with a thermal content the same as ambient (i.e., a non-buoyant plume). The 

8 impact of the shield building that surrounds the containment on initial plume size and release 

9 elevation was neglected. DEK assessed the impact of alternatively assuming a ground level 

10 release and a higher (buoyant) plume. The results of these sensitivity studies showed that a 

11 ground level release produces about a 6 percent reduction in population dose and offsite 

12 economic cost, while a conservatively large thermal content (buoyant plume) produces about a 

13 4 to 5 percent increase in population dose and economic cost. DEK also reported that an 

14 increase or decrease in initial plume size due to building wake size has no impact on population 

15 dose and a small (1 percent) change in offsite cost. In response to an RAI concerning the 

16 validity of release parameters for the dominant SGTR sequence, which has a release elevation 

17 somewhat lower than that assumed, but with a buoyant plume, DEK stated that the base case 

18 assumption of perpetual rain fall in the 40 to 50 mile segment surrounding the site introduces a 

19 30 to 40 percent conservatism that more than offsets any increase from selection of alternative 

20 release parameters (DEK, 2009a). Based on the information provided, the NRC staff concludes 

21 that the release parameters utilized are acceptable for the purposes of the SAMA evaluation. 

22 DEK used site-specific meteorological data for the 2002 calendar year as input to the MACCS2 

23 code. The development of the meteorological data is discussed in Section F.3.5 of the ER and 

24 in response to an RAI (DEK, 2009a). The wind and atmospheric stability data were collected 

25 from the onsite meteorological tower. Precipitation data was from Sturgeon Bay, Wisconsin, 

26 approximately 40 miles north of KPS, which is the closest weather station collecting hourly 

27 precipitation data. Seasonal morning and afternoon mixing heights were determined for each 

28 year from National Weather Service (NWS) measurements at Green Bay, Wisconsin. Data from 

29 2003 and 2004 were also considered, but the 2002 data was chosen because results of a 

30 MACCS2 sensitivity case comparing the use of the data indicated that the 2002 data produced 

31 more conservative results. In response to an RAI, DEK described the sources of data used to fill 

32 in gaps due to missing and invalid data (DEK, 2009a). The principal source was onsite 

33 measurements at other elevations, followed by data from the Point Beach site (approximately 4 

34 miles to the South), followed by nearest NWS locations. The NRC staff notes that previous 

35 SAMA analysis results have shown little sensitivity to year-to-year differences in meteorological 

36 data and concludes that the approach taken for collecting and applying the meteorological data 

37 in the SAMA analysis is reasonable. 

38 The population distribution the licensee used as input to the MACCS2 analysis was estimated 

39 for the year 2033. This estimate was based on the U.S. Census Bureau population data for 

40 2000, as provided by the SECPOP 2000 program (NRC, 2003), transient population estimates 

41 used in the updated evacuation time estimate study for KPS (TOMCOD, 2005), and county-by42 county growth rate estimates for the years 2000 to 2030 (State of Wisconsin, 2003). As 

43 described by DEK in response to an RAI, both geometric and exponential annual county growth 

44 rates were calculated for the 2030-2033 population growth (DEK, 2009a). The exponential rates 

45 were found to result in a larger 2033 population and were applied to the populations in each of 
Appendix F 

February 2010 F-15 Draft NUREG-1437, Supplement 40 

1 the 160 population zones (10 distance rings and 16 directions). Individual county rates were 

2 applied to the fraction of area in each zone in each county. Transient population was 

3 extrapolated in the same manner. The NRC staff considers the methods and assumptions for 

4 estimating population reasonable and acceptable for purposes of the SAMA evaluation. 

5 The emergency evacuation model was modeled as a single evacuation zone extending out 10 

6 miles (16 km) from the plant. It was assumed that 95 percent of the population would evacuate. 

7 This assumption is conservative relative to the NUREG-1150 study (NRC, 1990), which 

8 assumed evacuation of 99.5 percent of the population within the emergency planning zone. The 

9 evacuation time used in the SAMA analysis was based on a projection for the year 2033. The 

10 evacuees were assumed to begin evacuating 80 minutes after a General Emergency has been 

11 declared and to evacuate at an average radial speed of approximately 2.6 miles per hour (1.16 

12 meters per second). The evacuation speed is based on that for adverse weather conditions from 

13 the 2000 evacuation study extrapolated to 2033 by the ratio of the year 2000 population to the 

14 year 2033 population within the emergency planning zone (TOMCOD, 2005). The ER reports 

15 the results of several sensitivity analyses in which the evacuation modeling assumptions were 

16 varied. These analyses show that variations in the modeling assumptions had little or no impact 

17 on the results. Reducing the evacuation speed to half the base value, increasing it to the year 

18 2000 value or decreasing the evacuation effectiveness to 50 percent had less than a 0.5 

19 percent impact on population dose or offsite costs. Changing the time of declaration of a general 

20 emergency to the time when the core gets uncovered had no measurable impact on population 

21 dose and reduced offsite costs by 1 percent. The NRC staff concludes that the evacuation 

22 assumptions and analysis are reasonable and acceptable for the purposes of the SAMA 

23 evaluation. 

24 Much of the site-specific economic data was provided from SECPOP2000 (NRC, 2003) by 

25 specifying the data for each of the counties surrounding the plant to a distance of 50 miles (80 

26 km). This included the fraction of land devoted to farming, annual farm sales, the fraction of farm 

27 sales resulting from dairy production, and the value of non-farm land. SECPOP2000 utilizes 

28 economic data from the 1997 Census of Agriculture (USDA, 1998). Area-wide farm wealth was 

29 determined from 2002 National Census of Agriculture (USDA, 2002) county statistics for 

30 farmland, buildings and machinery, with only the fraction of each county within 50 miles of KPS 

31 considered. Non-farm wealth was similarly calculated from 2003 Wisconsin tax assessments but 

32 was found to be less than that from SECPOP2000, so the latter value was used. 

33 In addition, generic economic data that applies to the region as a whole was obtained from the 

34 MACCS2 sample problem input. This included parameters describing the cost of evacuating 

35 and relocating people, land decontamination, and property condemnation. An escalation factor 

36 of 1.85 was applied to these parameters to account for cost escalation from 1986 (the year the 

37 input was first specified) to 2007. 

38 As described in the ER, the three recently discovered problems in SECPOP2000 have all been 

39 accounted for in preparing the input for KPS. These problems involved: (1) an inconsistency in 

40 the format in which several economic parameters were output from the SECPOP2000 code and 

41 input to the MACCS2 code, (2) an error that resulted in use of agricultural/economic data for the 

42 wrong counties in the SECPOP2000 calculations, and (3) an error that resulted in the economic 

43 data for some counties being handled incorrectly. 
Appendix F 

Draft NUREG-1437, Supplement 40 F-16 February 2010 

1 The NRC staff concludes that the methodology used by DEK to estimate the offsite 

2 consequences for KPS provides an acceptable basis from which to proceed with an assessment 

3 of risk reduction potential for candidate SAMAs. Accordingly, the NRC staff based its 

4 assessment of offsite risk on the CDF and offsite doses reported by DEK. 

5 F.3. Potential Plant Improvements 

6 This section discussed the process for identifying potential plant improvements, an evaluation of 

7 that process, and the improvements evaluated in detail by DEK. 

8 F.3.1. Process for Identifying Potential Plant Improvements 

9 DEK's process for identifying potential plant improvements (SAMAs) consisted of the following 

10 elements: 

11 ● Review of the most significant basic events from the plant-specific PRA, 

12 ● Review of potential plant improvements identified in the KPS IPE and IPEEE, 

13 ● Review of Phase 2 SAMAs from recent license renewal applications for six other U.S. 

14 nuclear sites, and 

15 ● Review of generic SAMAs as documented in NEI 05-01 (NEI, 2005). 

16 Additionally, in response to RAIs, DEK’s process for identifying potential plant improvements 

17 was expanded to include: 

18 ● Review of dominant fire and seismic risk contributors from the IPEEE analysis for 

19 improvements that could potentially reduce the associated fire risk, and 

20 ● Review of the results of importance analysis of the K107Aa PRA (completed after the 

21 original SAMA assessment) for any additional potential improvements. 

22 Based on this process, an initial set of 189 SAMA candidates, referred to as Phase 1 SAMAs, 

23 was identified (ER Table F-17). In Phase 1 of the evaluation, DEK performed a qualitative 

24 screening of the initial list of SAMAs and eliminated SAMAs from further consideration using the 

25 following criteria: 

26 ● The SAMA is not applicable at KPS due to design differences (21 screened out), 

27 ● The SAMA has been effectively implemented at KPS (45 screened out), 

28 ● The SAMA has estimated costs that would exceed the dollar value associated with 

29 completely eliminating all severe accident risk at KPS (28 screened out), or 

30 ● The SAMA would be of very low benefit because it is associated with a non-risk31 significant system, and a change would have negligible impact on the risk profile (31 

32 screened out). 

33 Based on this screening, a total of 125 SAMAs were eliminated leaving 64 SAMAs for further 

34 evaluation. The remaining SAMAs, referred to as Phase 2 SAMAs, are listed in Table F-19 of 

35 the ER. Several of the SAMAs retained for further evaluation were considered to be similar in 
Appendix F 

February 2010 F-17 Draft NUREG-1437, Supplement 40 

1 terms of their benefits. As noted in Table F-17 of the ER, these SAMAs were combined and 

2 analyzed together in the Phase 2 evaluations. 

3 In Phase 2, a detailed evaluation was performed for the remaining SAMA candidates (46 

4 evaluations after combining similar SAMAs), as discussed in Sections F.4 and F.6 below. To 

5 account for the potential impact of external events, the estimated benefits based on internal 

6 events were multiplied by a factor of 2, as previously discussed. 

7 The review of the dominant fire and seismic contributors to risk did not identify any additional 

8 SAMAs. The review of the K107Aa PRA importance analysis identified one additional SAMA, 

9 involving implementation of temporary screenhouse ventilation. These reviews are discussed 

10 further in Section F.3.2 

11 F.3.2. Review of Dominion Energy Kewaunee, Inc.’s Process 

12 DEK’s efforts to identify potential SAMAs focused primarily on areas associated with internal 

13 initiating events, but also included explicit consideration of potential SAMAs for fire and seismic 

14 events. The initial list of SAMAs generally addressed the accident sequences considered to be 

15 important to CDF from functional, initiating event, and risk reduction worth perspectives at KPS, 

16 and included selected SAMAs from prior SAMA analyses for other plants. 

17 DEK provided a tabular listing of the PRA basic events sorted according to their Fussell-Vesely 

18 (F-V) importance with respect to CDF (DEK, 2008a). SAMAs impacting these basic events 

19 would have the greatest potential for reducing risk. DEK used an F-V cutoff of 0.005, which 

20 corresponds to about a 0.5 percent change in CDF given 100 percent reliability of the SAMA. 

21 This equates to a benefit of approximately $25,000. All 149 basic events in the listing were 

22 reviewed to identify potential SAMAs. Based on this review, 16 SAMAs were identified and 

23 included in the Phase 1 list of Table F-17. The remaining basic events were found to be events 

24 that had no physical meaning (such as complement events or constants), were covered by 

25 generic SAMAs already listed, or were due to conservative assumptions and could be 

26 eliminated by more detailed modeling. DEK also provided and reviewed the LERF-related F-V 

27 events down to an F-V value of 0.005. DEK correlated these basic events with the SAMAs 

28 already identified and did not find any additional SAMAs. 

29 In addition to basic event importance review, DEK reviewed the top 200 core damage cutsets to 

30 identify any basic events not included in the importance analysis that might suggest additional 

31 SAMAs. The resulting list contained 47 basic events (excluding events that had no physical 

32 meaning) and is provided in Table F-18 of the ER. Two additional SAMAs were identified in this 

33 review. 

34 DEK considered the potential plant improvements described in the IPE and IPEEE in the 

35 identification of plant-specific candidate SAMAs for internal and external events, as summarized 

36 below. 

37 The KPS IPE (WPSC, 1992) identified nine severe accident vulnerabilities and/or improvements 

38 associated with core damage. Six of these have either been implemented or assessed as not 

39 appropriate due to downside risk considerations (WPSC, 1994b). The Phase 1 SAMA list 

40 includes the remaining improvements identified in the IPE. No vulnerabilities or improvements 
Appendix F 

Draft NUREG-1437, Supplement 40 F-18 February 2010 

1 associated with poor containment performance were identified in the IPE nor are there any 

2 identified in the IPEEE. While the IPEEE did not identify any vulnerabilities, as discussed above, 

3 a number of equipment outliers were identified during the walkdowns, all of which have been 

4 resolved. 

5 The NRC staff questioned DEK about the disposition of a number of the basic events listed in 

6 the importance analyses, including consequential loss of offsite power and requested 

7 consideration of alternative SAMAs (NRC, 2009a). In response, DEK discussed why the 

8 consequential loss of offsite power event is important at KPS and the impact that potentially 

9 cost-beneficial SAMAs would have on this importance. Conservatisms in the modeling of the 

10 impact of this event were also discussed. Based on this information, the NRC staff concludes 

11 that no additional SAMAs would be effective in reducing the risk related to this event. DEK also 

12 discussed the benefit of additional refueling water storage tank (RWST) low-level alarms or an 

13 automatic RWST refilling system. DEK pointed out that the benefit of multiple low-level alarms is 

14 already included in the model and additional alarms would have a negligible impact on risk. A 

15 cost-benefit analysis for an automatic refill system, performed in a manner similar to the 

16 evaluation of other SAMAs, was provided, which showed that such a system would not be cost17 beneficial. 

18 The NRC staff requested clarification and further information regarding the screening of a 

19 number of the Phase 1 SAMAs (NRC, 2009a). In response, DEK: provided additional 

20 information regarding those SAMA that were screened out because they had already been 

21 implemented, cited additional data indicating that trip circuitry failure is not important to diesel 

22 generator failures, and clarified why additional transfer and isolation switches would not have 

23 any benefit. DEK clarified that while the central cooling water (CCW) system can be cross tied, 

24 there is presently no provision to cross tie the fire water system to the CCW system. A cost25 benefit analysis for adding a cross tie was provided that showed that such a modification would 

26 not be cost-beneficial. 

27 The NRC staff noted that KPS does not presently have a diesel-driven fire pump. In response to 

28 an RAI, DEK discussed the current fire pump design and the potential benefits and cost 

29 implications of adding a diesel-driven fire pump. While there is some opportunity for risk 

30 reduction by adding a diesel-driven pump, the benefits were qualitatively assessed by DEK to 

31 be small; whereas, the cost of a new pump, probably requiring a new building, was assessed as 

32 being more than any potential benefits. The NRC staff considers this conclusion reasonable 

33 given the available information on fire risk. 

34 DEK also clarified that while SAMA 151, “Increase training and operating experience feedback 

35 to improve operator response,” is stated to need further evaluation in ER Table F-17, it was not 

36 specifically evaluated since individual operator actions identified in the importance analysis 

37 review (ER Table F-3) and the cutset review (ER Table F-18) were evaluated separately. 

38 As indicated above, a number of Phase 1 SAMAs were combined for the Phase 2 evaluation. In 

39 response to an RAI concerning combining SAMAs 170 and 171 (involving safeguards alley 

40 cooling) with SAMAs 81, 82 and others (involving diesel building and switchgear room cooling), 

41 DEK provided a description of the various rooms and areas referred to as the “safeguards alley” 

42 (DEK, 2009a). The safeguards alley consists of a series of interconnected rooms housing both 

43 motor drive auxiliary feedwater pumps, the turbine driven auxiliary feedwater pump, both 
Appendix F 

February 2010 F-19 Draft NUREG-1437, Supplement 40 

1 divisions of 480 VAC switchgear, and both divisions of diesel generator/4160 VAC buses. DEK 

2 stated that because of the proximity and interconnections between these rooms, the benefits of 

3 providing high-temperature alarms and temporary ventilation can most effectively be evaluated 

4 by considering all rooms of the safeguards alley together. 

5 As requested in an RAI, DEK reviewed the results of importance analyses of the K107Aa 

6 completed after the original SAMA analysis to determine if any additional SAMAs would have 

7 been identified based on a review of the updated PRA. One of the modifications made in the 

8 PRA model involved adding screenhouse ventilation as a support system for the service water 

9 system. The K107Aa-based importance analysis showed that failures in screenhouse ventilation 

10 were important. In response, DEK indicated that a SAMA involving implementing temporary 

11 screenhouse ventilation and installing additional temperature detectors will be considered 

12 further (DEK, 2009a). 

13 The NRC staff questioned DEK about lower cost alternatives to some of the SAMAs evaluated 

14 (NRC 2009a, 2009b), including: 

15 ● Automating the cross-tie of the existing condensate storage tank (CST) to other water 

16 sources rather than installing a new CST, 

17 ● Modifying procedures to direct primary system cooldown to further reduce the 

18 probability of RCP seal failures, 

19 ● Modifying procedures and equipment for using a portable diesel-driven or AC-powered 

20 pump to provide feedwater to the steam generators with suction from the intake canal, 

21 ● Developing a procedure to cross-connect the chemical and volume control system 

22 (CVCS) holdup tanks to the volume control tank (VCT) through the CVCS holdup 

23 transfer pump, and 

24 ● Procuring and developing a procedure for using a gagging device to close a stuck25 open steam generator safety valve on a faulted steam generator before core damage 

26 occurs. 

27 In response to the RAIs, DEK addressed the lower cost alternatives and gave specific reasons 

28 why they would not impact the results of the SAMA evaluation, including the fact that some of 

29 these items are covered by an existing procedure or are addressed by other SAMAs (DEK 

30 2009a, 2009b, 2009c). This is discussed further in Section F.6.2. 

31 Based on this information, the NRC staff concludes that the set of SAMAs evaluated in the ER, 

32 together with those identified in response to NRC staff RAIs, addresses the major contributors 

33 to internal event CDF. 

34 Although the KPS IPEEE did not identify any vulnerabilities for external events, at the request of 

35 the NRC staff, DEK reviewed the results of the IPEEE fire and seismic risk analysis to 

36 determine if any KPS-specific external event SAMAs could be identified. This review is 

37 summarized below. 

38 The top cutsets resulting from the IPEEE fire PRA were reviewed to identify potential SAMAs 

39 that might reduce the KPS fire risk. The fire risk cutsets include failures due to fire itself 
Appendix F 

Draft NUREG-1437, Supplement 40 F-20 February 2010 

1 combined with non-fire related failures. DEK reviewed the non-fire related failures and 

2 determined that those in the dominant fire contributors were already addressed by multiple 

3 SAMAs identified in the internal events review (DEK, 2009a). To address the fire-induced 

4 failures, DEK estimated the total benefit that might result from entirely eliminating the fire risk 

5 from each fire risk contributor. This was done for the 7 percent discount rate base case as well 

6 as the 3 percent discount rate and the 95 percentile uncertainty sensitivity study cases. Six fire 

7 risk contributors were found to have a benefit that exceeded the $100,000 value used to 

8 estimate the minimum cost of a modification. DEK reviewed the fire induced failures for each of 

9 these six fire risk contributors and concluded that no cost-beneficial improvements in fire 

10 detection or mitigation were reasonably available (DEK, 2009b). At the request of the NRC staff, 

11 DEK also considered the impact on identification of SAMAs of several weaknesses in the fire 

12 PRA identified in the NRC review of the IPEEE submittal (NRC, 1999). Based on consideration 

13 of each weakness, DEK concluded that no new SAMAs would be identified as a result of 

14 correcting these weaknesses (DEK, 2009a). The NRC staff concludes that the opportunity for 

15 fire-related SAMAs has been adequately explored and that it is unlikely that there are additional 

16 potentially cost-beneficial, fire-related SAMA candidates. 

17 Based on the IPEEE seismic analysis, six sequences dominate the seismic risk at KPS. Three 

18 of these sequences involve major structural failures. DEK estimated that the cost of 

19 strengthening structures would exceed any potential benefit associated with reducing seismic 

20 risk. One dominant sequence involved failure of the operator to switch AFW pump suction from 

21 the CST to the service water system. A sensitivity study performed for the IPEEE showed that 

22 reducing the operator error resulted in only a 2 percent reduction in seismic CDF. DEK also 

23 noted that internal event SAMA items address improvements to long-term AFW availability, 

24 hence no new SAMAs are indicated for this sequence. The two other dominant sequences have 

25 a CDF of 1 x 10-6 per year or less and involve the emergency AC and DC power systems. All 

26 components in the AC power system have median seismic capacities of 1.86g PGA or more 

27 while the components of the DC power system have median seismic capacities of 1.10g PGA or 

28 more. Considering these relatively high seismic capacities, the low frequency of the seismic 

29 sequences that would challenge these systems, and the expected cost of strengthening the 

30 components, DEK identified no new SAMA items for these sequences (DEK, 2009a). At the 

31 request of the NRC staff, DEK also considered the impact on identification of SAMAs of the 

32 weaknesses in the seismic PRA identified in the NRC review of the IPEEE submittal (NRC, 

33 1999). Based on a discussion of each weakness, DEK concluded that no new SAMAs would be 

34 identified as a result of correcting these weaknesses (DEK, 2009a). 

35 The NRC staff notes that the set of SAMAs submitted is not all inclusive, since additional, 

36 possibly even less expensive, design alternatives can always be postulated. However, the NRC 

37 staff concludes that the benefits of any additional modifications are unlikely to exceed the 

38 benefits of the modifications evaluated and that the alternative improvements would not likely 

39 cost less than the least expensive alternatives evaluated, when the subsidiary costs associated 

40 with maintenance, procedures, and training are considered. 

41 The NRC staff concludes that DEK used a systematic and comprehensive process for 

42 identifying potential plant improvements for KPS, and that the set of SAMAs evaluated in the 

43 ER, together with those evaluated in response to NRC staff inquiries, is reasonably 

44 comprehensive and therefore acceptable. This search included reviewing insights from the 

45 plant-specific risk studies and reviewing plant improvements considered in previous SAMA 
Appendix F 

February 2010 F-21 Draft NUREG-1437, Supplement 40 

1 analyses. While explicit treatment of external events in the SAMA identification process was 

2 limited, it is recognized that the absence of external event vulnerabilities reasonably justifies 

3 examining primarily the internal events risk results for this purpose. 

4 F.4. Risk Reduction Potential of Plant Improvements 

5 DEK evaluated the risk-reduction potential of the 64 remaining SAMAs that were applicable to 

6 KPS (46 SAMA evaluations after combining similar SAMAs). The SAMA evaluations were 

7 performed using generally conservative assumptions. On balance, such calculations 

8 overestimate the benefit and are conservative. 

9 For most of the SAMAs, DEK used model re-quantification to determine the potential benefits. 

10 The CDF, population dose and offsite economic cost reductions were estimated using the 2007 

11 version of the KPS PRA model (K101AASAMA). The changes made to the model to quantify the 

12 impact of the SAMAs are detailed in Section F.6 of Attachment F to the ER. Table F.5-1 lists the 

13 assumptions considered to estimate the risk reduction for each of the evaluated SAMAs, the 

14 estimated risk reduction in terms of percent reduction in CDF and population dose, and the 

15 estimated total benefit (present value) of the averted risk. The estimated benefits reported in 

16 Table F.5-1 reflect the combined benefit in both internal and external events. The determination 

17 of the benefits for the various SAMAs is further discussed in Section F.6. 

18 The NRC staff questioned the assumptions used in evaluating the benefits or risk reduction 

19 estimates of certain SAMAs provided in the ER (NRC, 2009a). For example, in the ER DEK 

20 reported a negative benefit for SAMA 19, provide backup cooling to emergency diesel 

21 generators. In response to an RAI, DEK indicated the evaluation of SAMA 19 resulted in an 

22 increase in risk because of certain assumptions relative to operator response to the sequence 

23 after the modification was made. DEK provided an alternative assessment, incorporating 

24 procedure changes as well as hardware changes, which indicated a positive benefit. For SAMA 

25 150, improved maintenance procedures, the NRC staff questioned the applicability of the benefit 

26 determined by setting the maintenance unavailability to zero. In response, DEK stated that 

27 because no specific procedure improvement was identified by this generic SAMA, the 

28 maintenance unavailability for all of the Maintenance Rule (a)(1) equipment was used as a 

29 surrogate. DEK stated that this bounds the impact of improving the reliability of individual 

30 equipment items. Further, compliance with the Maintenance Rule will require reliability 

31 improvement actions be taken for any items failing to meet Maintenance Rule goals. DEK 

32 therefore concluded that no action for this SAMA is cost beneficial (DEK, 2009a). 

33 The NRC staff has reviewed DEK’s bases for calculating the risk reduction for the various plant 

34 improvements and concludes that the rationale and assumptions for estimating risk reduction 

35 are reasonable and generally conservative (i.e., the estimated risk reduction is higher than what 

36 would actually be realized). Accordingly, the NRC staff based its estimates of averted risk for 

37 the various SAMAs on DEK’s risk reduction estimates. 

38 F.5. Cost Impacts of Candidate Plant Improvements 

39 DEK estimated the costs of implementing the candidate SAMAs through the application of 

40 engineering judgment, the use of other licensees’ estimates for similar improvements and the 

41 use of KPS actual experience for similar improvements. The cost estimates conservatively did 
Appendix F 

Draft NUREG-1437, Supplement 40 F-22 February 2010 

1 not include the cost of replacement power during extended outages required to implement the 

2 modifications, nor did they include contingency costs associated with unforeseen 

3 implementation obstacles (DEK, 2008a). 

4 For a simple procedure change, DEK assumed a minimum cost of $50K for preparation, review, 

5 approval, training, and implementation. Complex procedure changes or changes involving 

6 emergency operating procedures were assumed to cost more. For a simple design change, 

7 DEK assumed a minimum cost of $100K for completing and assembling the design change 

8 package, performing limited calculations, and minor drawing revisions. Complex design 

9 changes were assumed to cost considerably more (DEK, 2008a). The cost estimates for each 

10 SAMA are detailed in Section F.6 of the ER. 

11 For a number of SAMAs (SAMAs 19, 26, 55, 56, 58, 59, 71, 81, 111, 112, 124, 125, 150, 178, 

12 179, 180, and 182) the estimated benefit for the 3 percent discount rate case and/or the 95th 

13 percentile uncertainty case was found to exceed the initial implementation cost estimate. The 

14 implementation costs for these SAMAs were further assessed to more realistically account for 

15 additional cost considerations. This is described in ER Sections F.7.1 and F.7.5, and in 

16 responses to NRC staff RAIs (DEK 2009a, 2009b). 

17 The NRC staff reviewed the bases for the licensee’s cost estimates (presented in Section F.6 of 

18 Attachment F to the ER). For certain improvements, the NRC staff also compared the cost 

19 estimates to estimates developed elsewhere for similar improvements, including estimates 

20 developed as part of other licensees’ analyses of SAMAs for operating reactors and advanced 

21 light-water reactors. The NRC staff reviewed the costs and found them to be reasonable and 

22 generally consistent with estimates provided in support of other plants’ analyses. 

23 The NRC staff concludes that the cost estimates provided by DEK are sufficient and appropriate 

24 for use in the SAMA evaluation. 

25 
Appendix F 

February 2010 F-23 Draft NUREG-1437, Supplement 40 

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

Kewaunee Power Station(a)

% Risk Reduction(b) Total Benefit ($) 

Case ID - Title 

Potential 

SAMAs 

evaluated by 

case 

Modeling 

Assumptions CDF Populati

on Dose 

Baseline 

(Internal + 

External) 

Baseline 

With 

Uncertainty 

Cost 

($) 

SAMA 1 

Improved 

Availability and 

Reliability of DC 

Power 

1, 3, 5, 6, 74 AC power to safety 

related battery 

chargers completely 

available. 

<0.1 <0.1 1.0K 1.9K 50K 

No service water 

required for EDGs. 

See 

Note (c) 

See 

Note (c) 

SAMA 19 (-)23K (-)41K 50K 

Provide Backup 

Cooling to 

emergency 

diesel 

generators 

(EDGs) 

19, 20 

0.1 probability of 

EDG cooling failure 

1.9 1.9 81K 150K 100K(e) 

SAMA 21 

Develop 

Procedures to 

Repair 4kVAC 

Breakers 

21 Failure probability of 

breakers supplying 

safety related buses 

5 and 6 set to zero. 

0.2 0.9 8.6K 16K 50K 

SAMA 26 

Provide 

Additional 

Diesel-Powered 

Safety Injection 

Pump 

26 Reactor coolant 

pump (RCP) seals 

and safety injection 

pumps would not fail. 

41 27 1.7M 3.0M 2M (e) 

SAMA 31 

Provide for 

Manual 

Alignment to 

emergency core 

cooling system 

(ECCS) 

Recirculation 

31 Electric power is not 

required for the 

valves needed to 

switch to ECCS 

recirculation. 

<0.1 0 360 650 50K 
Appendix F 

Draft NUREG-1437, Supplement 40 F-24 February 2010 

% Risk Reduction(b) Total Benefit ($) 

Case ID - Title 

Potential 

SAMAs 

evaluated by 

case 

Modeling 

Assumptions CDF Populati

on Dose 

Baseline 

(Internal + 

External) 

Baseline 

With 

Uncertainty 

Cost 

($) 

SAMA 32 

Provide 

Automatic 

Alignment to 

ECCS 

Recirculation 

32 HEPs associated with 

ECCS recirculation 

set to zero. 

1.6 0.3 51K 92K 100K 

SAMA 46 

Add a Service 

Water Pump 

46 Failure probability of 

service water pumps 

set to zero. 

18 15 820K 1.5M 2.7M 

SAMA 50 

Enhance Loss 

of Cooling 

Water 

Procedures 

50, 162, 163 Failure probability of 

the basic event that 

represents failure of 

operator action to 

initiate reactor 

coolant system 

(RCS) cool down in 

response to a loss of 

seal cooling set to 

1.0E-04. 

0.37 0.3 15K 28K 50K 

SAMA 55 

Install 

Independent 

RCP Seal 

Injection System 

With Dedicated 

Diesel 

55 Failure probability of 

charging to RCP 

seals set to zero. 

33 19 1.3M 2.3M 2M (e) 

SAMA 56 

Install 

Independent 

RCP Seal 

Injection System 

Without 

Dedicated 

Diesel 

56 Failure probability of 

charging to RCP 

seals for all accident 

scenarios except 

station blackout set to 

zero. 

29 14 1.0M 1.8M 1.5M 

(e) 

SAMA 58 

Install Improved 

RCP Seals 

58 Failure probability of 

charging to RCP 

seals set to zero. 

33 19 1.3M 2.3M 1.4M 

(e) 
Appendix F 

February 2010 F-25 Draft NUREG-1437, Supplement 40 

% Risk Reduction(b) Total Benefit ($) 

Case ID - Title 

Potential 

SAMAs 

evaluated by 

case 

Modeling 

Assumptions CDF Populati

on Dose 

Baseline 

(Internal + 

External) 

Baseline 

With 

Uncertainty 

Cost 

($) 

SAMA 59 

Install an 

Additional CCW 

Pump 

59 Failure probability of 

CCW pumps set to 

zero. 

25 14 980K 1.8M 1.4M 

(e) 

SAMA 66 

Install a New 

Feedwater 

Source 

[Proceduralize 

use of existing 

sources](d)

66 Failure probability for 

the hardware 

associated with water 

sources to the 

feedwater systems 

set to zero. 

6.7 8.5 380K 690K 50K 

SAMA 71 

Install A New 

Condensate 

Storage Tank 

71 Failure probability of 

events associated 

with providing a 

cross-tie of the CSTs 

to other sources set 

to zero. 

19 18 1.0M 1.8M 1.7M 

(e) 

SAMA 76 

Change Failure 

Position of 

Condenser 

Makeup Valve 

76, 184 Remove any power 

dependencies from 

valve MU-3A. 

<0.1 <0.1 4.4K 7.9K 100K 

SAMA 80 

Add Redundant 

Ventilation 

Systems [Stage 

temporary 

equipment and 

provide 

procedures and 

power source 

connections](d)

80 Remove any 

ventilation system 

dependencies for 

equipment located in 

the auxiliary building 

from the fault tree 

models. 

12 6.0 510K 910K 250K 

SAMA 81 

Diesel Room 

Cooling 

Improvements(f)

81, 160, 166, 

167, 170, 171 

Diesel room 

ventilation was 

always successful. 

4.6 5.1 240K 430K 400K 

(e) 
Appendix F 

Draft NUREG-1437, Supplement 40 F-26 February 2010 

% Risk Reduction(b) Total Benefit ($) 

Case ID - Title 

Potential 

SAMAs 

evaluated by 

case 

Modeling 

Assumptions CDF Populati

on Dose 

Baseline 

(Internal + 

External) 

Baseline 

With 

Uncertainty 

Cost 

($) 

SAMA 82 

Switchgear 

Room 

Ventilation 

Response 

[Stage backup 

fans in 

switchgear 

rooms, add 

switchgear room 

high 

temperature 

alarm, stage 

temporary fans 

and ducts along 

with power 

cords for 

safeguards alley 

room cooling, 

provide high 

temperature 

alarms for 

safeguards 

alley](d)

82, 83, 170, 

171 

Add an operator 

action to implement 

actions for temporary 

ventilation following 

any loss of 

switchgear room 

ventilation. 

8.8 9.4 440K 800K 400K 

SAMA 86 

Proceduralize 

Backup Power 

to Air 

Compressors 

86 Power to air 

compressors F and G 

does not fail. 

0.2 0.2 11K 19K 50K 

SAMA 87 

Replace Air 

Compressors 

With SelfCooled Units 

87 Remove the service 

water and plant 

equipment water 

dependency of air 

compressors from the 

system fault trees. 

0.7 0.4 26K 46K 100K 

SAMA 111 

Improve 

Prevention and 

Detection of 

interfacing 

systems loss-ofcoolant accident 

(ISLOCA) 

111, 113 ISLOCA frequency 

set to zero. 

1.1 3.8 130K 240K 190K 

(e) 
Appendix F 

February 2010 F-27 Draft NUREG-1437, Supplement 40 

% Risk Reduction(b) Total Benefit ($) 

Case ID - Title 

Potential 

SAMAs 

evaluated by 

case 

Modeling 

Assumptions CDF Populati

on Dose 

Baseline 

(Internal + 

External) 

Baseline 

With 

Uncertainty 

Cost 

($) 

SAMA 112 

Enhance 

Containment 

Isolation Valve 

Indication 

112 ISLOCA frequency 

set to zero and 

containment isolation 

set to success. 

1.1 3.4 130K 240K 150K 

(e) 

SAMA 114 

Install SelfActuating 

Containment 

Isolation Valves 

114 Containment isolation 

set to success in the 

Level 2 PRA models. 

0 <0.1 1.3K 2.3K 100K 

SAMA 118 

Improve 

Training on 

ISLOCA 

118 Failure probability of 

all human action 

events associated 

with ISLOCAs set to 

1.0E-04. 

<0.1 0.1 4.7K 8.6K 50K 

SAMA 122 

Improve RCS 

Depressurizatio

n Capability 

122 Hardware associated 

with primary 

depressurization 

does not fail. 

0.1 <0.1 4.7K 8.4K 100K 

SAMA 124 

Improve 

Detection of 

SGTR 

124 Probability of 

operator failure to 

detect and diagnose 

a SGTR is 1.0E-04. 

0.1 4.2 130K 240K 150K 

(e) 

SAMA 125 

Prevent 

Release of 

SGTR From 

Steam 

Generators 

125, 129 Level 2 PRA model 

changed so that 

SGTR events do not 

lead to containment 

bypass. 

<0.1 64 1.8M 3.2M 2.7M 

(e) 

SAMA 126 

Install ClosedLoop Steam 

Generator 

Cooling System 

126 Hardware associated 

with cool down and 

depressurization 

would not fail 

following a SGTR. 

3.6 2.8 170K 300K 2.7M 
Appendix F 

Draft NUREG-1437, Supplement 40 F-28 February 2010 

% Risk Reduction(b) Total Benefit ($) 

Case ID - Title 

Potential 

SAMAs 

evaluated by 

case 

Modeling 

Assumptions CDF Populati

on Dose 

Baseline 

(Internal + 

External) 

Baseline 

With 

Uncertainty 

Cost 

($) 

SAMA 131 

Install Additional 

Primary System 

Relief Capacity 

to Mitigate 

ATWS 

131 Initiating event 

equation for ATWS 

events set to zero. 

3.3 3.5 170K 310K 700K 

SAMA 150 

Improve 

Maintenance 

Procedures 

150 Maintenance 

unavailability for 

Maintenance Rule 

(a)(1) equipment set 

to zero. 

1.4 0.6 56K 100K 100K 

(e) 

SAMA 168 

Add Capability 

to Isolate 

Service Water 

Without Power 

168 Eliminate from the 

fault tree models the 

requirement for 

power to close 

service water valves 

SW-10A and SW10B. 

1.2 <0.1 33K 59K 100K 

SAMA 169 

Provide Flood 

Protection for 

MCC-52E, -62E, 

and -62H 

169 Eliminate floodinduced failure of the 

three MCCs from the 

fault tree models. 

12 4.3 420K 750K 284K 

SAMA 172 

Provide 

Additional Alarm 

for Extremely 

Low CST Level 

172 Failure probability for 

the associated basic 

event set to 1.0E-04. 

14 13 750K 1.4M 250K 

SAMA 173 

Protect Auxiliary 

Building 

Mezzanine 

Cooling Units 

From Spray 

173 Remove floodinduced failures of 

the auxiliary building 

mezzanine cooling 

units from the fault 

tree models. 

3.6 2.9 170K 310K 150K 

SAMA 174 

Protect Boric 

Acid Transfer 

Pumps From 

Spray 

174 Remove floodinduced failures of 

the boric acid transfer 

pumps from the fault 

tree models. 

3.3 2.5 160K 280K 150K 
Appendix F 

February 2010 F-29 Draft NUREG-1437, Supplement 40 

% Risk Reduction(b) Total Benefit ($) 

Case ID - Title 

Potential 

SAMAs 

evaluated by 

case 

Modeling 

Assumptions CDF Populati

on Dose 

Baseline 

(Internal + 

External) 

Baseline 

With 

Uncertainty 

Cost 

($) 

SAMA 175 

Protect A-Train 

CCW Pump 

From Spray 

175 Remove floodinduced failures of 

the A-train CCW 

pump from the fault 

tree models. 

4.0 2.9 185K 330K 150K 

SAMA 176 

Install Larger 

Sump Pumps In 

Safeguards 

Alley 

176 Eliminate 

submergenceinduced failures of 

equipment from the 

fault tree models. 

8.7 6.7 360K 660K 269K 

SAMA 177 

Install 

Watertight 

Barrier Between 

480 VAC 

Switchgear 

Rooms 

177 Remove flood 

propagation-induced 

failures of equipment 

in safeguards alley 

from the fault tree 

models for events 

that initiate on the 

opposite side of the 

wall. 

9.7 8.7 440K 790K 162K 

SAMA 178 

Install Flood 

Detection In 

Battery Rooms 

178 Probability of the 

basic event that 

represents operator 

failure to isolate 

battery room floods 

set to zero. 

2.0 2.5 110K 200K 150K 

(e) 

SAMA 179 

Add Diverse 

AFW Flow 

Indication 

179 Probability of the 

AFW flow 

miscalibration errors 

set to zero. 

3.2 2.6 160K 280K 200K 

(e) 

SAMA 180 

Remove AFW 

Low Lube Oil 

Pressure Start 

Interlock 

180 Remove the auxiliary 

lube oil pump failure 

logic from the fault 

tree models. 

2.5 2.7 130K 240K 150K 

(e) 

SAMA 181 

Install Break 

Away 

Mechanisms on 

EDG Room 

Doors 

181 Remove floodinduced failures from 

the main, reserve, 

and tertiary auxiliary 

transformers. 

2.7 4.6 180K 330K 100K 
Appendix F 

Draft NUREG-1437, Supplement 40 F-30 February 2010 

% Risk Reduction(b) Total Benefit ($) 

Case ID - Title 

Potential 

SAMAs 

evaluated by 

case 

Modeling 

Assumptions CDF Populati

on Dose 

Baseline 

(Internal + 

External) 

Baseline 

With 

Uncertainty 

Cost 

($) 

SAMA 182 

Install Flood 

Relief Path In 

Screenhouse 

182 Remove flood 

propagation-induced 

equipment failures 

from accident 

sequences that begin 

with a screenhouse 

flood. 

1.4 1.5 72K 130K 100K 

(e) 

SAMA 183 

Install Flood 

Detection in 

Control Room 

heating, 

ventilation, and 

air conditioning 

(HVAC) Room 

183 Remove flood 

propagation-induced 

equipment failures 

from accident 

sequences that begin 

with a control room 

HVAC room flood. 

<0.1 0.4 17K 30K 100K 

SAMA 188 

Install Larger 

Capacity Sump 

Pumps In 

Turbine Building 

188 HEP associated with 

isolating turbine 

building floods and 

assuming that small 

flooding events in 

safeguards alley 

cannot propagate set 

to 1.0E-04. 

2.8 2.2 120K 210K 269K 

SAMA 189 

Install Diverse 

SI Flow 

Indication 

189 Eliminate 

miscalibration errors 

from the SI fault tree. 

0.4 0.5 23K 45K 100K 

(a)SAMAs in bold are potentially cost-beneficial. 

(b)Percent risk reduction determined from base case and uncertainty values provided in ER Sections F.6 and F.7.5. 

(c)CDF and Population Dose increased for this SAMA due to modeling assumptions. Results of an alternate 

evaluation provided below based on DEK RAI response (DEK, 2009a). 

(d)Description in brackets is more appropriate for understanding the SAMA evaluation. 

(e)Costs and/or benefits of these SAMAs were further assessed. Based on further assessment, implementation costs 

were determined to be higher than the estimated benefits, even for the 95th percentile uncertainty case (ER 

Section F.7.5, DEK, 2008a, and responses to RAI 6a, 7.b and 7.c in DEK, 2009a and 2009b). 

(f)SAMA 81 found to be cost-beneficial if implemented simultaneously with other SAMAs (ER Section 7.7, DEK, 

2008a). 

1 F.6. Cost-Benefit Comparison 

2 DEK’s cost-benefit analysis and the NRC staff’s review are described in the following sections. 
Appendix F 

February 2010 F-31 Draft NUREG-1437, Supplement 40 

1 F.6.1. Dominion Energy Kewaunee, Inc.’s Evaluation 

2 The methodology used by DEK was based on NEI 05-01, Severe Accident Mitigation 

3 Alternatives (SAMA) Analysis Guidance Document (NEI, 2005), which in turn is based on NRC’s 

4 guidance for performing cost-benefit analysis, i.e., NUREG/BR-0184, Regulatory Analysis 

5 Technical Evaluation Handbook (NRC, 1997a). NEI 05-01 was endorsed by the NRC for use in 

6 license renewal applications (NRC, 2007). The guidance involves determining the net value for 

7 each SAMA 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. DEK’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 3 

19 percent and one at 7 percent (NRC, 2004). DEK provided a base set of results using the 7 

20 percent discount rate and a sensitivity study using the 3 percent discount rate (DEK, 2008a). 

21 Averted Public Exposure (APE) Costs

22 The APE costs were calculated using the following formula: 

23 APE = Annual reduction in public exposure (units of person-rem per year) 

24 x monetary equivalent of unit dose ($2000 per person-rem) 

25 x present value conversion factor (10.76 based on a 20-year period with a 7-

26 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 caused by 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 caused by 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, DEK calculated an APE of approximately $650,000 for the 

35 20-year license renewal period. 
Appendix F 

Draft NUREG-1437, Supplement 40 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 per event basis) 

5 x present value conversion factor 

6 This term represents the sum of the frequency-weighted offsite economic costs for each release 

7 category, as obtained for the Level 3 risk analysis. For the purposes of initial screening, which 

8 assumes elimination of all severe accidents caused by internal events, DEK calculated an 

9 annual offsite economic cost of about $49,700 based on the Level 3 risk analysis. This results in 

10 a discounted value of approximately $535,000 for the 20-year license renewal period. 

11 Averted Occupational Exposure (AOE) Costs

12 The AOE costs were calculated using the following formula: 

13 AOE = Annual CDF reduction 

14 x occupational exposure per core damage event 

15 x monetary equivalent of unit dose 

16 x present value conversion factor 

17 DEK derived the values for AOE from information provided in Section 5.7.3 of the regulatory 

18 analysis handbook (NRC, 1997a). Best estimate values provided for immediate occupational 

19 dose (3,300 person-rem) and long-term occupational dose (20,000 person-rem over a 10-year 

20 cleanup period) were used. The present value of these doses was calculated using the 

21 equations provided in the handbook, in conjunction with a monetary equivalent of unit dose of 

22 $2,000 per person-rem, a real discount rate of 7 percent, and a time period of 20 years to 

23 represent the license renewal period. For the purposes of initial screening, which assumes 

24 elimination of all severe accidents caused by internal events, DEK calculated an AOE of 

25 approximately $30,800 for the 20-year license renewal period. 

26 Averted Onsite Costs

27 Averted onsite costs (AOSC) include averted cleanup and decontamination costs and averted 

28 power replacement costs. Repair and refurbishment costs are considered for recoverable 

29 accidents only and not for severe accidents. DEK derived the values for AOSC based on 

30 information provided in Section 5.7.6 of NUREG/BR-0184, the regulatory analysis handbook 

31 (NRC, 1997a). 

32 DEK divided this cost element into two parts—the onsite cleanup and decontamination cost, 

33 also commonly referred to as averted cleanup and decontamination costs (ACC), and the 

34 replacement power cost (RPC). 
Appendix F 

February 2010 F-33 Draft NUREG-1437, Supplement 40 

1 ACCs 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 the 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, DEK calculated an ACC of approximately $939,000 for the 20-year license 

10 renewal period. 

11 Long-term RPCs 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 power is 

15 required 

16 x reactor power scaling factor 

17 DEK based its calculations on the rated KPS net electric output of 556 megawatt-electric (MWe) 

18 and scaled down from the 910 MWe reference plant in NUREG/BR-0184 (NRC, 1997a). 

19 Therefore, DEK applied a power scaling factor of 556/910 to determine the replacement power 

20 costs. For the purposes of initial screening, which assumes elimination of all severe accidents 

21 caused by internal events, DEK calculated an RPC of approximately $390,000, and an AOSC of 

22 approximately $1.3M for the 20-year license renewal period. 

23 Using the above equations, DEK estimated the total present dollar value equivalent associated 

24 with completely eliminating severe accidents caused by internal events at KPS to be about 

25 $2.54M. Use of a multiplier of two to account for external events increases the value to $5.09M 

26 and represents the dollar value associated with completely eliminating all internal and external 

27 event severe accident risk at KPS, also referred to as the Modified Maximum Averted Cost Risk 

28 (MMACR). 

29 DEK’s Results

30 If the implementation costs for a candidate SAMA exceeded the calculated benefit, the SAMA 

31 was considered not to be cost-beneficial. In the baseline analysis contained in the ER, (using a 

32 7 percent discount rate), DEK identified 14 potentially cost-beneficial SAMAs. The potentially 

33 cost-beneficial SAMAs are: 

34 ● SAMA 66 – Install a New Feedwater Source (The evaluated SAMA actually involved 

35 proceduralizing use of existing water sources) 
Appendix F 

Draft NUREG-1437, Supplement 40 F-34 February 2010 

1 ● SAMA 80 – Add Redundant Ventilation Systems (The evaluated SAMA actually 

2 involved staging temporary equipment and providing procedures and power source 

3 connections) 

4 ● SAMA 82, 83, 170, 171 – Switchgear Room Ventilation Response (The evaluated 

5 SAMA actually involved staging backup fans in switchgear rooms, adding switchgear 

6 room high-temperature alarm, staging temporary fans and ducts along with power 

7 cords for safeguards alley room cooling, and providing high-temperature alarms for the 

8 safeguards alley) 

9 ● SAMA 169 – Provide Flood Protection for MCC-52E, -62E, and -62H 

10 ● SAMA 172 – Provide Additional Alarm for Extremely Low CST Level 

11 ● SAMA 173 – Protect Auxiliary Building Mezzanine Cooling Units from Spray 

12 ● SAMA 174 – Protect Boric Acid Transfer Pumps from Spray 

13 ● SAMA 175 – Protect A-Train CCW Pump from Spray 

14 ● SAMA 176 – Install Larger Sump Pumps In Safeguards Alley 

15 ● SAMA 177 – Install Watertight Barrier between 480 VAC Switchgear Rooms 

16 ● SAMA 181 – Install Break Away Mechanisms on EDG Room Doors 

17 DEK performed additional analyses to evaluate the impact of parameter choices and 

18 uncertainties on the results of the SAMA assessment (DEK, 2008a). 

19 Based on an analysis using 3 percent, as recommended in NUREG/BR-0058 (NRC, 2004), 

20 DEK determined that four of the Phase 1 SAMAs screened out due to excessive implementation 

21 cost (SAMAs 2, 104, 116 and 119) and would have been retained for further analysis. Thirteen 

22 of the Phase 2 SAMAs, which had a negative net value at a 7 percent discount rate (SAMAs 19, 

23 26, 55, 56, 58, 59, 111, 112, 124, 178, 179, 180, and 182) would have a potentially positive net 

24 value at a 3 percent discount rate. In Section F.7.1 of the ER (and in RAI 6.a responses for 

25 SAMA 19), DEK discussed each of these SAMAs and concluded that in each case the cost of 

26 implementation would be higher than that utilized in the original cost-benefit analyses and would 

27 exceed the benefit using the 3 percent discount rate (DEK 2008a, 2009a, 2009b). 

28 If the benefits are increased by a factor of 1.8 to account for uncertainties, four Phase 1 SAMAs 

29 (the same four SAMAs mentioned above) would have been retained for further analysis, and 17 

30 Phase 2 SAMAs (the 13 SAMAs mentioned above plus SAMAs 71, 81, 125, and 150) would 

31 become potentially cost-beneficial. In Section F.7.5 of the ER (and in RAI responses for SAMAs 

32 19 and 58), DEK discusses each of these items noting: costs that were not included in the base 

33 case assessment, the optimistic nature of some of the estimates and, in some cases, the 

34 conservative nature of the benefit calculation. Based on this, DEK concludes that no additional 

35 SAMAs would be cost beneficial even at the 95 percentile risk values. 

36 DEK also considered the impact of simultaneous implementation of several of the SAMAs from 

37 both a benefit and a cost standpoint. DEK concluded that while the simultaneous 

38 implementation of several SAMAs would not increase the total benefit beyond that for each 

39 SAMA individually, the implementation cost could be reduced. Based on the evaluation of 
Appendix F 

February 2010 F-35 Draft NUREG-1437, Supplement 40 

1 similar SAMAs involving improvements in room cooling and ventilation, DEK concluded that the 

2 following three additional SAMAs involving diesel room cooling improvements would be cost 

3 beneficial: 

4 ● SAMA 81 – Add a diesel building high temperature alarm or redundant louver and 

5 thermostat 

6 ● SAMA 166 – Open Doors for Alternate DG Room Cooling 

7 ● SAMA 167 – Proceduralize Actions to Open EDG Room Doors on Loss of HVAC and 

8 Implement Portable Fans 

9 As discussed above, DEK’s review of the results of importance analysis of the K107Aa PRA, 

10 prepared subsequent to the SAMA evaluation documented in the ER, indicated one new 

11 contributor to risk that could be impacted by a candidate SAMA. DEK concluded that a new 

12 SAMA addressing this contributor—loss of screenhouse ventilation—could be cost effectively 

13 combined with similar SAMAs 81, 82, 83, 160, 166, 167, 170, and 171. 

14 ● Implementation of temporary screenhouse ventilation, including installing additional 

15 temperature detectors 

16 DEK committed to further review these SAMAs for implementation as part of DEK’s ongoing 

17 performance improvement program (DEK 2008a, 2009a). 

18 The potentially cost-beneficial SAMAs and DEK’s plans for further evaluation of these SAMAs 

19 are discussed in more detail in Section F.6.2. 

20 F.6.2. Review of Dominion Energy Kewaunee, Inc.’s Cost-Benefit Evaluation 

21 The cost-benefit analysis performed by DEK was based primarily on NEI 05-01, Severe 

22 Accident Mitigation Alternatives (SAMA) Analysis Guidance Document (NEI, 2006), which in 

23 turn is based on NRC’s guidance for performing cost-benefit analysis, i.e., NUREG/BR-0184, 

24 Regulatory Analysis Technical Evaluation Handbook (NRC, 1997a). NEI 05-01 was endorsed by 

25 the NRC for use in license renewal applications (NRC, 2007). The NRC staff’s review indicated 

26 that the cost-benefit analysis was implemented in accordance with these guidance documents. 

27 NUREG/BR-0058 has recently been revised to reflect the agency’s policy on discount rates. 

28 Revision 4 of NUREG/BR-0058 states that two sets of estimates should be developed, one at 3 

29 percent and one at 7 percent (NRC, 2004). DEK provided a base set of results using the 7 

30 percent discount rate and a sensitivity study using the 3 percent discount rate (DEK, 2008a). 

31 SAMAs identified primarily on the basis of the internal events analysis could provide benefits in 

32 certain external events, in addition to their benefits in internal events. To account for the 

33 additional benefits in external events, DEK multiplied the internal event benefits by a factor of 2. 

34 The NRC staff notes that the KPS external events CDF is approximately 60 percent of the 

internal events CDF from the K101AASAMA PRA (based on a fire CDF of 3.6 x 10-5 35 per year, a 

seismic CDF of 1 x 10-5 36 per year, a negligible HFO contribution, and an internal events CDF of 

8.1 x 10-5 37 per year). Accordingly, the total CDF from internal and external events would be 

38 approximately 1.6 times the internal events CDF from the K101AASAMA PRA. Thus, the use a 
Appendix F 

Draft NUREG-1437, Supplement 40 F-36 February 2010 

1 multiplier of 2 is conservative. The NRC staff concludes that the factor of 2 multiplier for external 

2 events is reasonable for purposes of the SAMA evaluation. 

3 DEK considered the impact that possible increases in benefits from analysis uncertainties would 

4 have on the results of the SAMA assessment. In the ER, DEK presents the results of an 

uncertainty analysis of the internal events CDF for KPS, which indicates that the 95th 5 percentile 

6 value is a factor of 1.8 greater than the mean CDF for KPS. DEK assessed the impact on the 

7 SAMA screening, if the estimated benefits were further increased by this uncertainty factor (in 

8 addition to the multiplier of 2 for external events). 

9 DEK performed additional sensitivity analyses, including use of a 3 percent discount rate, use of 

10 a longer plant life and use of different evacuation assumptions, and considered the impact of 

11 unresolved peer review findings and recent plant modifications on the results of the SAMA 

12 analysis. These analyses did not identify additional potentially cost-beneficial SAMAs beyond 

13 those already identified through the uncertainty analysis. 

14 The NRC staff noted in an RAI that a number of important basic events involved failure of the 

15 operator to refill the RWST and requested that DEK consider an automatic refilling system as a 

16 potential SAMA (NRC, 2009a). In response, DEK provided a cost benefit analysis, based on a 7 

17 percent discount rate, which showed that this modification would not be cost beneficial (DEK, 

18 2009a). In a request for clarification of the RAI response (NRC, 2009b), the NRC staff pointed 

19 out that based on DEK’s analysis, the automatic refilling system would be cost-beneficial at a 3 

20 percent discount rate or when considering uncertainties in CDF. In response to the request for 

21 clarification, DEK agreed that using the original cost estimate of $850,000 for an automatic 

22 refilling system, the enhancement would be cost beneficial for these sensitivity cases. However, 

23 they indicated that this cost estimate was a conservatively low screening estimate. DEK 

24 provided an updated cost estimate of approximately $1.5 million, based on a more refined 

25 analysis similar to that for a CST refill system (discussed later). Since this is more than the 

26 benefit using a 3 percent discount rate ($972,000) or when accounting for uncertainty ($1.1 

27 million), DEK concluded that this enhancement would not be cost-beneficial (DEK, 2009b). 

28 A similar situation was observed for SAMA 19. As noted previously, DEK’s evaluation of SAMA 

29 19, provide backup cooling to emergency diesel generators, resulted in an increase in CDF. In 

30 response to an RAI, DEK provided a cost benefit analysis that indicated that the SAMA was not 

31 cost beneficial. The analysis in this initial response was performed for a 7 percent discount rate. 

32 In a request for clarification of the RAI response (NRC, 2009b), the NRC staff pointed out that 

33 based on DEK’s analysis, the SAMA would be cost-beneficial at a 3 percent discount rate or 

34 when considering uncertainties in CDF. In response to the request for clarification, DEK agreed 

35 that using the original cost estimate of $100,000, this SAMA would be cost beneficial for these 

36 sensitivity cases. However, they indicated that this cost estimate was a conservatively low 

37 screening estimate. DEK provided an updated cost estimate of at least $150,000, which 

38 accounted for additional hardware costs associated with the modification. Since this is more 

39 than the benefit using a 3 percent discount rate ($125,000) or when accounting for uncertainty 

40 ($146,000), DEK concluded that this enhancement would not be cost beneficial (DEK, 2009b). 

41 The NRC staff noted that for certain SAMAs considered in the ER, there may be alternatives 

42 that could achieve much of the risk reduction at a lower cost. The NRC staff asked the licensee 

43 to evaluate several lower cost alternatives to the SAMAs considered in the ER, including 
Appendix F 

February 2010 F-37 Draft NUREG-1437, Supplement 40 

1 SAMAs that had been found to be potentially cost-beneficial at other PWR plants. These 

2 alternatives were: (1) automating the cross-tie of the existing CST to other water sources rather 

3 than installing a new CST, (2) modifying procedures to direct primary system cool-down to 

4 further reduce the probability of RCP seal failures, (3) modifying procedures and equipment for 

5 using a portable diesel-driven or AC-powered pump to provide feedwater to the steam 

6 generators with suction from the intake canal, (4) developing a procedure to cross-connect the 

7 CVCS holdup tanks to the VCT through the CVCS holdup transfer pump, and (5) procuring and 

8 developing a procedure for using a gagging device to close a stuck-open steam generator 

9 safety valve on a faulted steam generator before core damage occurs. The latter had been 

10 found potentially cost-beneficial in two previous SAMA evaluations (Entergy, 2008; FENOC, 

11 2007) and might be cost beneficial at KPS as a SGTR where failure to isolate contributes 64 

12 percent of the population dose at KPS (See Table F.2-2). DEK provided a further evaluation of 

13 these alternatives, as summarized below: 

14 ● Automate the CST Cross-Tie. The cost benefit of automating the CST cross-tie was 

15 evaluated by setting the operator failure to perform the cross-tie to zero. This produced 

16 an 18 percent reduction in CDF and a 17 percent reduction in person-rem, yielding a 

17 benefit of $912,000 (based on a 7 percent discount rate, and including the factor of 2 

18 multiplier for external events). The cost of this enhancement was estimated to be 

19 approximately $1.5 million. Based on this assessment, the enhancement would not be 

20 cost beneficial. In a request for clarification of RAI responses, DEK addressed the 

21 impact of assuming a 3 percent discount rate or accounting for uncertainty. A revised 

22 analysis using a 3 percent discount rate and the K101AASAMA PRA model yielded a 

23 total benefit of about $1.4 million, which is less than the cost of the enhancement. To 

24 address the impact of uncertainty, DEK recalculated the base case and SAMA 

25 assessment case using the more recent K107AaILRT PRA model. Use of this PRA 

26 model and a more realistic (less conservative) assumption concerning the SAMA 

27 benefits (both operator failure and electrical bus failure required to fail the CST cross28 tie rather than setting operator error to zero) resulted in only an 8 percent reduction in 

29 CDF and a $333,000 benefit. Based on this alternative evaluation, DEK concluded that 

this enhancement would not be cost-beneficial even for the 95th 30 percentile uncertainty 

31 case (DEK Electric Kewaunee, 2009b). 

32 ● Modify Procedures to Reduce RCP Seal Failures. Modifying procedures to direct 

33 primary system cooldown was evaluated in SAMAs 50, 162 and 163 and found by DEK 

34 to not be cost beneficial. 

35 ● Modify Procedures to Use a Portable Pump to Provide Feedwater to Steam 

36 Generators. DEK described the procedures followed and actions taken by the 

37 operators following a reactor trip. These include determining status of AFW flow, 

38 attempting to restore AFW flow, if not available, or restoring main feedwater. If this is 

39 not possible, procedures include depressurizing the steam generators to establish 

40 condensate flow or initiating feed and bleed cooling. The time available and steps 

41 necessary to establish flow to a steam generator from a portable pump were also 

42 described. Based on the required actions and time available, DEK concluded that, 

43 unless significant plant impairments exist, it would be best for the operators to focus on 

44 restoration of cooling using permanently installed equipment. Modifying procedures to 
Appendix F 

Draft NUREG-1437, Supplement 40 F-38 February 2010 

1 use a portable pump for steam generator makeup would provide a negligible risk 

2 reduction and would not be cost-beneficial. 

3 ● Modify Procedures to Provide Makeup to the Volume Control Tank. DEK discussed the 

4 potential use of the CVCS holdup tanks to provide makeup to the VCT and thereby 

5 provide a continued source of water for injection to the RCP seals and the RCS. DEK 

6 noted that makeup to the VCT is normally from the letdown flow. If this is interrupted, 

7 then flow is provided automatically from the RWST. If this fails, RCP seal integrity will 

8 be maintained as long as component cooling water to the seals continues. If this is lost, 

9 seals will fail if injection is not restored within 13 minutes. DEK indicated that provision 

10 of flow from the CVCS holdup tanks to the VCT in 13 minutes is not considered 

11 practical. While flow from the CVCS after a seal loss of coolant accident (LOCA) would 

12 provide RCS makeup, it would not remove decay heat nor prevent core damage. 

13 Based on the above, DEK concluded that this proposed enhancement would not offer 

14 significant risk reduction benefits and would not be cost-beneficial. 

15 ● Provide a Gagging Device to Close a Stuck-Open Steam Generator Safety Valve. DEK 

16 discussed and evaluated the conditions under which a gagging device could be used 

17 to close a stuck-open steam generator safety valve, and the resulting benefit 

18 associated with it. As outlined in the DEK response, two circumstances contribute to 

19 the release of radioactivity following an SGTR event with a stuck-open safety valve. 

20 The first is an induced-SGTR, which occurs after core damage when hot gases and 

21 high RCS pressure cause a steam generator tube to fail, with subsequent safety valve 

22 opening and failure to re-close. The second circumstance is a spontaneous SGTR, in 

23 which a tube rupture is the initiating event and high pressure from the reactor coolant 

24 system causes the steam generator pressure to rise. If the operators fail to cool down 

25 and depressurize soon enough in this latter event, the secondary water level would 

26 increase along with pressure causing a safety valve to open and pass liquid. There 

27 would then be a significant chance that, when the pressure is reduced, the safety valve 

28 would fail to re-close. 

29 For the induced-SGTR events (which account for approximately 80 percent of the total SGTR30 related release frequency), the radiation levels in the vicinity of the valve is expected to be too 

31 high to permit operators to install and utilize the gagging device. Thus, the gagging device 

32 would not provide benefits in induced-SGTR events. With regard to SGTR-initiated events, the 

33 gagging device would only provide benefits for a limited subset of events, specifically, events in 

34 which the operators follow the emergency operating procedures (EOPs), but fail to cool down 

35 and depressurize in time to prevent overfilling the steam generator. (If operators were not 

36 following the EOPs, then secondary pressure would keep rising and the gagging device could 

37 not be used.) Given that operators follow the EOPs but fail to prevent overfilling the steam 

38 generator, the EOPs direct the operators to continue to cool down and depressurize the RCS to 

39 cold shutdown conditions and to establish heat removal using the residual heat removal (RHR) 

40 system. If this is successful, core damage is prevented. If a gagging device is used to re-close 

41 the stuck open safety valve, achieving cold shutdown and use of the RHR is not needed as heat 

42 can be removed via the intact (or faulted) steam generator without loss of reactor coolant 

43 inventory. Thus, the risk associated with failure to achieve cold shutdown and use RHR would 

44 be eliminated by the gagging device. 
Appendix F 

February 2010 F-39 Draft NUREG-1437, Supplement 40 

1 To determine the benefit associated with the use of a gagging device, DEK revised the SAMA 

2 base case model to eliminate the operator execution error and the hardware failures associated 

3 with establishing RHR cooling following a SGTR with stuck-open safety valve. The result was a 

0.4 percent reduction in CDF (from 8.089 x 10-5 per year to 8.060 x 10-5 4 per year) and a 1.1 

5 percent reduction in offsite person-rem per year (from 30.19 person-rem per year to 29.86 

6 person-rem per year). The total averted cost is about $19,000 at a 7 percent discount rate, and 

7 $35,000 accounting for uncertainty. Based on an estimated cost of procuring a gagging device 

8 and preparing procedures for its use of $50,000, DEK concluded that this potential 

9 enhancement would not be cost-beneficial (DEK, 2009c). The NRC staff notes that this benefit 

10 estimate does not include doubling to account for external events, but that this is considered 

11 appropriate because SGTR events would not generally occur as a direct result of an external 

12 event and this SAMA would not have any associated benefit for these events. 

13 The NRC staff concurs with DEK’s conclusions regarding these alternative SAMAs because the 

14 NRC staff finds the additional information provided by DEK for the aforementioned alternative 

15 SAMAs to be technically sound. 

16 In the discussion of the conclusions of the cost-benefit analysis, DEK identified the individual 

17 SAMAs that address improving the availability of HVAC. The SAMAs identified were those 

18 found to be cost-beneficial in the baseline analysis (SAMAs 80, 82, 83, 170, and 171), plus 

19 those found to be cost-beneficial due to synergies, if the SAMAs were implemented concurrently 

20 (SAMAs 81, 160, 166 and 167). In response to an RAI, DEK noted that the latter four SAMAs 

21 would be included within the set of SAMAs that they intend to review further for possible 

22 implementation as part of DEK’s ongoing performance improvement program (DEK, 2009a). In 

23 a request for clarification, the NRC staff noted that SAMA 160, Insulate EDG Exhaust Ducts, 

24 was not included in the evaluation of simultaneous implementation in Section 7.7 of the ER. In 

25 response, DEK agreed that SAMA 160 should not have been included as a SAMA to be 

26 considered further, since it does not have any implementation synergisms with the HVAC 

27 SAMAs and there would be no noticeable risk reduction if implemented alone. DEK, however, 

28 indicated SAMA 160 will be considered further when risk reduction strategies are evaluated in 

29 the future (DEK, 2009b). 

30 The NRC staff concludes that, with the exception of the potentially cost-beneficial SAMAs 

31 discussed above, the costs of the SAMAs evaluated would be higher than the associated 

32 benefits. 

33 F.7. Conclusions 

34 DEK compiled a list of 189 SAMAs based on a review of the most significant basic events from 

35 the current (at the time of the ER preparation) plant-specific PRA, insights from the plant36 specific IPE and IPEEE, Phase 2 SAMAs from license renewal applications for other plants, and 

37 review of other industry documentation. An initial screening removed SAMA candidates that (1) 

38 are not applicable at KPS due to design differences, (2) have been effectively implemented at 

39 KPS, (3) have estimated costs that would exceed the dollar value associated with completely 

40 eliminating all severe accident risk at KPS, or (4) have a very low benefit because they are 

41 associated with a non-risk-significant system. Based on this screening, 125 SAMAs were 

42 eliminated, leaving 64 candidate SAMAs for evaluation. 
Appendix F 

Draft NUREG-1437, Supplement 40 F-40 February 2010 

1 For the remaining 64 SAMA candidates, a more detailed evaluation was performed as shown in 

2 Table F.5-1. The cost-benefit analyses in the ER showed that 14 SAMA candidates were 

3 potentially cost-beneficial in the baseline analysis (SAMAs 66, 80, 82, 83, 169, 170, 171, 172, 

4 173, 174, 175, 176, 177, and 181). DEK performed additional analyses to evaluate the impact of 

5 parameter choices and uncertainties on the results of the SAMA assessment. As a result, no 

6 additional SAMAs were identified as potentially cost-beneficial. In response to an NRC request, 

7 DEK reviewed the most recent KPS PRA, prepared subsequent to the SAMA evaluation 

8 documented in the ER, and identified one additional potentially cost-beneficial enhancement 

9 involving implementing temporary screenhouse ventilation and installing additional temperature 

10 detectors. DEK also considered the cost savings associated with simultaneous SAMA 

11 implementation and concluded that three additional SAMAs (SAMAs 81, 166 and 167) would be 

12 potentially cost-beneficial if implemented together with SAMAs 82, 83, 160, 170, and 171 (all but 

13 SAMA 160 were found to be potentially cost-beneficial in the baseline analysis). Although not 

14 cost-beneficial, SAMA 160 will also be considered during the evaluation of risk reduction 

15 strategies. DEK has indicated that all these potentially cost-beneficial SAMAs will be considered 

16 for implementation at KPS as part of the ongoing performance improvement program. 

17 The NRC staff reviewed the DEK analysis and concludes that the methods used and the 

18 implementation of those methods were sound. The treatment of SAMA benefits and costs 

19 support the general conclusion that the SAMA evaluations performed by DEK are reasonable 

20 and sufficient for the license renewal submittal. Although the treatment of SAMAs for external 

21 events was somewhat limited, the likelihood of there being cost-beneficial enhancements in this 

22 area was minimized by improvements that have been realized as a result of the IPEEE process, 

23 and inclusion of a multiplier to account for external events. 

24 The NRC staff concurs with DEK’s identification of areas in which risk can be further reduced in 

25 a cost-beneficial manner through the implementation of the identified, potentially cost-beneficial 

26 SAMAs. Given the potential for cost-beneficial risk reduction, the NRC staff agrees that further 

27 evaluation of these SAMAs by DEK is warranted. However, these SAMAs do not relate to 

28 adequately managing the effects of aging during the period of extended operation. Therefore, 

29 they need not be implemented as part of license renewal pursuant to Title 10 of the Code of 

30 Federal Regulations, Part 54. 

31 F.8. References 

32 American Society of Mechanical Engineers (ASME). 2003. “ASME RA-Sa-2003, Addenda to 

33 ASME RA-S-2002 Standard for Probabilistic Risk Assessment for Nuclear Power Plant 

34 Applications.” 

35 Dominion Energy Kewaunee, Inc. (DEK). 2006. Regulatory Meeting Internal Flooding Risk 

36 Reduction Activities, ML063460495, November 30, 2006. 

37 Dominion Energy Kewaunee, Inc. (DEK). 2008a. Kewaunee Power Station, Licensee’s 

38 Environmental Report Operating License Renewal Stage, August 2008. 

39 Dominion Energy Kewaunee, Inc. (DEK). 2008b. Letter from Leslie N. Hartz, Dominion, to U.S. 

40 Nuclear Regulatory Commission Document Control Desk. Subject: “Kewaunee Power Station, 

41 License Amendment Request 242: Extension of the One-time Fifteen Year Containment 

42 Integrated Leak Rate Test Interval,” September 11, 2008. 
Appendix F 

February 2010 F-41 Draft NUREG-1437, Supplement 40 

1 Dominion Energy Kewaunee, Inc. (DEK). 2009a. Letter from Leslie N. Hartz, Dominion, to U.S. 

2 Nuclear Regulatory Commission Document Control Desk. Subject: “Kewaunee Power Station, 

3 Response to Request Additional Information Regarding Severe Accident Mitigation Alternative 

4 for Kewaunee Power Station License Renewal Application”, March 9, 2009. 

5 Dominion Energy Kewaunee, Inc. (DEK). 2009b. Letter from Leslie N. Hartz, Dominion, to U.S. 

6 Nuclear Regulatory Commission Document Control Desk. Subject: “Kewaunee Power Station, 

7 Response to Follow-up Questions Regarding Severe Accident Mitigation Alternative for 

8 Kewaunee Power Station,” June 1, 2009. 

9 Dominion Energy Kewaunee, Inc. (DEK). 2009c. Letter from J. Alan Price, Dominion, to U.S. 

10 Nuclear Regulatory Commission Document Control Desk. Subject: “Kewaunee Power Station, 

11 Response to Follow-up Questions Regarding Severe Accident Mitigation Alternatives,” July 28, 

12 2009. 

13 Electric Power Research Institute (EPRI). 1991. A Methodology for Assessment of Nuclear 

14 Power Plant Seismic Margins, Revision 1. EPRI Report NP-6041-SL. 

15 Entergy Nuclear Northeast (Entergy). 2008. Letter from Fred R. Dacimo, Entergy Nuclear 

16 Northeast, to U. S. Nuclear Regulatory Document Control Desk. Subject: “Supplemental Reply 

17 to Request for Additional Information Regarding License Renewal Application – Severe 

18 Accident Mitigating Alternatives,” May 22, 2008. 

19 First Energy Nuclear Operating Company (FENOC). 2007. License Renewal Application. 

20 August 27, 2007. 

21 Kennedy, R. P. 1999. “Overview of Methods for Seismic PRA and Margin Analysis Including 

22 Recent Innovations”, Proceedings of the OECD-NEA Workshop of Seismic Risk, Tokyo, Japan, 

23 10-12 August 1999. 

24 Nuclear Management Company, LLC (NMC). 2005. Letter from Michael G. Gaffney, Nuclear 

25 Management Company, LLC to U. S. Nuclear Regulatory Commission Document Control Desk. 

26 Subject: “Response to Request for Additional Information Regarding Risk-Informed Inservice 

27 Inspection Program Plan (TAC No. MC2537).” June 17, 2000. 

28 Nuclear Energy Institute (NEI). 2005. “Severe Accident Mitigation Alternative (SAMA) Analysis 

29 Guidance Document”, NEI 05-01 (Rev. A), November 2005. 

30 State of Wisconsin, 2003. Final Projections for Wisconsin Counties by Components of Change”. 

31 Available URL: http://www.doa.state.wi.us/docs_view2.asp?docid=2065

32 TOMCOD, 2005. “Evacuation time Estimate Study for the Kewaunee Power Station Emergency 

33 Planning Zone (EPZ)”, TOMCOD, Inc. August 8, 2005. 

34 U.S. Department of Agriculture (USDA). 1998. “1997 Census of Agriculture, National Agriculture 

35 Statistics Service,” 1998. Available URL: 

36 http://www.nass.usda.gov/census/census97/volume1/vol1pubs.htm

37 U.S. Department of Agriculture (USDA). 2002. 2002 Census of Agriculture, Volume 1 

38 Geographic Area Series Census, State-county Data,” Available URL: 

39 http://www.nass.usda.gov/census/create_census_US_CNTY.jsp

40 U. S. Geologic Survey (USGS). 2008. “2008 NSHM Gridded Data, Peak Ground Acceleration,” 

41 Available URL: http://earthquake.usgs.gov/research/hazmaps/products_data/2008/data
Appendix F 

Draft NUREG-1437, Supplement 40 F-42 February 2010 

1 U.S. Nuclear Regulatory Commission (NRC). 1990. Severe Accident Risks: An Assessment for 

2 Five U.S. Nuclear Power Plants. NUREG-1150, Washington, D.C., December 1990. 

3 U.S. Nuclear Regulatory Commission (NRC). 1991. Generic Letter No. 88-20, Supplement 4, 

4 “Individual Plant Examination of External Events for Severe Accident Vulnerabilities,” NUREG5 1407, Washington, D.C., June 28, 1991. 

6 U.S. Nuclear Regulatory Commission (NRC). 1994. Revised Livermore Seismic Hazard 

7 Estimates for Sixty-Nine Nuclear Power Plant Sites East of the Rocky Mountains. NUREG8 1448, Washington, D.C., March 1994. 

9 U.S. Nuclear Regulatory Commission (NRC). 1997a. Regulatory Analysis Technical Evaluation 

10 Handbook. NUREG/BR-0184, Washington, D.C., January 1997. 

11 U.S. Nuclear Regulatory Commission (NRC). 1997b. Letter from Richard J. Laufer, U.S. NRC, 

12 to M. L. Marchi, Wisconsin Public Service Corporation. Subject: “Review of Individual Plant 

13 Examination for Internal Events,” (TAC No. M74424), January 15, 1997. 

14 U.S. Nuclear Regulatory Commission (NRC). 1997c. Individual Plant Examination Program: 

15 Perspectives on Reactor Safety and Plant Performance. NUREG-1560, Washington, D.C. 

16 December 1997. 

17 U.S. Nuclear Regulatory Commission (NRC). 1998. Letter from William O. Long, U.S. NRC to 

18 M. L. Marchi, Wisconsin Public Service Corporation, Subject: “Kewaunee Nuclear Power Plant – 

19 Safety Evaluation for USI A-46 Program Implementation, Revision 1 (TAC No. M69455),” May 

20 26, 1998. 

21 U.S. Nuclear Regulatory Commission (NRC). 1999. Letter from Tae Kim, U.S. NRC to M. L. 

22 Marchi, Wisconsin Public Service Corporation, Subject: Kewaunee Nuclear Power Plant - 

23 Review of Individual Plant Examination for External Events (IPEEE) Submittal (TAC No. 

24 M83633),” October 5, 1999. 

25 U.S. Nuclear Regulatory Commission (NRC). 2003. “SECPOP 2000: Sector Population, Land 

26 Fraction, and Economic Estimation Program.” NUREG/CR-6525 Revision 1, Washington, D.C., 

27 August 2003. 

28 U.S. Nuclear Regulatory Commission (NRC). 2004. Regulatory Analysis Guidelines of the U.S. 

29 Nuclear Regulatory Commission. NUREG/BR-0058, Revision 4, Washington, D.C., September 

30 2004. 

31 U.S. Nuclear Regulatory Commission (NRC). 2007. Letter from Pao-Tsin Kuo, U.S.NRC, to 

32 James H. Riley, Nuclear Energy Institute, subject: “Final License Renewal Interim Staff 

33 guidance LR-ISG-2006-03: Staff Guidance for Preparing Severe Accident Mitigation Alternatives 

34 Analysis,” August 2, 2007. 

35 U.S. Nuclear Regulatory Commission (NRC). 2009a. Letter from Sarah Lopas, U.S. NRC, to 

36 David A. Christian, Dominion Energy Kewaunee, Inc., Subject: “Request for Additional 

37 Information Regarding Severe Accident Mitigation Alternatives for the Kewaunee Power Station 

38 (TAC No. MD9409),” January 8, 2009. 

39 U.S. Nuclear Regulatory Commission (NRC). 2009b. Memorandum by Sarah Lopas, U.S. NRC, 

40 Subject: “Summary of Conference Call with Dominion Energy Kewaunee, Inc. to Discuss 

41 Responses to Severe Accident Mitigation Alternatives Request for Additional Information for the 

42 Kewaunee Power Station (TAC No. MD9409),” April 22, 2009. 
Appendix F 

February 2010 F-43 Draft NUREG-1437, Supplement 40 

1 Wisconsin Public Service Corporation (WPSC). 1992. Letter from C. R. Steinhardt, WPSC to 

2 U.S. Nuclear Regulatory Commission Document Control Desk. Subject: “Docket No. 50-305, 

3 Operating License No. DPR-43, Kewaunee Nuclear Power Plant, Response to Generic Letter 

4 88-20, Individual Plant Examination,” December 1, 1992. 

5 Wisconsin Public Service Corporation (WPSC). 1994a. Letter from C. R. Steinhardt, WPSC to 

6 U.S. Nuclear Regulatory Commission Document Control Desk. Subject: “Docket No. 50-305, 

7 Operating License No. DPR-43, Kewaunee Nuclear Power Plant, Response to Generic Letter 

8 88-20, Supplement 4. Individual Plant Examination of External Events,” June 28, 1994. 

9 Wisconsin Public Service Corporation (WPSC). 1994b. Letter from C. R. Steinhardt, WPSC to 

10 U.S. Nuclear Regulatory Commission Document Control Desk. Subject: “Docket No. 50-305, 

11 Operating License No. DPR-43, Kewaunee Nuclear Power Plant, Response to Generic Letter 

12 88-20 Individual Plant Examination,” September 21, 1994. 

13 Wisconsin Public Service Corporation (WPSC). 1995. Letter from C. R. Steinhardt, WPSC to 

14 U.S. Nuclear Regulatory Commission Document Control Desk. Subject: “Docket No. 50-305, 

15 Operating License No. DPR-43, Kewaunee Nuclear Power Plant, Response to Request for 

16 Additional Information Regarding Individual Plant Examination for External Events,” October 13, 

17 1995. 

18 Wisconsin Public Service Corporation (WPSC). 1998. Letter from Mark L Marchi, WPSC to U.S. 

19 Nuclear Regulatory Commission Document Control Desk. Subject: “Docket No. 50-305, 

20 Operating License No. DPR-43, Kewaunee Nuclear Power Plant, Response to Supplemental 

21 Request for Additional Information Regarding Individual Plant Examination for External Events,” 

22 September 28, 1998. 

23 

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 40

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 40

Regarding Kewaunee Power Station

Draft Report for Comment

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 above

provide name and mailing address.)

and mailing address.)

10. SUPPLEMENTARY NOTES

Docket No. 50-00305

11. ABSTRACT (200 words or less)

This draft supplemental environmental impact statement (SEIS) has been prepared in response to an application submitted by

Dominion Energy Kewaunee, Inc. (DEK) to renew the operating license for Kewaunee Power Station (KPS) for an additional 20

years. This draft SEIS includes the preliminary analysis that evaluates the environmental impacts of the proposed action and

alternatives to the proposed action. It also includes the NRC's recommendation regarding the proposed action.

The NRC's preliminary recommendation is that the adverse environmental impacts of license renewal for KPS 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) information submitted in DEK's Environmental Report; (3) consultation

with other Federal, State, and local agencies; (4) a review of other pertinent studies and reports; and (5) a consideration of public

comments received during the scoping process.

12. KEY WORDS/DESCRIPTORS (List words or phrases that will assist researchers in locating the report.)

Kewaunee Power Station

KPS

Supplement to the Generic Environmental Impact Statement

DSEIS

National Environmental Protection Act

NEPA

License Renewal

GEIS

NUREG 1437, Supplement 40

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, D.C. 20555-0001