*U.S.NRC

United States Nuclear Regulatory Commission

Protecting People and the Environment

NUREG-1437

Supplement 41

Generic Environmental

Impact Statement for

License Renewal of

Nuclear Plants

Supplement 41

Regarding Cooper Nuclear

Station

Final Report

Office of Nuclear Reactor Regulation
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7U.S.NRC

United States Nuclear Regulatory Commission

Protecting People and the Environment

NUREG-1437

Supplement 41

Generic Environmental

Impact Statement for

License Renewal of

Nuclear Plants

Supplement 41

Regarding Cooper Nuclear

Station

Final Report

Manuscript Completed: July 2010

Date Published: July 2010

Office of Nuclear Reactor Regulation

ABSTRACT

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

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

for Cooper Nuclear Station for an additional 20 years.

This SEIS includes the analysis that evaluates the environmental impacts of the proposed

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

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

combination of alternatives that includes natural gas combined-cycle generation, energy

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

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

the adverse environmental impacts of license renewal for Cooper Nuclear Station are not so

great that preserving the option of license renewal for energy-planning decision makers would

be unreasonable.

July 2010 iii NUREG-1437, Supplement 41

TABLE OF CONTENTS

A b stra ct ....................................................................................................................................... iii

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

F ig u re s ....................................................................................................................................... x i

T a b le s ...................................................................................................................................... x ii

Executive Sum m ary .................................................................................................................... xv

Abbreviations and Acronym s .................................................................................................... xxiii

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

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

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

1.3 M ajor Environm ental Review M ilestones ....................................................................... 1-1

1.4 Generic Environm ental Im pact Statem ent ...................................................................... 1-4

1.5 Supplem ental Environm ental Im pact Statem ent ............................................................ 1-6

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

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

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

1.9 Status of Com pliance ..................................................................................................... 1-9

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

2.0 Affected Environm ent ........................................................................................................ 2-1

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

2.1.1 Reactor and Containm ent System s ......................................................................... 2-1

2.1.2 Radioactive W aste M anagem ent ............................................................................. 2-5

2.1.2.1 Radioactive Liquid W aste .................................................................................. 2-6

2.1.2.2 Radioactive Gaseous W aste ............................................................................. 2-6

2.1.2.3 Radioactive Solid W aste ................................................................................... 2-7

2.1.3 Nonradiological W aste M anagem ent ....................................................................... 2-8

2.1.3.1 Nonradioactive W aste Stream s ......................................................................... 2-8

2.1.3.2 Pollution Prevention and W aste M inim ization ................................................... 2-9

2.1.4 Plant O peration and M aintenance ......................................................................... 2-10

2.1.5 Power Transm ission System .............................................................. . ..... 2-10

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

2.1.7 Facility W ater Use and Quality .............................................................................. 2-17

2.1.7.1 Ground W ater Use and Q uality ....................................................................... 2-17

2.1.7.2 Surface W ater Use and Q uality ....................................................................... 2-18

2.1.7.3 National Pollutant Discharge Elim ination System ........................................... 2-19

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

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

2.2.1 Land Use ............................................................................................................... 2-21

2.2.2 Clim ate and M eteorology ....................................................................................... 2-23

2.2.2.1 Air Q uality Im pacts .......................................................................................... 2-24

2.2.3 Ground W ater Resources ...................................................................................... 2-25

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

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

July 2010 v NUREG-1437, Supplement 41
Table of Contents

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

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

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

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

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

2.2.5.6 Primary Producers: Phytoplankton, Periphyton, and Aquatic

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

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

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

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

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

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

2.2.7.1 Aquatic Species .............................................................................................. 2-49

2.2.7.2 Terrestrial Species .......................................................................................... 2-52

2.2.8 Socioeconomic Factors ......................................................................................... 2-56

2.2.8.1 Housing ........................................................................................................... 2-57

2.2.8.2 Public Services ................................................................................................ 2-58

2.2.8.3 Offsite Land Use ............................................................................................. 2-62

2.2.8.4 Visual Aesthetics and Noise ............................................................................ 2-63

2.2.8.5 Demography .................................................................................................... 2-64

2.2.8.6 Economy ......................................................................................................... 2-70

2.2.9 Historic and Archaeological Resources ................................................................. 2-73

2.2.9.1 Cultural Background ........................................................................................ 2-73

2.2.9.2 Prehistoric Periods .......................................................................................... 2-73

2.2.9.3 Historic Period ................................................................................................. 2-74

2.2.10 Historic and Archaeological Resources at the Cooper Nuclear Station Site ....... 2-75

2.3 Related Federal and State Activities ............................................................................ 2-76

2.4 References ................................................................................................................... 2-77

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 Ground W ater ................................................................................................................. 4-2

4.3.1 Generic Ground W ater Issues ................................................................................. 4-2

4.3.2 Ground W ater Use Conflicts .................................................................................... 4-2

4.4 Surface W ater ................................................................................................................ 4-3

4.4.1 Generic Surface W ater Issues ................................................................................. 4-3

4.4.2 W ater Use Conflicts ................................................................................................. 4-4

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

4.5.1 Generic Aquatic Ecology Issues .............................................................................. 4-5

4.5.2 Entrainment and Im pingement ................................................................................. 4-5

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

4.5.2.2 History of Cooper Nuclear Station's 316(b) Com pliance ................................... 4-6

4.5.2.3 Analysis ............................................................................................................. 4-7

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

4.5.4 Total Im pacts on Aquatic Resources ..................................................................... 4-10

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

4.7 Threated and Endangered Species .............................................................................. 4-12

NUREG-1437, Supplement 41 vi July 2010
Table of Contents

4.7.1 Aquatic Species ..................................................................................................... 4-12

4.7.2 Terrestrial Species ................................................................................................. 4-13

4.8 Hum an Health .............................................................................................................. 4-14

4.8.1 Generic Hum an Health Issues ............................................................................... 4-15

4.8.2 M icrobiological O rganism s ..................................................................................... 4-16

4.8.3 Electrom agnetic Fields - Acute Shock .................................................................. 4-18

4.8.4 Electrom agnetic Fields - Chronic Effects .............................................................. 4-18

4.9 Socioeconom ics ........................................................................................................... 4-19

4.9.1 Generic Socioeconom ic Issues ............................................................................. 4-19

4.9.2 Housing Im pacts .................................................................................................... 4-20

4.9.3 Public Services: Public Utilities ................................. 4-20

4.9.4 Offsite Land Use - License Renewal Period ......................................................... 4-21

4.9.4.1 Population-Related Im pacts ............................................................................ 4-21

4.9.4.2 Tax Revenue-Related Im pacts ........................................................................ 4-21

4.9.5 Public Services: Transportation Im pacts ............................................................... 4-22

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

4.9.7 Environm ental Justice ............................................................................................ 4-24

4.9.7.1 M inority Population in 2000 ............................................................................. 4-26

4.9.7.2 Low-Incom e Population in 2000 ...................................................................... 4-28

4.9.7.3 Analysis of Im pacts ......................................................................................... 4-32

4.9.7.4 Subsistence Consum ption of Fish and W ildlife ............................................... 4-32

4.10 Evaluation of New and Potentially Significant Inform ation ......................................... 4-34

4.11 Cum ulative Im pacts .................................................................................................... 4-35

4.11.1 Cum ulative Im pacts on W ater Resources ........................................................... 4-35

4.11.2 Cumulative Impacts on Electromagnetic Fields and Thermophilic

M icrobiological O rganism s ................................................................................. 4-36

4.11.3 Cum ulative Im pacts on Aquatic Resources ......................................................... 4-37

4.11.4 Cum ulative Im pacts on Terrestrial Resources ..................................................... 4-40

4.11.5 Cum ulative Air Q uality Im pacts ............................................................................ 4-43

4.11.6 Cum ulative Hum an Health Im pacts ..................................................................... 4-45

4.11.7 Cum ulative Socioeconom ic Im pacts .................................................................... 4-4 5

4.11.8 Sum m ary of Cum ulative Im pacts ......................................................................... 4-46

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

5.0 Environm ental Im pacts of Postulated Accidents ................................................................ 5-1

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

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

5.3 Severe Accident M itigation Alternatives ........................................................................ 5-3

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

5.3.2 Estim ate of Risk ....................................................................................................... 5-4

5.3.3 Potential Plant Im provements .................................................................................. 5-5

5.3.4 Evaluation of Risk Reduction and Costs of Im provem ents ...................................... 5-5

5.3.5 Cost-Benefit Com parison .......................................................................................... 5-6

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

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

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

G reenhouse Gas Em issions ........................................................................................... 6-1

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

6.2 Greenhouse gas em issions ............................................................................................ 6-2

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

July 2010 vii NUREG-1437, Supplement 41
Table of Contents

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

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

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

6.2.1.4 Summary of Nuclear Greenhouse Gas Emissions Compared to

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

6.2.1.5 Summary of Nuclear Greenhouse Gas Emissions Compared to

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

6.2.2 Conclusions: Relative Greenhouse Gas Emissions ................................................ 6-8

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

7.0 Environmental Impacts of Decomm issioning ..................................................................... 7-1

7.1 Decom m issioning ........................................................................................................... 7-1

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

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

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

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

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

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

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

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

8.1.1.5 Carbon Dioxide ................................................................................................. 8-7

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

8.1.2 Ground W ater Use and Quality ................................................................................ 8-7

8.1.3 Surface W ater Use and Quality ............................................................................... 8-7

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

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

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

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

8.1.6 Socioeconom ics ...................................................................................................... 8-9

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

8.1.6.2 Socioeconom ics .............................................................................................. 8-10

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

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

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

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

8.1.7 W aste Management ............................................................................................... 8-12

8.2 Natural Gas-Fired Com bined-Cycle Generation ........................................................... 8-13

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

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

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

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

8.2.1.5 Construction Im pacts ...................................................................................... 8-15

8.2.2 Ground W ater Use and Quality .............................................................................. 8-16

8.2.3 Surface W ater Use and Quality ............................................................................ 8-16

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

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

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

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

8.2.6 Socioeconom ics ..................................................................................................... 8-17

8.2.6.1 Land Use ......................................................................................................... 8-17

NUREG-1437, Supplement 41 viii July 2010
Table of Contents

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

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

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

8.2.6.5 Historic and Archaeological Resources .......................................................... 8-19

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

8.2.7 W aste Management ............................................................................................... 8-20

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

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

8.3.2 Ground W ater Use and Quality .............................................................................. 8-23

8.3.3 Surface W ater Use and Quality ............................................................................. 8-23

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

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

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

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

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

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

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

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

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

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

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

8.3.7 W aste Management ............................................................................................... 8-29

8.4 Alternatives Considered but Dism issed ........................................................................ 8-30

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

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

8.4.3 New Nuclear .......................................................................................................... 8-30

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

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

8.4.6 Solar Power ............................................................................................................ 8-31

8.4.7 Biomass W aste ...................................................................................................... 8-32

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

8.4.9 W ave and Ocean Energy ....................................................................................... 8-32

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

8.4.11 Municipal Solid-W aste ......................................................................................... 8-33

8.4.12 Biofuels ................................................................................................................ 8-33

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

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

8.4.15 Delayed Retirement ............................................................................................. 8-34

8.5 No-Action Alternative .................................................................................................... 8-34

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

8.5.2 Ground W ater Use and Quality .............................................................................. 8-35

8.5.3 Surface W ater Use and Quality ............................................................................. 8-35

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

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

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

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

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

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

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

8.5.6.3 Transportation ................................................................................................. 8-36

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

July 2010 ix NUREG-1437, Supplement 41
Table of Contents

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

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

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

8.6 Alternatives Summary .................................................................................................. 8-37

8 .7 R efe re nce s ................................................................................................................... 8-39

9 .0 C o n c lu sio n ......................................................................................................................... 9 -1

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

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

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

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

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

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

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

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

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

1 1 .0 In d e x .............................................................................................................................. 1 1 -1

12.0 List of Agencies, Organizations, and Persons to Whom Copies of the

Supplemental Environmental Impact Statement are Sent ............................................ 12-1

Appendix A. Comments Received on the Cooper Nuclear Station Environmental

R e v ie w ........................................................................................................................... A -1

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

P ow e r P la nts .................................................................................................................. B -1

Appendix C. Applicable Regulations, Laws, and Agreements ........................................... C-1

Appendix D. Consultation Correspondences ..................................................................... D-1

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

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

M a ry la n d ..................................................................................................................... D .2 -1

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

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

Mitigation Alternatives for Cooper Nuclear Station In Support of License Renewal

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

NUREG-1437, Supplement 41 x July 2010
Table of Contents

FIGURES

Figure 1-1. Environmental Review Process ............................................................................... 1-3

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

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

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

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

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

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

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

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

Figure 2:2.1-1. Cooper Nuclear Station Facility Location ........................................................ 2-21

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

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

their interactions that govern the integrity of the aquatic biota of

M idw estern stream s ............................................................................................ 2-28

Figure 2.2.6-1. Nontidal Wetlands Located on the Cooper Nuclear Station Site ..................... 2-37

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

(Ind ivid ua l S tate ) ................................................................................................. 4 -2 7

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

(C om bined S tate ) ............................................................................................... 4-28

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

(Ind ivid ua l S tate ) ................................................................................................ 4 -30

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

(C om bined State) .......................................................................................... 4-3!

Figure 3-1. Location of Cooper Nuclear Station, 50-mile (80-kilometer) Region ................... D.2-2

Figure 3-2. Location of Cooper Nuclear Station, 6-miles (10-kilometer) Region ................... D.2-3

Figure 3-3. Cooper Nuclear Station, General Site Layout ..................................................... D.2-5

Figure 3-4. Cooper Nuclear Station, Intake Structure Plan .................................................... D.2-7

Figure 3-5. Cooper Nuclear Station, Intake Structure Section ............................................... D.2-7

Figure 3-6. Cooper Nuclear Station, Typical Dual Flow Screen ............................................ D.2-8

July 2010 xi NUREG-1437, Supplement 41
Table of Contents

TABLES

Summary of Environmental Impacts of Proposed Action and Alternatives ................................ xxi

Table 1-1. Licenses and Perm its ............................................................................................. 1-10

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

System Permit for Cooper Nuclear Station ......................................................... 2-19

Table 2.2.7-1. Listed Aquatic and Terrestrial Species ............................................................. 2-40

Table 2.2.8-1. Cooper Nuclear Station Employee Residence by County ................................ 2-57

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

Atchison C ounty in M issouri ............................................................................... 2-58

Table 2.2.8.2-1. Public Water Supply Systems (thousand gallons per day) ............................ 2-60

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

2006 Average Annual Daily Traffic Count ........................................................... 2-62

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

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

and Projected for 2007 to 2050 .......................................................................... 2-64

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

Four-County Socioeconomic Region of Influence in 2000 .................................. 2-65

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

Four-County Socioeconomic Region of Influence in 2007, Estimated ................ 2-66

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

N uclea r S tatio n ................................................................................................... 2-67

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

Located within 50 Miles of the Cooper Nuclear Station ...................................... 2-69

Table 2.2.8.6-1. Major Employers in Nemaha County ............................................................. 2-70

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

T lof Influence in 2007 ............................................................................................ 2-71

Table 2.2.8.6-3. Cooper Nuclear Station Estimated Tax Distribution, 2005-2007 .................. 2-72

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

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

Table 4-1. Land U se Issues ....................................................................................................... 4-1

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

Table 4-3. Aquatic Resources Issues ........................................................................................ 4-5

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

Table 4-5. H um an H ealth Issues ............................................................................................. 4-14

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

Table 4-7. Category 2 Issues Applicable to Socioeconomics and Environmental Justice

D uring the Renew al Term ................................................................................... 4-20

T able 4-8 . Inta kes .................................................................................................................... 4-39

Table 4-9. S tastny 2004 ........................................................................................................... 4-4 0

Table 4-10. Summary of Cumulative Impacts on Resources Areas ........................................ 4-46

Table 5-1. Cooper Nuclear Station, Core Damage Frequency for Internal Events .................... 5-4

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

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

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

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

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

S o u rc e s ................................................................................................................. 6 -7

Table 7-1. Category 1 Issues Applicable to the Decommissioning of Cooper Nuclear

Station Following the Renewal Term .................................................................... 7-1

NUREG-1437, Supplement 41 xii July 2010
Table of Contents

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

Alternative Compared to Continued Operation of Cooper Nuclear Station ......... 8-13

Table 8-2. Summary of Environmental Impacts of the Natural Gas-Fired,

Combined-Cycle Generation Alternative Compared to Continued

Operation of Cooper Nucler Station .................................................................... 8-21

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

Compared to Continued Operation of Cooper Nuclear Station .......................... 8-29

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

Operation of Cooper Nuclear Station .................................................................. 8-37

Table 8-5. Summary of Environmental Impacts of Proposed Action and Alternatives ............. 8-38

Table 10-1. List of P reparers ................................................................................................... 10-1

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

Table A-2. Structures and Operations of Cooper and Fort Calhoun Generating Stations

That Affect Aquatic Resources .......................................................................... A-50

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

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

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

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

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

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

S u m m a ry ........................................................................................................ . . F -5

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

C ore D am age Frequency .................................................................................... F-8

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

C ooper N uclear S tation ..................................................................................... F-21

July 2010 xiii NUREG-1437, Supplement 41i

EXECUTIVE SUMMARY

BACKGROUND

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

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

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

Pursuant to Title 10, Part 51.20(b)(2) of the Code of Federal Regulations (10 CFR 51.20(b)(2)),

the Commission indicates that a renewal of a power reactor operating license requires

preparation of an environmental impact statement (EIS) or a supplement to an existing EIS. In

addition, 10 CFR 51.95(c) states that the Commission shall prepare an EIS, which is a

supplement to the Commission's Generic Environmental Impact Statement for License Renewal

of Nuclear Plants (GELS), NUREG-1437, published in May 1996.

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

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

environmental impact statement (SEIS) and conduct scoping. In preparation of this SEIS for

CNS, the NRC staff performed the following:

conducted public scoping meetings on February 25, 2009, in Brownville and

Auburn, NE

* conducted a site audit at the plant in late March 2009

* reviewed NPPD's environmental report (ER) and compared it to the GElS

• consulted with other agencies

* conducted a review of the issues following the guidance set forth in

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

Power Plants, Supplement 1: Operating License Renewal (NRC, 2000)

considered public comments received during the scoping process

PROPOSED ACTION

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

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

DPR-46 will expire on January 18, 2014. The NRC's Federal action is the decision whether or

not to renew the license for an additional 20 years.

July 2010 XV NUREG-1437, Supplement 41
Executive Summary

PURPOSE AND NEED FOR ACTION

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

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

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

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

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

review required by the Atomic Energy Act of 1954 (AEA) or findings in the National

Environmental Policy Act (NEPA) environmental analysis that would lead to the rejection of a

license renewal application, the NRC does not have a role in the energy-planning decisions of

State regulators and utility officials as to whether a particular nuclear power plant should

continue to operate.

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

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

ENVIRONMENTAL IMPACTS OF LICENSE RENEWAL

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

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

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

criteria:

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

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

specified plant or site characteristics.

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

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

high-level waste and spent fuel disposal.

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

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

be sufficiently beneficial to warrant implementation.

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

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

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

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

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

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

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

I of license renewal of CNS. Neither NPPD nor the NRC identified information that is both new

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

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

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

upon the conclusions of the GElS for all Category 1 issues applicable to CNS.

NUREG-1437, Supplement 41 xvi July 2010
Executive Summary

LAND USE

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

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

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

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

mitigation measures are not sufficiently beneficial to be warranted.

AIR QUALITY

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

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

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

GELS.

GROUND WATER USE AND QUALITY

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

ground water issues. Ground water use conflicts: potable and service water-plants using

greater than 100 gallons per minute is a Category 2 issue related to license renewal at CNS.

Because of the limited radius of influence of CNS wells in the unconfined aquifer, no public

ground water supplies are close enough to CNS to be impacted by ground water use at the

station. There are no well-head protection areas or Environmental Protection Agency (EPA)

designated sole source aquifers in the vicinity of CNS. Therefore, the impact of ground water

use by CNS is SMALL.

SURFACE WATER USE AND QUALITY

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

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

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

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

GElS that the impacts are SMALL.

AQUATIC RESOURCES

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

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

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

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

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

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

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

CNS's operating license is SMALL.

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

shellfish and heat shock, the NRC staff reviewed field studies on the total impact of CNS's

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

impact on aquatic resources due to all aspects of CNS's cooling system operation is SMALL.

TERRESTRIAL RESOURCES

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

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

July 2010 xvii NUREG-1437, Supplement 41
Executive Summary

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

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

related to these issues beyond those discussed in the GElS. The GElS further concludes that

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

sufficiently beneficial to implement.

THREATENED AND ENDANGERED SPECIES

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

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

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

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

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

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

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

term would be SMALL.

HUMAN HEALTH

SMALL. The NRC staffs review of the historical radioactive releases from CNS and the

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

radiation protection standards. Continued compliance with regulatory requirements is expected

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

expected to change during the license renewal term.

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

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

issues, the NRC's conclusion in the GElS was that the impacts are SMALL and additional

site-specific mitigation measures are not likely to be sufficiently beneficial to be warranted.

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

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

to the microbiological organisms issue and concludes that thermophilic microbiological

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

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

I microbiological organisms from continued operation of CNS in the license renewal period are

SMALL.

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

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

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

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

SMALL.

SOCIOECONOMICS

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

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

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

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

transportation), and historic and archaeological resources.

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

I during outages, employment levels at CNS would remain relatively constant with no additional

NUREG-1437, Supplement 41 xviii July 2010
Executive Summary

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

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

been experienced.

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

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

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

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

experienced.

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

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

no transportation impacts. Therefore, offsite land use and transportation issues would remain

relatively unchanged.

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

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

historic and archaeological resources could be located several feet beneath the ground surface.

NPPD has instituted a stop work order within its Cultural Resource Protection Plan to ensure

that proper notification is taken to protect these resources should they be discovered. Based on

a review of Nebraska State Historical Society (NSHS) files (archaeological surveys,

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

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

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

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

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

radius of CNS indicated there would be no disproportionately high and adverse impacts to these

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

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

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

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

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

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

SEVERE ACCIDENT MITIGATION ALTERNATIVES

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

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

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

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

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

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

The NRC staff reviewed the ER's evaluation of potential SAMAs. Subsequent to the ER, a

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

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

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

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

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

July 2010 xix NUREG-1437, Supplement 41
Executive Summary

The NRC staff reviewed NPPD's re-analysis and the methods used by NPPD as submitted by

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

offsite economic cost and that no SAMAs were inappropriately excluded from consideration in

the license renewal application as a result of the error.

Based on the staffs review and the supplemental information provided by NPPD, the NRC staff

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

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

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

ALTERNATIVES

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

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

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

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

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

capacity component, and a wind power component. The NRC staff initially considered a number

I of additional alternatives for analysis as alternatives to license renewal of CNS; these were later

dismissed due to technical, resource availability, or commercial limitations that currently exist

and that the NRC staff believes are likely to continue to exist when the existing CNS license

expires. The no-action alternative by the NRC staff and the effects it would have were also

considered.

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

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

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

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

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

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

summarized in the table on the following page.

COMPARISON OF ALTERNATIVES

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

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

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

(Hg). The corresponding human health impacts and construction impacts to aquatic, terrestrial,

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

alternative the least environmentally favorable alternative.

The gas-fired alternative would have slightly lower air emissions than the coal-fired alternative,

and impacts to aquatic, terrestrial, historic, and archaeological resources would vary depending

upon the location of the plant. Purchased power would likely have operational impacts that

would include aspects of coal-fired, gas-fired, and existing nuclear generation. The combination

alternative would have lower air emissions and waste management impacts than both the

gas-fired and coal-fired alternatives; however, the combination alternative would have relatively

high construction impacts to aquatic, terrestrial, and potential historic and archaeological

resources due mainly to the wind turbine component.

NUREG-1437, Supplement 41 XX July 2010
Executive Summary

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

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

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

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

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

impact.

Summary of Environmental Impacts of Proposed Action and Alternatives

Impact Area

a

L.

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u

U•

4-

U)

0

U)

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CE

.=

8

0

0

0

0

U)

C

0

2

0

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Cu

C

Cu

0

Alternative

License renewal SMALL SMALL SMALL SMALL SMALL SMALL SMALL

Supercritical SMALL to MODERATE

coal-fired alternative MODERATE SMALL SMALL SMALL to SMALL LARGE

at the CNS site MODERATE I

Gas-fired alternative SMALL TO SMALL to SAMD SMALL to T

at the CNS site MODERATE SMALL SMALL MODERATE SMALL MODERATE

Combination of SMALL TO SMALL to SMALL to SMALL to SMALL

alternatives MODERATE SMALL SMALL LARGE MODERATE MODERATE

SMALL to

No-action alternative SMALL SMALL SMALL SMALL SMALL MODERATE SMALL

RECOMMENDATION

Our recommendation is that the Commission determines that the adverse environmental

impacts of license renewal for CNS are not so great that preserving the option of license

renewal for energy planning decision makers would be unreasonable. This recommendation is

based on:

(1) the analysis and findings in the GElS

(2) information submitted in the NPPD's ER

July 2010 xxi NUREG-1437, Supplement 41
Executive Summary

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

(4) review of other pertinent studies and reports

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

NUREG-1437, Supplement 41 xxii July 2010
ABBREVIATIONS AND ACRONYMS

AADT average annual daily traffic

ac acre

ACC averted cleanup and decontamination costs

ADAMS Agencywide Documents Access and Management System

ADS automatic depressurization system

ADV atmospheric dump valve

AEA Atomic Energy Act of 1954

AEC U.S. Atomic Energy Commission

AEO Annual Energy Outlook

ALARA as low as reasonably achievable

AMSL above mean sea level

ANSI American National Standards Institute.

APE area of potential effect

ASDS alternate shutdown system

ASME American Association of Mechnical Engineers

BA biological assessment

BACT best available control technology

BBR Bureau of Business Research

Btu British thermal unit

Btu/ft3 British thermal unit per cubic feet

Btu/kWh British thermal unit per kilowatt-hour

Btu/Ib British thermal unit per pound

BWR boiling-water reactor

BWST borated water storage tank

CAA Clean Air Act

CAFTA cutest and fault tree analysis

CAMR Clean Air Mercury Rule

CDC Center for Disease Control

CDF core damage frequency

CDM Clean Development Mechanism

CENRAP Central Regional Air Planning Association

July 2010 xxiii NUREG-1437, Supplement 41
Abbreviations and Acronyms

CEQ

I CERCLA

CESQG

CET

CFR

cfs

CH4

cm

cm/s

CNS

CO

CO 2

CPPD

CRA

CRD

CRT

CS

CST

CWA

Council on Environmental Quality

Comprehensive Environmental Response, Compensation, and

Liability

conditionally exempt small quantity generator

containment event tree

Code of Federal Regulations

cubic feet per second

methane

centimeter

centimeter per second

Cooper Nuclear Station

carbon monoxide

carbon dioxide

Consumers Public Power District

Conestoga Rover Associates

control rod drive

cathode ray tube

core spray

condensate storage tank

Clean Water Act

decibels adjusted

design-basis accident

insecticide, dichlorodiphenyldichloroethylene

insecticide, dichlorodiphenyltrichloroethane

decay heat closed cooling water

Department of Health and Human Services

decay heat removal

decay heat river water system

Department of Natural Resources

Department of Energy

Department of Transportation

demonstration power reactor

Department of Public Safety

draft supplemental environmental impact statement

dBA

DBA

DDE

DDT

DHCCW

DHHS

DHR

DHRW

DNR

DOE

DOT

DPR

DPS

DSEIS

NUREG-1437, Supplement 41 xxiv July 2010
Abbreviations and Acronyms

DSM demand-side management

E.O. Executive Order

ECCS emergency core cooling system

EDG emergency diesel generator

EFPD effective full-power day

EFW emergency feedwater

EIA Energy Information Administration

EIS environmental impact statement

ELF-EMF extremely low frequency-electromagnetic field

EMF electromagnetic fields

EMS environmental management system

EOP emergency operating procedure

EPA Environmental Protection Agency

EPCRA Emergency Planning and Community Right-to-Know Act

EPRI Electric Power Research Institute

EPZ emergency planning zone

ER environmental report

ESA Endangered Species Act

ESAS engineered safeguards actuation signal

ESRP Environmental Standard Review Plan

F&O fact and observation

FCIA Fire Compartment Interaction Analysis

FCS Fort Calhoun Station

FES final environmental statement

FIVE fire-induced vulnerability evaluation

FR Federal Register

FSAR final safety analysis report

ft foot

ftmin feet per minute

ft3 cubic feet

g Ceq/kWh grams of CO 2 equivalents per kilowatt-hour

GE General Electric

July 2010 xxv NUREG-1437, Supplement 41
Abbreviations and Acronyms

GElS generic environmental impact statement

GHG greenhouse gas

gpm gallons per minute

GRA Generation Risk Assessment

Gy/d grays per day

ha hectare

HAP hazardous air pollutant

HCLPF high confidence in low probability of failure

HFC hydrofluorocarbons

HFE hydrofluorinated ethers

Hg mercury

HID high intensity discharge (light)

HLW high-level waste

HPCI high pressure coolant injection

HPI high-pressure injection

HRA human reliability analysis

HRSG heat recovery steam generator

HVAC heating, ventilation, and air conditioning

IAEA International Atomic Energy Agency

ICCW immediate closed cooling water

IEEE Institute of Electrical and Electronics Engineers

IGCC integrated gasification combined-cycle

Inc. incorporated

Idaho National Energy and Environmental Laboratory

IPCC Intergovernmental Panel on Climate Change

IPE individual plant examination

IPEEE individual plant examination of external events

ISFSI independent spent fuel storage installation

ISLOCA interfacing-systems loss-of-coolant accident

J joule

JHEP joint human error probability

NUREG-1437, Supplement 41 xxvi July 2010
Abbreviations and Acronyms

kg kilogram

km kilometer

km 2 square kilometer

kmh kilometer per hour

kPa kilopascal

kV kilovolt

kWh kilowatt-hour

lb pound

lb/MWh pound per megawatt-hour

LERF large early release frequency

LLC limited liability corporation

LLMW low-level mixed waste

LLNL Lawrence Livermore National Laboratory

LLW low-level radioactive waste

LOCA loss-of-coolant accident

LOOP loss of offsite power

LPI low pressure injection

LQG large quantity generator

m meter

m/min meter per minute

m/s meter per second

m 3 cubic meter

m3/month cubic meter per month

m3/s cubic meter per second

MAAP modular accident analysis program

MACCS2 MELCOR Accident Consequence Code System 2

MCR main control room

MDC Missouri Department of Conservation

MDNR Missouri Department of Natural Resources

mg/L milligrams per liter

mgd million gallons per day

mGy milligray

mGy/d milligray per day

July 2010 xxvii NUREG-1437, Supplement 41
Abbreviations and Acronyms

mi mile

mi 2 square mile

MOU Memorandum of Understanding

MOV motor operated valve

mph mile per hour

mrad milliradiation absorbed dose

mrem milliroentgen equivalent man (mrem)

MSA Magnuson-Stevens Fishery Conservation and Management Act of

1996

MSIV main steam isolation valve

msl mean sea level

MSPI Mitigating System Performace Index

mSv millisievert

MT metric tonnes

MW megawatt

MWd/MTU megawatt-days per metric ton uranium

MWe megawatt-electric

MWt megawatt-thermal

N20 nitrous oxide

NA not applicable

NAAQS National Ambient Air Quality Standards

NAC Nebraska Administrative Code

NAQR Nebraska Air Quality Regulations

NAS National Academy of Sciences

NBPP no break power panel

NCDC National Climatic Data Center

NDE Nebraska Department of Education

NDED Nebraska Department of Economic Development

NDEQ Nebraska Department of Environmental Quality

NDNR Nebraska Department of Natural Resources

NDOR Nebraska Department of Roads

NEI Nuclear Energy Institute

NEPA National Environmental Policy Act of 1969

NESC National Electric Safety Code

NUREG-1437, Supplement 41 xxviii July 2010
Abbreviations and Acronyms

NF3 nitrogen triflouride

ng nanograms

NGPC Nebraska Game and Parks Commission

NHHS Nebraska Department of Health and Human Services

NHPA National Historic Preservation Act

NIEHS National Institute of Environmental Health Sciences

NMFS National Marine Fisheries Service

NNRD Nemaha Natural Resources District

NO 2 nitrogen dioxide

NOAA National Oceanic and Atmospheric Administration

NO, nitrogen oxide(s)

NPDES National Pollutant Discharge Elimination System

NPPD Nebraska Public Power District

NPSH net positive suction head

NRC U.S. Nuclear Regulatory Commission

NRHP National Register of Historic Places

NSCCW nuclear service closed cooling water

NSHS Nebraska State Historical Society

NSR New Source Review

NWPCC Nebraska Water Pollution Control Council

NWS National Weather Service

ODAM Offsite Dose Assessment Manual

ODCM Offsite Dose Calculation Manual

ODNR Ohio Department of Natural Resources

OMB Office of Management and Budget

OPPD Omaha Public Power District

PAH polycyclic aromatic hydrocarbon

PCB polychlorinated biphenyl

pCi/L picocuries per liter

PDS plant damage state

PFC perfluorocarbons

PILOT payments in lieu of taxes

PM particulate matter

July 2010 xxix NUREG-1437, Supplement 41
Abbreviations and Acronyms

PM10 particulate matter, 10 microns or less in diameter

PM2.

5 particulate matter, 2.5 microns or less in diameter

PMF probably maximum flood

PRA probabilistic risk assessment

psig pounds per square inch gage

PWR pressurized water reactor

rad/d radiation absorbed dose per day

RAI request for additional information

RBEC reactor building emergency cooling

RBWMD Rainwater Basin Wetland Management District

RCIC reactor core isolation cooling

RCP reactor coolant pump

RCRA Resource Conservation and Recovery Act

RCS reactor coolant system

REMP radiological environmental monitoring program

RHR residual heat removal

RHRSW residual heat removal service water

RKm river kilometer

RLE review level earthquake

RM river mile

rms root mean square

ROI region of influence

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

RPMA recovery priority management area

RPO regional planning organization

RPS reactor protection system

RPV reactor pressure vessel

RRW risk reduction worth

RWD Rural Water District

SAMA Severe Accident Mitigation Alternative

SAR safety analysis report

SAS security alarm station

SBO station blackout

NUREG-1437, Supplement 41 XXX July 2010
Abbreviations and Acronyms

SC species of concern

SCDHEC South Carolina Department of Health and Environmental Control

SCR selective catalytic reduction

SEIS supplemental environmental impact statement

SER safety evaluation report

SF6 sulfur hexafluoride

SGTR steam generator tube rupture

SHPO State Historic Preservation Office

SLC standby liquid control

SO2 sulfur dioxide

SO3 sulfur trioxide

SOx sulfur oxide(s)

SPDES State Pollutant Discharge Elimination System

SQG small quantity generator

SQUG Seismic Qualification User's Group

SR supporting requirements

SRV safety relief valve

Sv sievert

SWBP service water booster pump

TDEC Tennessee Department of Environment and Conservation

TEC turbine equipment cooling

TSP total suspended particles

TSS total suspended solids

U Uranium

U.S. United States

U.S.C. United States Code

UDEQ Utah Department of Environmental Quality

UNL University of Nebraska-Lincoln

USACE United States Army Corps of Engineers

USCB U.S. Census Bureau

USDA U.S. Department of Agriculture

USFWS U.S. Fish and Wildlife Service

USGCRP United States Global Change Research Program

July 2010 xxxi NUREG-1437, Supplement 41
Abbreviations and Acronyms

USGS U.S. Geological Survey

USI unresolved safety issue

V volt

VOC volatile organic compound

WGA Western Governors Association

WHO World Health Organization

yd3 cubic yard

yd 3/month cubic yard per month

NUREG-1437, Supplement 41 xxxii July 2010
1.0 PURPOSE AND NEED FOR ACTION

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

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

Commission's (NRC's) environmental protection regulations in Title 10, Part 51, "Environmental

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

of Federal Regulations (10 CFR Part 51.20).

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

granted for up to 40 years, but permitted license renewal. The 40-year licensing period was

based on economic and antitrust considerations rather than on technical limitations of the

nuclear facility.

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

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

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

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

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

1.1 PROPOSED FEDERAL ACTION

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

application for license renewal of the Cooper Nuclear Station (CNS), for which the existing

license, DPR-46, expires January 18, 2014 (NPPD, 2008a).The NRC's Federal action is the

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

1.2 PURPOSE AND NEED FOR THE PROPOSED FEDERAL ACTION

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

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

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

may be determined by State, utility, and, where authorized, Federal decision makers (other than

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

NRC's recognition that, unless there are findings in the safety review required by the AEA or

findings in the National Environmental Policy Act (NEPA) environmental analysis that would

lead the NRC not to issue a renewal, the NRC does not have a role in the energy-planning

decisions of State regulators and utility officials as to whether or not a particular nuclear power

plant should continue to operate.

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

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

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

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

operating license, January 18, 2014.

1.3 MAJOR ENVIRONMENTAL REVIEW MILESTONES

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

(NPPD, 2008a) in September 2008. After reviewing the application and the ER for sufficiency,

the NRC staff published a Notice of Acceptability and Opportunity for Hearing on December 30,

July 2010 1-1 NUREG-1437, Supplement 41
Purpose and Need for Action

2008, in the Federal Register (73 FR 79921). On January 26, 2009, the NRC published another

notice in the Federal Register (NRC, 2009a) on its intent to conduct scoping, thereby beginning

the 60-day scoping period.

The agency held two public scoping meetings on February 25, 2009, in Brownville, NE, and

Auburn, NE. The NRC report entitled "Environmental Impact Statement Scoping Process

Summary Report for Cooper Nuclear Station," dated May 29, 2009, presents the comments

received during the scoping process in their entirety (NRC, 2009b). Appendix A to this SEIS

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

review and the associated NRC responses.

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

(;NS from March 30 through April 3, 2009. During the site audit, staff met with plant personnel,

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

local agencies. The agency published a summary of that site audit and a list of the attendees in

a report entitled, "Summary of Site Audit Related to the Review of the License Renewal

Application for Cooper Nuclear Station," dated April 30, 2009 (NRC, 2009c).

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

scoping period and site audit, the staff compiled its findings in the draft SEIS, which was made

available for public comment for 75 days. During this comment period, the NRC staff hosted

public meetings and collected public comments. Based on the information gathered, the staff

amended the draft SEIS findings, as necessary, and published this final SEIS.

NUREG-1437, Supplement 41 1-2 July 2010
Purpose and Need for Action

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

opportunities for public involvement.

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

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

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

review. The staff documents the findings of the safety review in a safety evaluation report

(SER). The Commission considers the findings in both the SEIS and the SER in its decision to

either grant or deny the issuance of a new license.

July 2010 1-3 NUREG-1437, Supplement 41
Purpose and Need for Action

1.4 GENERIC ENVIRONMENTAL IMPACT STATEMENT

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

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

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

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

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

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

those environmental issues that could be dispositioned generically in the GElS.

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

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

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

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

following criteria:

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

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

specified plant or site characteristics.

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

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

high-level waste and spent fuel disposal.

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

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

be sufficiently beneficial to warrant implementation.

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

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

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

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

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

the SEIS.

The GElS establishes 92 issues for the NRC staff Significance indicates the importance

to independently verify. Of these 92, the staff of likely environmental impacts and is

determined that 69 are Category 1, while 21 issues determined by considering two

do not lend themselves to generic consideration variables: context and intensity.

(Category 2). Two other issues remained Context is the geographic, biophysical,

uncategorized and must be evaluated on a and social context in which the effects

site-specific basis: environmental justice and the will occur.

chronic effects of electromagnetic fields. Refer to Intensity refers to the severity of the

Appendix B of this SEIS for a list of all 92 issues. impact, in, whatever context it occurs.

1 NUREG-1437, Generic Environmental Impact Statement (GELS) for License Renewal of Nuclear Power Plants,

Volume 1 and 2, May 1996, Washington, D.C.

NUREG-1437, Supplement 41 1-4 July 2010
Purpose and Need for Action

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

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

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

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

the results of the analysis apply to all plants, and (6) considers whether or not additional

mitigation measures are warranted for impacts that would have the same significance level for

all plants.

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

Environmental Quality (CEQ) terminology for "significant." The NRC established three levels of

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

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

destabilize nor noticeably alter any important attribute of the resource.

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

important attributes of the resource.

LARGE - Environmental effects are clearly noticeable and are sufficient to destabilize important

attributes of the resource.

nuclear power plant operation

Process

used Environmental Environmental to analyze

impacts same impacts differ and

at all sites across sites categorize ca nd

issues in

the GElS

Category 1 I~ssue Catelgory 2 Issue

No new and New and New issue

significant significant not analyzed

information information in the GElS

related to related to

issue issue Process

used

to analyze

Site-specific analysis issues for

each SEIS

Adopt conclusions

of the GElS Site-specific conclusion f

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

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

July 2010 1-5 NUREG-1437, Supplement 41
Purpose and Need for Action

1.5 SUPPLEMENTAL ENVIRONMENTAL IMPACT STATEMENT

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

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

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

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

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

impacts from alternatives, and Chapter 9 presents the recommendation to the Commission as to

whether or not the environmental impacts of license renewal are so great that preserving the

option of license renewal would be unreasonable. The recommendation will be made after

consideration of the SEIS.

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

" reviewed information provided in the NPPD ER

" consulted with other Federal, State, and local agencies

" conducted an independent review of the issues during site audit

" considered public comments received during the scoping process

New information can be identified from a

number of sources, including the applicant, ••New, and signifit-.inf..rma. ti "..either

the NRC, other agencies, or public )ide'n tife•)e s a, sign ifa enronmental issueI

comments. If a new issue is revealed, then it'ered in ..... or ,'-nt:',,cvbrd i Gý lS`-, 6 , (2) .was. not.

it is first analyzed to determine whether it is cosdee-i.heaalss.(,h -l n

within the scope of the license renewal eads to an ipt finding that isf tr

evaluation. If the issue is not addressed in

the GELS, then the NRC determines its th2,ning presented in theG,.-

significance and documents its analysis in

the SEIS.

1.6 COOPERATING AGENCIES

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

agencies in the preparation of this SEIS.

1.7 CONSULTATIONS

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

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

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

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

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

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

documents.

Advisory Council on Historic Preservation

Department of Health and Human Services

Iowa Tribe of Kansas and Nebraska

Iowa Tribe of Oklahoma

NUREG-1437, Supplement 41 1-6 July 2010
Purpose and Need for Action

Kickapoo Tribe in Kansas

Nebraska Game and Parks Commission

Nebraska Department of Natural Resources

Nebraska State Historic Society

Missouri State Historic Society

Omaha Tribe of Nebraska

Otoe-Missouria Tribe of Indians

Prairie Band of Potawatomi Indians

Sac and Fox Nation of Missouri

Sac and Fox Tribe of the Mississippi in Iowa

Sac and Fox Nation of Oklahoma

U.S. Army Corps of Engineers

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

1.8 CORRESPONDENCE:

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

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

of all documents sent and received during the environmental review.

Advisory Council on Historic Preservation

Department of Health and Human Services

Iowa Tribe of Kansas and Nebraska

Iowa Tribe of Oklahoma

Kickapoo Tribe in Kansas

Nebraska Game and Parks Commission

Nebraska Department of Health and Human Services

Nebraska Department of Natural Resources

Nebraska State Historic Preservation Office

Missouri State Historic Preservation Office

Omaha Tribe of Nebraska

Otoe-Missouria Tribe of Indians

Prairie Band of Potawatomi Indians

Sac and Fox Nation of Missouri

Sac and Fox Tribe of the Mississippi in Iowa

Sac and Fox Nation of Oklahoma

U.S. Army Corps of Engineers

July 2010 1-7 NUREG-1437, Supplement 41
Purpose and Need for Action

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

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

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

Mr. Ronald D. Asche Presdntand DChie EciMr. Gene Mace Mr. John C. McClure

Officer Nuclear Asset Manager Vice President and General Counsel Nebraska Public Power District Nebraska Public Power District Nebraska Public Power District P.O. Box 98 P.O. Box 499

1414 15th Street Box 98 Cox 499

Columbus, NE 68601 Brownville, NE 68321 Columbus, NE 68602-0499

Mr. David Van Der Kamp Mr. Michael J. Linder, Director Chairman

Licensing Manager Nebraska Department of Nemaha County Board of Environmental Commissioners

Nebraska Public Power District Quaity Nem ahasCon t o u

P.O. Box 98 Quality Nemaha County Courthouse

Brownville, NE 68321 P.O. Box 98922 1824 N Street

Lincoln, NE 68509-8922 Auburn, NE 68305

Ms. Julia Schmitt, Manager

Mr. Stewart B. Minahan Radiation Control Program Deputy Director for Policy

Vice President Nebraska Health & Human Services Missouri Department of Natural

Nuclear and Chief Nuclear Officer R&L Resources

Cooper Nuclear Station Public Health Assurance P.O. Box 176

72676- 648A Avenue 301 Centennial Mall, South Jefferson City, MO 65102-0176

Brownville, NE 68321 P.O. Box 95007

Lincoln, NE 68509-5007

Senior Resident Inspector Regional Administrator, Region IV Director, Missouri State Emergency

U.S. Nuclear Regulatory U.S. Nuclear Regulatory Management Agency

Commission Commission

P.O. Box 218 612 E. Lamar Blvd, Suite 400 PeO.eBox 116

Brownville, NE 68321 Arlington, TX 76011-4125

Chief, Radiation and Asbestos Ms. Melanie Rasmussen Mr. Keith G. Henke, Planner

Control Section Radiation Control Program Director Division of Community and Public

Kansas Department of Health Bureau of Radiological Health Health

and Environment Iowa Department of Public Health Office of Emergency Coordination

Bureau of Air and Radiation Lucas State Office Building, 5th Floor 930 Wildwood Drive

1000 SW Jackson, Suite 310 321 East 12th Street P.O. Box 570

Topeka, KS 66612-1366 Des Moines, IA 50319 Jefferson City, MO 65102

Mr. Art Zaremba, Director of Nuclear Mr. John F. McCann, Director Mr. Mike Boyce

Safety Assurance Licensing, Entergy Nuclear Cooper Strategic Initiatives Manager

Nebraska Public Power District Northeast Cooper Nuclear Station

P.O. Box 98 Entergy Nuclear Operations, Inc. 72676 - 648A Avenue

Box 98 440 Hamilton Avenue Brownville, NE 68321

White Plains, NY 10601-1813

Mr. Garry Young Mr. Alan Cox Mr. Dave Lach

License Renewal Manager License Renewal Technical Manager LRP Entergy Project Manager

Entergy Nuclear Entergy Nuclear Entergy Nuclear

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

Russellville, AR 72802 Russellville, AR 72802 Russellville, AR 72802

Mr. Jerry Perry Ms. Yolanda Peck Ms. Kendall Neiman

500 S. Main Street 1008 Central Avenue 830 Central Avenue

Rock Port, MO 64482 Auburn, NE 68305 Auburn, NE 68305

Ms. Annie Thomas Mr. John Chaney Mr. Darrell Kruse

1522 I Street 1101 17th Street 2415 McConnell Avenue

Auburn, NE 8305 Auburn, NE 68305 Auburn, NE 68305

Mr. Daryl J. Obermeyer Ms. Sherry Black, Director Board of Brownville, NE

I NUREG-1437, Supplement 41 1-8 July 2010
Purpose and Need for Action

ADC Auburn Memorial Library Attn: Chairman Marty Hayes

64381 727A Road 1810 Courthouse Avenue P.O. Box 67

Brownville, NE 68321 Auburn, NE 68305 223 Main Street

Brownville, NE 68321

Mr. John Cochnar

Mr. Bob Engles Ms. Jo Stevens U.S. Fish and Wildlife Service

Mayor of Auburn, NE Mayor of Rock Port, MO Ecological Services

1101 J Street 500 S. Main Street Nebraska Field Office

Auburn, NE 68305 Rock Port, MO 64482 203 West Second Street

Grand Island, NE 68801

Mr. John Askew Ms. Joann Scheafer, Director Mr. Doyle Childers, Director

Regional Administrator Nebraska Department of Health & Missouri Department of Natural

U.S. EPA Region 7 Human Services Resources

901 N. 5th Street 301 Centennial Mall South P.O. Box 176

Kansas City, KS 66101 Lincoln, NE 68509 Jefferson City, MO 65102

Mr. Mark Miles Mr. Michael J. Smith Mr. Robert Puschendorf

State Historic Preservation Officer State Historic Preservation Officer Nebraska State Historical Society

Department of Natural Resources Nebraska State Historical Society 1500 R Street

P.O. Box 176 P.O. Box 82554 P.O. Box 82554

Jefferson City, MO 65102 Lincoln, NE 68501 Lincoln, NE 68501-2554

Mr. Seth Greenburg

Environment, Planning, and Mr. Matthew Leaf Mr. Jim Thomas

Infrastructure KTNC/KLZA Radio Enercon

Research Assistant 1602 Stone St 5100 E. Skelton Street, 450

9300 Lee Highway Falls City, NE 68335 Tulsa, OK 74135

Fairfax, VA 22031

Ms. Carla Mason

ADC

820 Central Avenue

Auburn, NE 68305

1.9 STATUS OF COMPLIANCE

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

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

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

State, and local authorities for activities at CNS.

July 2010 1-9 NUREG-1437, Supplement 41
Purpose and Need for Action

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

Permit Number Dates Responsible Agency

Operating License DPR-46 Issued: 1/18/1974 Expires: 1/18/2014 NRC

National Pollutant Discharge NE0001244 Expires: 6/30/2012 Nebraska Department of

Elimination System (NPDES) Permit Environmental Quality (NDEQ)

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

Permit to Construct an Air Not Applicable NA NDEQ

Contaminant Source (NA)

Hazardous Waste Generator NED055071062 NA NDEQ

Identification

Class V Well Underground Injection NE0208256 Expires: 11/16/2010 NDEQ

Well Registration G-030088 NA Nebraska Department of Natural

Resources (NDNR)

Well Registration G-030089 NA NDNR

Well Registration G-040718 NA NDNR

Well Registration G-100339 NA NDNR

Well Registration G-100340 NA NDNR

Well Registration G-149001A NA NDNR

Well Registration G-149001B NA NDNR

Well Registration G-149001C NA NDNR

Well Registration G-1 49001D NA NDNR

Well Registration G-149001E NA NDNR

Well Registration G-149001F NA NDNR

Well Registration G-149001G NA NDNR

Well Registration G-149001H NA NDNR

Well Registration G-1490011 NA NDNR

Well Registration G-149001J NA NDNR

Well Registration G-149001K NA NDNR

Water withdrawal permit D-1071 NA NDNR

Class III Public Water Nebraska Health and Human

Supply System Permit Services (NHHS) System

Nebraska Water Pollution Control 401 Certification NA NAConi(NPC Council (NWPCC)

CNS Radioactive Waste T-NE002-L08 12/31/2008 Tennessee Department of

License for Delivery Environment and Conservation

(TDEC), Division of Radiological

Health

Generator Site Access Permit 0111000042 1/3/2009 Utah Department of Environmental

Quality (UDEQ), Division of

Radiological Health

Industrial Storm Water Permit NEROOOOOO 9/18/1997 NPDES

Section 404 Permit for dredging at

intake structure and discharge of

dredge material

Section 404 Permit of intake structure

ice deflectors

NUREG-1437, Supplement 41 1-10 July 2010
Purpose and Need for Action

1.10 REFERENCES

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

Protection Regulations for Domestic Licensing and Related Regulatory Functions."

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

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

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

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

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

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

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

Station, Appendix E - Applicant's Environmental Report, Operating License Renewal Stage,"

Columbus, NE, September 24, 2008, Agencywide Documents Access and Management System

(ADAMS) Accession Nos. ML083030246 (main report) and ML083030252 (attachments).

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

Application," ADAMS Accession No. ML083030227.

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

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

ADAMS Accession Nos. ML040690705 and ML040690738.

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

for License Renewal of Nuclear Plants, Main Report, "Section 6.3 - Transportation, Table 9.1,

Summary of Findings on NEPA Issues for License Renewal of Nuclear Power Plants, Final

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

ML040690720.

U.S. Nuclear Regulatory Commission (NRC). 2009a. "United States Nuclear Regulatory

Commission, Nebraska Public Power District, Cooper Nuclear Station, Notice of Intent to

Prepare an Environmental Impact Statement and Conduct Scoping Process," Federal Register,

Vol. 74, No. 15, pp. 4476-4477, January 26, 2009.

U.S. Nuclear Regulatory Commission (NRC). 2009b. "Environmental Impact Statement,

Scoping Process, Summary Report, Cooper Nuclear Station." Brownville, Nebraska, ADAMS

Accession No. ML091200017.

U.S. Nuclear Regulatory Commission (NRC). 2009c. "Summary of Site Audit Related to the

Review of the License Renewal Application for Cooper Nuclear Station (TAC Nos. MD9763 and

MD9737)," ADAMS Accession No. ML090970414.

July 2010 1-11 NUREG-1437, Supplement 41

2.0 AFFECTED ENVIRONMENT

Cooper Nuclear Station (CNS) is located in Nemaha County, Nebraska, 2.25 miles (mi) (3.6

kilometers (km)) southeast of Brownville, Nebraska, approximately 60 mi (96 km) southeast of

Lincoln, Nebraska and 65 mi south of Omaha, Nebraska. CNS is bounded on the east by the

Missouri River and on the north, south, and west by non-Nebraska Public Power District (NPPD)

owned property. Figure 2.1-1 shows a map of a 50-mi (80-km) radius around CNS. Figure 2.2-2

shows the area within a 6-mi (9.6 km) radius of CNS. The site is owned and operated by NPPD.

The site structures for CNS span approximately 55 acres (ac) (22 hectares (ha)) of the site's

total area of approximately 1,359 ac (550 ha), inclusive of the 239 ac (97 ha) on the opposite

bank (east) of the Missouri River in Atchison County, Missouri. Over 99 percent of the total

acreage in Nemaha County is used for agriculture and farming. A significant portion of NPPD

property at CNS, 234 ac (947 ha) in Missouri and 715 ac (289 ha) in Nebraska, is currently

leased for agricultural activities such as farming and raising livestock or conservation purposes.

2.1 FACILITY DESCRIPTION

The principal structures at CNS consist of the reactor building, turbine building (including service

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

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

multi-purpose facility, railroad airlock, drywell and suppression chamber, miscellaneous

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

chemistry gas generator building, and office building. Predominant features are the 290-foot (ft)

(88-meter (m)) tall reactor building, the 325-ft (99-m) tall elevated release point, and the

328.08-ft (100-m) tall meteorological tower.

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

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

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

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

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

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

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

permitted within the CNS exclusion area boundary.

2.1.1 Reactor and Containment Systems

CNS is a single-unit boiling-water reactor (BWR) plant with a nuclear steam supply system

supplied by General Electric Company and a turbine generator set supplied by Westinghouse

Electric Corporation. CNS achieved commercial operation in 1974 with an initial licensed core

thermal power of 2,381 megawatts-thermal (MWt). In 2008, with U.S. Nuclear Regulatory

Commission (NRC) approval, the applicant performed a measurement uncertainty recapture

uprate that increased the core thermal power by 1.62 percent to its current level of 2,419 MWt

and 830 megawatts-electric (MWe) (NPPD, 2008a). Figure 2.1-3 shows the general layout of

the buildings at CNS.

July 2010 2-1 NUREG-1437, Supplement 41
Affected Environment

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

(Source: NPPD, 2008a)

NUREG-1437, Supplement 41 2-2 July 2010
Affected Environment

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

(Source: NPPD, 2008a)

July 2010 2-3 NUREG-1437, Supplement 41
Affected Environment

Figure 2.1-3. Cooper Nuclear Station, General Site Layout (Source: NPPD, 2008a)

The reactor fuel is low-enriched high density ceramic uranium dioxide fuel pellets stacked within

a Zircaloy-2 cladding tube, which is evacuated, back-filled with helium, and sealed by welding

Zircaloy plugs in each end. NPPD currently operates CNS with an individual rod average burnup

of not more than 62,000 megawatt-days per metric ton uranium (MWd/MTU) (NPPD, 2008a).

The CNS containment system uses a multibarrier concept consisting of two systems, a primary

containment, which is a pressure suppression system, and a secondary containment, which

minimizes the release of radioactive materials.

The primary containment houses the reactor pressure vessel, the reactor coolant recirculation

system, and other branch connections of the reactor coolant system. Primary containment is a

NUREG-1437, Supplement 41 2-4 July 2010
Affected Environment

pressure suppression system consisting of a drywell, a suppression chamber which stores a

large volume of water, a connecting vent system between the drywell and suppression pool,

isolation valves, portions of the emergency core cooling system, and other service equipment.

The drywell is a steel pressure vessel in the shape of an inverted light bulb, and the suppression

chamber is a torus-shaped steel pressure vessel, often referred to as the torus, located below

and encircling the drywell.

Secondary containment encloses the primary containment system, refueling and reactor

servicing areas, new and spent fuel storage facilities, and other reactor auxiliary systems.

Secondary containment serves as the primary containment, when required, during reactor

refueling and maintenance operations, when primary containment is inoperable and as an

additional barrier when primary containment is operable (NPPD, 2008a).

2.1.2 Radioactive Waste Management

The radioactive waste system for CNS collects, treats, and disposes of radioactive and

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

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

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

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

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

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

Regulations (CFR) Part 20, "Standards for Protection against Radiation," 10 CFR Part 50,

"Domestic Licensing of Production and Utilization Facilities," the plant's technical specifications,

and the CNS offsite dose assessment manual (ODAM) (NPPD, 2008a).

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

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

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

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

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

are solids from the reactor coolant system, solids that come into contact with reactor coolant

system liquids or gases, or solids used in the reactor coolant system or steam and power

conversion system operation or maintenance (NPPD, 2008a).

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

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

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

fuel pool in the reactor building. In addition to the spent fuel pool, spent nuclear fuel is expected

to be stored in dry casks during the license renewal term.

The CNS ODAM contains the methodology and parameters used to calculate offsite doses

resulting from radioactive gaseous and liquid effluents, and the gaseous and liquid effluent

monitoring alarm and trip setpoints used to verify that the radioactive material being discharged

meets regulatory limits. The ODAM also contains the radioactive effluent controls and

radiological environmental monitoring activities and descriptions of the information that is

included in the annual radiological environmental operating report and annual radioactive

effluent release report (NPPD, 2008a).

July 2010 2-5 NUREG-1437, Supplement 41
Affected Environment

2.1.2.1 Radioactive Liquid Waste

I The CNS liquid waste disposal system collects, holds, treats, processes, and monitors all liquid

radioactive wastes for reuse or disposal. The function of the radioactive waste system is to

reclaim the liquid phase of the wet solid wastes for reuse within the station and to prepare the

solid waste for offsite shipment while minimizing radiation exposure to the workers. Prior to

offsite shipment to a licensed burial ground, solid wastes may be stored on site in shielded

areas. The solid waste processing systems are located in the radioactive waste building and

augmented radioactive waste building. Liquid radioactive waste is collected in sumps and

drainage tanks and transferred to the appropriate subsystem collection tanks for treatment,

disposal, or recycle. The waste processing selectively removes the radioactive material from the

liquid. The processing methods used include filtration and/or demineralization. The system can

also handle effluent streams that typically do not contain radioactive material, but may on

occasion, be radioactive. The applicant limits, to the extent possible, the amount of liquid

radioactive wastes discharged to the Missouri River. For example, there were no liquid

I radioactive discharges from CNS into the Missouri River in 2007. Liquid discharges are made

only after the radioactive material has been analyzed and the projected dose to members of the

public has been calculated to be within the values specified in the ODAM, 10 CFR Part 20, and

Appendix I to 10 CFR Part 50 (NPPD, 2008a).

The NRC staff reviewed the CNS radioactive effluent release reports for 2003 through 2009 for

liquid effluents (NPPD, 2004), (NPPD, 2005, (NPPD, 2006a), (NPPD, 2007a), (NPPD, 2008b),

(NPPD, 2009a), (NPPD, 2010) to determine if there was an adverse trend (i.e., a steady and

consistent annual increase in the amount of liquid effluents discharged) that might result in

levels that approach the radiation dose limits for members of the public. The effluent releases

are generally consistent from year to year, allowing for variations based on plant operation, the

number of refueling outages, and the scope of routine maintenance work performed. No

adverse trend was observed.

2.1.2.2 Radioactive Gaseous Waste

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

effluent to the atmosphere. The off-gas system (non-augmented) includes subsystems that

process and dispose of the gases from the main condenser air ejectors, the startup mechanical

vacuum pumps, and the gland steam condensers. The processed gases are routed to the

elevated release point for dilution and release to the atmosphere. Radiation monitors monitor

the gaseous discharges (NPPD, 2008a).

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

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

gaseous effluents before discharge to meet the dose limits in 10 CFR Part 20 and the dose

design objectives in Appendix I to 10 CFR Part 50.

The NRC staff reviewed the CNS radioactive effluent release reports for 2003 through 2009 for

gaseous effluents (NPPD, 2004), (NPPD, 2005), (NPPD, 2006a), (NPPD, 2007a), (NPPD,

2008b), (NPPD, 2009a), (NPPD, 2010) to determine if there was an adverse trend (i.e., a steady

and consistent annual increase in the amount of gaseous effluents discharged) that might result

in levels that approach the radiation dose limits for members of the public. The gaseous effluent

releases are generally consistent from year to year, allowing for variations based on plant

operation, the number of refueling outages, and the scope of routine maintenance work

performed. No adverse trend was observed.

NUREG-1437, Supplement 41 2-6 July 2010
Affected Environment

2.1.2.3 Radioactive Solid Waste

The CNS radioactive solid waste disposal system collects, stores, and processes wet and dry

solid waste for packaging and shipment offsite. The system consists of a wet process, which

collects, processes, dewaters, and solidifies wet solid wastes, and a dry process, which collects

and packages dry solid wastes. Wet solid wastes include spent resins, filter cartridges, and filter

crud. Dry solid wastes include contaminated rags, clothing, paper, outage equipment, and other

radioactively contaminated equipment. CNS uses a combination of onsite processing and an

offsite vendor to process radioactive wastes for disposal. Transportation of the radioactive solid

waste is conducted in accordance with NRC and U.S. Department of Transportation (DOT)

regulations as specified in 10 CFR Part 61, "Licensing Requirements for Land Disposal of

Radioactive Wastes," and 10 CFR Part 71, "Packaging and Transportation of Radioactive

Material" (NPPD, 2008a).

The State of South Carolina's licensed low-level radioactive waste (LLW) disposal facility,

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

that are not part of the Atlantic Low-Level Waste Compact. Nebraska is not a member of the

Atlantic Low-Level Waste Compact. This has had a minimal affect on CNS's ability to dispose of

its solid LLW. It uses the licensed LLW disposal site operated by Envirocare in Clive, Utah, for

its Class A waste. The applicant has onsite storage capacity to store its Class B and C

radioactive waste during the license renewal term.

In 2007, preparation work began for the construction of an independent spent fuel storage

installation (ISFSI) located on the north end of the CNS site in an area that was previously

disturbed. The ISFSI will provide storage space for spent fuel storage casks. The ISFSI, in

combination with the existing spent fuel pool, will store spent fuel assemblies generated during

the license renewal term. Operation of the ISFSI will be in accordance with NRC regulations to

ensure the spent fuel is stored safely and that worker and public radiation exposures are

controlled in accordance with the dose limits specified in 10 CFR Part 20, as well as the

Environmental Protection Agency's (EPA) radiation standards in 40 CFR Part 190,

"Environmental Radiation Protection Standards for Nuclear Power Operations" (NPPD, 2008a).

The NRC staff reviewed the CNS LLW reports for 2003 through 2009 (NPPD, 2004),

(NPPD, 2005), (NPPD, 2006a), (NPPD, 2007a), (NPPD, 2008b), (NPPD, 2009a), (NPPD,

2010). The solid waste volumes and radioactivity amounts generated in 2009 are typical of

previous annual waste shipments made by CNS. Variations in the amount of solid radioactive

waste generated and shipped from year to year are expected, based on the overall performance

of the plant and the number and scope of outages and maintenance activities. The volume and

activity of solid radioactive wastes reported by CNS are reasonable and no unusual trends were

noted.

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

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

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

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

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

license renewal term.

July 2010 2-7 NUREG-1437, Supplement 41
Affected Environment

2.1.3 Nonradiological Waste Management

CNS generates nonradioactive wastes as part of routine plant maintenance, cleaning activities,

and plant operations. The Resource Conservation and Recovery Act (RCRA) governs the

disposal of solid and hazardous waste. RCRA regulations are contained in Title 40, "Protection

of the Environment," Parts 239 through 299 (40 CFR 239, et seq.), of the CFR. Parts 239

through 259 of Title 40 contain regulations for solid (nonhazardous) waste, and Parts 260

through 279 contain regulations for hazardous waste. RCRA Subtitle C establishes a system for

controlling hazardous waste from "cradle to grave," and RCRA Subtitle D encourages States to

develop comprehensive plans to manage nonhazardous solid waste and mandates minimum

technological standards for municipal solid waste landfills. Nebraska State RCRA regulations

are administered by the Nebraska Department of Environmental Quality (NDEQ) and address

the identification, generation, minimization, transportation, and final treatment, storage, or

disposal of hazardous and nonhazardous waste.

2.1.3.1 Nonradioactive Waste Streams

CNS generates solid waste, defined by RCRA, as part of routine plant maintenance, cleaning

activities, and plant operations. Nebraska is a part of EPA Region 7 and its solid waste program.

In 1985, the EPA authorized NDEQ to administer portions of the RCRA program in the State of

Nebraska that are incorporated in Title 128 (Nebraska Hazardous Waste Regulations) of the

Nebraska Administrative Code (NAC). NAC Title 128 was updated in 2007 to keep current with

Federal RCRA regulations.

The EPA classifies certain nonradioactive wastes as hazardous based on characteristics

including ignitability, corrosivity, reactivity, or toxicity (identification and listing of hazardous

waste is available in 40 CFR Part 261). States authorized to administer the RCRA program may

require generators to manage additional wastes, in addition to those hazardous wastes listed by

EPA.

The EPA recognizes three main types of the hazardous waste generators (40 CFR Part 262)

based on the quantity of the hazardous waste produced: large quantity generators (LQGs), that

generate more than 2,200 pounds (Ibs) (1,000 kilograms (kg)) per month or more of hazardous

waste, more than 2.2 lbs (1 kg) per month of acutely hazardous waste, or more than 220 lbs

(100 kg) per month of acute spill residue or soil; small quantity generators (SQGs) that generate

more than 220 lbs (100 kg), but less than 2,200 lbs (1,000 kg) of hazardous waste per month;

and conditionally exempt small quantity generators (CESQGs) that generate 220 lbs (100 kg) or

less per month of hazardous waste, or 2.2 lbs (1 kg) or less per month of acutely hazardous

waste, or less than 220 lbs (100 kg) per month of acute spill residue or soil. The State of

Nebraska has incorporated the EPA's regulations regarding hazardous wastes and recognizes CNS as a CESQG of hazardous wastes under Title 128, Chapter 8 of the NDEQ Administrative

Code. CNS generates small amounts of hazardous wastes including spent and expired

chemicals, laboratory chemical wastes, and occasional project-specific wastes. As reported in

I the NPPD environmental report (ER), CNS produced no hazardous waste in 2003, 1,112 lbs

(504 kg) in 2004, 4,285 lbs (1,944 kg) in 2005, 5,317 lbs (2,412 kg) in 2006, and 308 lbs (140

I kg) in 2007 (NPPD, 2008a). The increase in quantity of the hazardous waste produced by CNS

in 2005-2006 was due to large volumes of paint used during outages, as was confirmed by the

I NRC staff during the site audit. Used oil, produced during operation of CNS, is sent offsite to the

EPA-approved hazardous waste disposal facility (NPPD, 2009c).

The EPA classifies several hazardous wastes as universal wastes; these include batteries,

pesticides, mercury-containing items, and fluorescent lamps. NDEQ has incorporated the EPA's

NUREG-1437, Supplement 41 2-8 July 2010
Affected Environment

regulations (40 CFR Part 273) regarding universal wastes in Chapter 25 of Title 128 of the NAC.

NDEQ defines used batteries, pesticides, mercury-containing items, spent non-Toxic

Characteristic Leaching Procedure (TCLP) fluorescent and high intensity discharge (HID)

lamps, cathode ray tubes (CRTs), and electronics as universal waste; such wastes make up the

majority of the hazardous wastes produced by CNS. The NPPD ER reports that in 2007, CNS

produced 20,860 lbs (9,462 kg) of electronic waste, 6,190 lbs (2,808 kg) of lamps, and 25,200

lbs (11,431 kg) of batteries (NPPD, 2008a).

CNS does not routinely chlorinate circulating water systems; however, the periodic use of

chlorine/bromine in the circulating water system and cooling water system is allowed in CNS

National Pollutant Discharge Elimination System (NPDES) Permit No. NE0001244

(NPPD, 2008a). Radioactive liquid waste is addressed in Section 2.1.2. Section 2.1.7.3 provides

more information on the CNS NPDES permit and permitted discharges.

The Emergency Planning and Community Right-to-Know Act (EPCRA) requires applicable

facilities to provide information on hazardous and toxic chemicals to local emergency planning

authorities and the EPA (Title 42, Section 11001, of the United States Code (42 USC 11001)).

On October 17, 2008, the EPA finalized several changes to the Emergency Planning (Section

302), Emergency Release Notification (Section 304), and Hazardous Chemical Reporting

(Sections 311 and 312) regulations that were proposed on June 8, 1998 (63 FR 31268). CNS is

subject to Federal EPCRA reporting requirements and thus, submits an annual Section 312

(Tier II) report on hazardous substances to local emergency agencies.

Low-level mixed wastes (LLMW) are wastes that contain both LLW and RCRA hazardous waste

(40 CFR 266.210). The EPA (or any authorized State agency) regulates the hazardous

component of the mixed waste through RCRA, and the NRC regulates radioactive waste subject

to the Atomic Energy Act (AEA). CNS, as a CESQG under RCRA Subtitle C, periodically

produces small amounts of LLMW, mainly from the use of liquid cleaners, and sends it offsite for

disposal to an approved disposal facility.

2.1.3.2 Pollution Prevention and Waste Minimization

NPPD established company-wide recycling programs at its major and minor facilities, with a

growing Green Team, that focuses on pollution prevention, waste minimization, and education

of personnel. CNS implements this program and participates in Green Team activities. NPPD

compiles an annual recycling report that summarizes recycling efforts at various locations

including CNS. As a result of the CNS recycling efforts, 51.2 tons (46 metric tonnes (MT)) of

office paper, 6,800 lbs (3.1 MT)of batteries, 8,500 lbs (3.9 MT) of electronic waste, and

2,675 lbs (1.2 MT) of fluorescent lamps were recycled in 2008 as stated in the "Nebraska Public

Power District 2008 Recycling Report" (NPPD, 2008a).

In support of nonradiological waste minimization efforts, the EPA's Office of Prevention and

Toxics has established a clearinghouse that provides information regarding waste management

and technical and operational approaches to pollution prevention (EPA, 2009c). The EPA's

clearinghouse can be used as a source for additional opportunities for waste minimization and

pollution prevention at CNS, as appropriate.

July 2010 2-9 NUREG-1437, Supplement 41
Affected Environment

The EPA also encourages the use of Environmental Management Systems (EMSs) for

organizations to assess and manage the environmental impact associated with their activities,

products, and services in an efficient and cost-effective manner. The EPA defines an EMS as "a

set of processes and practices that enable an organization to reduce its environmental impacts

and increase its operating efficiency." EMSs help organizations fully integrate a wide range of

environmental initiatives, establish environmental goals, and create a continuous monitoring

process to help meet those goals. The EPA Office of Solid Waste especially advocates the use

of EMSs at RCRA-regulated facilities to improve environmental performance, compliance, and

pollution prevention (EPA, 2009c).

2.1.4 Plant Operation and Maintenance

I Maintenance activities conducted at CNS include inspection, testing, and surveillance to

maintain the current licensing basis of the facility and to ensure compliance with environmental

I and safety requirements. Various programs and activities currently exist at CNS to maintain,

inspect, test, and monitor the performance of facility equipment. These maintenance activities

include inspection requirements for reactor vessel materials, boiler and pressure vessel

in-service inspection and testing, maintenance structures monitoring program, and maintenance

of water chemistry.

Additional programs include those implemented to meet technical specification surveillance

requirements, those implemented in response to the NRC generic communications, and various

periodic maintenance, testing, and inspection procedures. Certain program activities are

performed during the operation of the unit, while others are performed during scheduled

refueling outages. Nuclear power plants must periodically discontinue the production of

electricity for refueling, periodic in-service inspection, and scheduled maintenance. CNS refuels

on an 18-month interval.

2.1.5 Power Transmission System

The NPPD notes in their ER that four transmission lines, three of which are owned and operated

by NPPD, are considered in scope for license renewal. Three of these four lines are numbered

and connect CNS to the regional grid via 345-kilovolt (kV) transmission lines, and total

approximately 148 mi (238 km). Two of these numbered lines, NPPD TL3501 and NPPD

TL3502, form a transmission line corridor extending 146 mi (233 km) west-northwest from CNS

in Nemaha County and ending within 4 mi (6 km) east of Grand Island in Merrick County. Line

NPPD TL3501 originates at CNS and extends approximately 64 mi (103 km) west-northwest to

the Mark T. Moore substation, located 1.5 mi (2.4 km) north of Hallam, Nebraska. Line NPPD

TL3502 extends approximately 83 mi (134 km) west-northwest from the Moore substation and

ends east of Grand Island, crossing the Platte River within 1 mi of the Grand Island substation

(Figure 2.1.5-1). This transmission line right-of-way (ROW) originating from the CNS switchyard

spans Nemaha County, Johnson County, Gage County, Lancaster County, Saline County,

Fillmore County, York County, Hamilton County, and Merrick County, Nebraska. Line NPPD

TL3504 originates at CNS and extends 0.6 mi (1 km) east from the plant and midway to the

Missouri River, where it connects with a transmission line owned by Mid-America Energy that is

not considered in scope. A fourth unnumbered transmission line connects from the plant to the

switchyard and is also considered in the scope of license renewal (NPPD, 2008a).

NUREG-1437, Supplement 41 2-10 July 2010
Affected Environment

There are several additional transmission lines that connect with the CNS switchyard that are

neither owned nor operated by NPPD. These consist of two transmission lines connecting with

the CNS switchyard which are owned by Omaha Public Power District (OPPD). Another

transmission line connecting with one of the OPPD lines, not connected to the CNS switchyard

is owned by Kansas City Power and Light. However, whether a line is in scope for license

renewal depends on more than just whether they were constructed for connection to the grid,

(i.e., lines originally constructed for connection but no longer necessary are not in scope).

The transmission lines do not cross any Federal, State, or local parks. However, the western

half of the only one in scope transmission line corridor traverses counties that are part of the

U.S. Fish and Wildlife Service's (USFWS) Rainwater Basin Wetland Management District

(RBWMD). The RBWMB contains 61 tracts of wetlands comprising over 21,000 ac scattered

over 14 counties in southeastern Nebraska, and are managed to provide resting stops for

millions of migratory birds (USFWS, 2009a).

Farming occurs virtually unimpeded under the majority of the transmission lines, and only the

footprints of the poles are not used for crops (NPPD, 2008a). On the CNS property, the

agricultural land is managed by two farmers under an agreement with NPPD. According to the

staff of NPPD, approximately 70 percent of the transmission line corridor beyond the CNS site

traverses cropland, and NPPD has easements with the individual property owners to perform

maintenance activities along the corridor. Where the remaining 30 percent of the transmission

line corridor crosses forested areas, including wetlands and streams, NPPD has vegetative

maintenance procedures in place to prevent vegetation from interfering with the lines (NPPD,

2006b).

NPPD uses an integrated management approach to maintain vegetation along the transmission

line ROW that includes both mechanical and chemical control methods. Mechanical control

methods in the non-cultivated areas include clearing only woody plants with growth habits that

may interfere with the transmission lines or the removal of tall trees that may fall onto the

transmission line tower poles. Chemical treatment is used to control brush and re-growth of

stumps following mechanical cutting (NPPD, 2006b). Native grasses and low growing woody

plants are allowed to grow below the power lines within the forested ROWs (NPPD, 2008a). All

tree trimming performed by NPPD follows American National Standards Institute (ANSI)

guidelines for maintaining safe clearance and operation of the electrical systems. Chemical

control methods adhere to the State of Nebraska, Department of Agriculture guidelines for

application of restricted-use herbicides. All personnel involved with herbicide applications are

trained and certified on the application of restricted-use herbicides by the State of Nebraska or a

reciprocating State. For mechanical vegetation management in wetlands or along the shoreline

of the Missouri River, NPPD contacts the U.S. Army Corps of Engineers (USACE) to determine

if there is a need to obtain a Section 404 permit (NPPD, 2006b). NPPD staff has indicated that

no chemical treatment of vegetation is performed in wetlands. Chapter 3 of the NPPD Corporate

Environmental Manual (NPPD, 2007b) includes provisions for NPPD personnel and

vendors/contractors to follow for any land disturbance activities, including work performed in

wetlands or along riverbanks.

ROW aerial inspections occur six times annually, and there is an annual foot patrol inspection;

additional patrols are conducted following severe storms. Maintenance activities are performed

in compliance with the Endangered Species Act (ESA), the Bald and Golden Eagle Protection

Act, and the Migratory Bird Treaty Act. Birds that are nesting are protected except for nests of

pigeons, house sparrows, and starlings (NPPD, 2006b).

July 2010 2-11 NUREG-1437, Supplement 41
Affected Environment

Figure 2.1.5-1. Cooper Nuclear Station Transmission Line Corridor

(Modified from NPPD, 2008a)

2.1.6 Cooling and Auxiliary Water Systems

I CNS lies on the western shore of the Missouri River, withdraws river water for its once-through

cooling system, and discharges heated water back to the river. Unless otherwise cited, the NRC

I staff drew information about CNS's cooling and auxiliary water systems from NPPD (2006c) and

the applicant's ER. In the vicinity of the plant, the Missouri River has a regulated minimum flow

I of 3,000 cubic feet per second (cfs) (878 cubic meters per second (m3/s)) to the southeast. The

circulating water intake structure is located on the western shore of the river behind a guide wall

and submerged weir meant to reduce the amount of suspended sediment in the cooling water.

The weir attaches to shoreline structures north of the intake and then runs parallel to the face of

the intake at a distance of 14.25 ft (4.3 m). The wall continues past the intake and ends 40 ft (12

m) downstream of the downstream corner of the intake structure. In a line riverward of the weir

wall and extending downstream of it, 23 sheet pile vanes (10 ft wide by 6 ft high (3 m wide by 2

m high)), oriented at a 22 degree angle to the weir, redirect sand and gravel outward from the

weir and the intake structure. After flowing generally south along the weir and vanes, river water

must reverse course and turn northwest to move between the weir and shore and reach the

intake bays. Water velocity between the weir wall and the cooling water intake structure is about

4 feet per second (ft/s) (1.2 meters per second (m/s)).

In winter, about 25 to 30 percent of main condenser discharge water recirculates through an ice

control tunnel at the front of the intake structure and discharges in front of the trash rack to

NUREG-1437, Supplement 41 2-12 July 2010
Affected Environment

prevent icing. Water flows beneath a curtain wall at about 1.1 ft/s (0.3 m/s). Water enters the

five intake bays, four of which provide circulating water and are 22 ft (6.7 m) wide and one of

which provides service water and is 22.5 ft (6.8 m) wide. The incoming water then flows through

trash racks, 3/8 inch (1 centimeter (cm)) vertical bars separated 3 inches (7.6 cm) on center, at

up to 0.7 ft/s (20 centimeters per second (cm/s)).

The circulating water intake bays each separate into two screen bays and the service water

intake bay narrows before water encounters the traveling screens, which are oriented at right

angles to the flow. Water filters twice through nine 1/8 by 1⁄2-inch (.3 cm by 1.3 cm) smooth-top

mesh modified dual-flow traveling screens (eight for circulating water and one for service water).

The upward pass is in the front and the downward pass is behind the screens that rotate

continuously at 8.2 feet per minute (ft/min) (2.5 meters per minute (m/min). The intake water

velocity at the screens is about 2 ft/s (0.6 m/s).

After the 4.2-ft (1.28-m) wide traveling screen panels rotate over the upper cog and begin

moving down, a high pressure (30-60 pounds per square inch gage (psig), 200-400 kilopascal

(kPa)) screen wash of 3,000 gallons per minute (gpm) (0.19 m3/s) supplied by the service water

pumps removes fish and debris, which return together to the river through an 18-inch (0.46-m)

diameter steel pipe that discharges downstream from the intake. Although the screens are fitted

with fish baskets, the system has neither a low-pressure spray system to more gently remove

fish from the screens nor a fish return trough to convey fish and other aquatic organisms back to

the river separately from potentially damaging debris. Debris loads are about 10 cubic yards per

month (yd 3/month) (8 cubic meters per month (m3/month)).

CNS plans to install "dual-flow conversion screen fish handling systems" during its current

operational term. This system will have low pressure (5-10 psig, 35-70 kPa) fish washing

sprays on both the ascending and descending screens and a fish return trough that is separate

from the debris trough. A recovery basket will collect fish and other aquatic organisms washed

from the screens, and the fish trough will return them to the river. Figures 2.1.6-1, 2.1.6-2, and

2.1.6-3 show the CNS intake structures.

July 2010 2-13 NUREG-1437, Supplement 41
Affected Environment

SERVICE WATER

PUMPS rCIRCULATING

= Z AER PUMPS

SCREENS

B AR RACKS

L22'-" 91Y 22'

Figure 2.1.6-1. Cooper Nuclear Station, Intake Structure Plan (Source: NPPD, 2008a)

NUREG-1437, Supplement 41 2-14 July 2010
Affected Environment

CIRCULATING

WATER PUMP

ICE CONTROL TUNNEL

SLUICE GATES

-- EL E529 - 6

~1 2S

Figure 2.1.6-2. Cooper Nuclear Station, Intake Structure Section (Source: NPPD, 2008a)

July 2010 2-15 NUREG-1437, Supplement 41
Affected Environment

HIGH PRESSURE

SPRAY WASH

DEBRIS RETURN TROUGH

FISH

I-01 FLOW FLOW

z

II

II

II

II

I Figure 2.1.6-3. Cooper Nuclear Station, Typical Dual Flow Screen (Source: NPPD, 2008a)

NUREG-1437, Supplement 41 2-16 July 2010
Affected Environment

After water passes through the traveling screens, the two screen bays of each intake bay rejoin

behind the screens. The four circulating water pumps, one per bay, draw water from the bays

and provide up to 159,000 gpm (10 m3

/s) each. The four service water pumps in the fifth bay

provide a combined flow of 32,000 gpm (2 m3/s). Water from the circulating water pumps travels

to and circulates through the condenser, where it cools steam from the turbines. Because of the

scouring from the suspended sediment, CNS typically does not need to chlorinate the circulating

water to control biological film fouling, although it has the capacity to chlorinate or brominate if

needed. NPPD is studying the effectiveness of these options.

Water temperature increases about 17.8°F (10°C) as it passes through the condenser tubes.

From the condenser, circulating cooling water flows through concrete tunnels to a seal well

structure and then to the discharge canal, where it travels about 1,000 ft (300 m) to discharge to

the river at a slight angle. Water velocity at the discharge is about 1 ft/s (0.3 m/s) at average

river flow and about 5.6 ft/s (1.7 m/s) during low flow. The travel time from the intake structure to

the discharge is about 20 minutes at high river flow and 10 to 12 minutes at low flow.

Cooling water flow varies with plant power and ambient river water temperature. At full load

during the summer, the expected circulating water system flow is highest: about 636,000 gpm

(40 m3

/s). Circulating water flow is lower under other conditions. In comparison, the lowest river

flow at CNS is about 3,000 cfs (85 m3

/s). Under the worst conditions, the circulating water

system flow would be about 47 percent of Missouri River flow and about 4 percent or less under

average annual flow conditions. Stone riprap at the discharge structure prevents the discharge

from eroding the river bottom.

2.1.7 Facility Water Use and Quality

CNS has a once-through circulating water system withdrawing cooling water from and

discharging to the Missouri River. Each of the four facility circulating water pumps can draw a

maximum of 159,000 gpm. The four service water pumps provide a combined flow of

32,000 gpm. In addition, CNS uses two wells to supply potable ground water to the facility, two

wells to supply water to pump seals and one well for fire protection training (NPPD, 2008a).

2.1.7.1 Ground Water Use and Quality

The CNS property overlies the Missouri River Stream Valley Aquifer (described in Section 2.2.3)

which consists of interbedded alluvial sand, silt, clay, and gravel ranging in thickness between

62 and 71 ft (18.9 and 21.6 m) (NDNR, 2008). Saturated thickness of the aquifer averages

approximately 50 ft (15.2 m). In the area of CNS, the alluvial aquifer is in hydraulic contact with

the Missouri River with seasonal discharge to the river during lower river stage and recharge

from the river during high stage (NPPD, 2008a). Ground water usually flows from west to east

toward the river, but will flow east to west when river levels are high in the spring.

The two potable water supply wells completed in the alluvial aquifer are registered with the

Nebraska Department of Natural Resources (NDNR) and have a current combined pumping

capacity of 250 gpm (0.016 m3

/s) (NDNR, 2008). Normal operations require pumping only one

well at a time to supply 125 gpm (0.008 m3/s). The wells together operate as a Nebraska Public

Water Supply System under Permit No. NE3150505 from the Nebraska Department of Health

and Human Services (NHHSS, 2000). The water is chlorinated, distributed onsite, and operated

with preventive maintenance and cross connection/backflow prevention programs. NPPD plans

to replace the two drinking water wells with two similar new wells in the near future.

July 2010 2-17 NUREG-1437, Supplement 41
Affected Environment

A third alluvial aquifer well registered with the NDNR used for fire protection training has a

capacity of 750 gpm (0.047 m3

/s). Two additional wells, River Wells A and B, have a capacity of

150 gpm (0.01 m3/s) each and are used to supply water for pump seals.

NPPD CNS also has authorization number NE0208256 from the NDEQ to conduct underground

injection of stormwater runoff within the protected area using stormwater drainage wells (dry

wells) (NDEQ, 2000). These wells look like storm drains but contain gravel at the bottom that

allows the collected stormwater to seep into the fill material above the water table. This water

eventually reaches the water table and disperses before likely discharging to the Missouri

River.

Ground water monitoring at CNS is conducted by sampling 14 monitoring wells, 11 of which

were installed to measure the concentration of tritium in ground water. Three of the wells are

piezometers installed as part of the ISFSI Project. NPPD has documented seven instances of

liquid radiological releases since the licensing of CNS in 1974, but none of the releases is a

current source of ground water contamination (CRA, 2007). In 2008, the Cooper Nuclear Station

(CNS) of the Nebraska Public Power District (NPPD) Nebraska Public Power District instituted a

comprehensive program to evaluate the impact of station operations on groundwater in the

vicinity of CNS. During that time period, 308 analyses were performed on 44 samples from 11

locations. In assessing all the data gathered for this report, it was concluded that the operation

of CNS had no adverse radiological impact on the environment, and there are no known active

releases into the groundwater or surface water at Nebraska Public Power District. Tritium was

not detected in any of the groundwater samples at concentrations greater than the United

States Environmental Protection Agency (USEPA) drinking water standard (and the Nuclear

Regulatory Commission Reporting Limit) of 20,000 pCi/L. The tritium concentrations ranged

from 238 ± 121 pCi/L to 1170 + 181 pCi/L. Strontium-89 and strontium-90 were not detected at

concentrations greater than the Lower Limit of Detection in any of the groundwater samples.

Iron-55 was not detected in any of the groundwater samples. Nickel-63 was not detected in any

of the groundwater samples.

2.1.7.2 Surface Water Use and Quality

CNS employs a once-through cooling system using water from the Missouri River. Wing dams

on the Missouri side of the river are designed to force flow into the central channel of the river.

Flow in the river is channelized and carries a heavy sediment load. Sedimentation at the CNS

intake is minimized by turning vanes and a sheet-pile wall set in the river that direct sediment

away from the intake structure.

Surface water quality data in the CNS vicinity are provided by USACE low flow studies in

support of the Missouri River Master Water Control Manual. Results show relatively small

ranges of values of temperature, pH, and dissolved oxygen, but wider variations of suspended

solids (USACE, 2007). None of the samples from downstream of CNS showed effects from

operating the CNS once-through cooling system. However, the NDEQ, under the authority of

the Clean Water Act, has designated the Missouri River in the reach from the Platte River to the

Kansas border as impaired for primary contact recreation and fish consumption due to the

presence of fecal coliform and polychlorinated biphenyls (PCBs). Beneficial uses of surface

water identified in the CNS area are recreational, aquatic life (Warmwater A), public drinking

water supply, agricultural water supply, industrial water supply, and aesthetics (NDEQ, 2004).

NUREG-1437, Supplement 41 2-18 July 2010
Affected Environment

2.1.7.3 National Pollutant Discharge Elimination System

The Nebraska Department of Health, Water Pollution Control Council originally authorized CNS

to use water from and discharge to the Missouri River. Discharge is regulated by Nebraska

NPDES Permit No. NE0001244 which identifies effluent limitations, monitoring requirements,

and other conditions to comply with NDEQ Title 117 and Title 119, Chapter 27 (NPDES permits

rules and regulations) and 40 CFR Part 423 (NPPD, 2008a). The effluent limitations for each

outfall are shown in Table 2.1.7-1.

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

System Permit for Cooper Nuclear Station

Total Oil and Grease Total Temperature-°F

Suspended Residual

Solids Chlorine

Outfall Avg. Max. Avg. Max. Avg. Max. Max. current

No. Month Daily Month Daily Month Daily

001 NLR NLR NLR NLR 0.01 0.02 109.4

002b 30 100 NLR 10 NLR NLR NLR

002c 30 100 NLR 10 NLR NLR NLR

004 30 100 NLR 10 NLR NLR NLR

008 30 100 NLR 10 NLR NLR NLR

009 30 100 NLR 10 NLR NLR NLR

NLR = No Limit Required, NPPD NPDES Permit No. NE0001244

Outfall 001, the main discharge canal outfall for the circulating water system, is located

approximately 1,000 ft (305 m) downstream of the CNS intake structure and empties to the

Missouri River. The once-through service water and equipment non-contact cooling water

discharges through Outfall 001, which empties into the discharge canal. Outfall 004 discharges

overflow from the reverse osmosis treatment system and boiler blowdown and also empties into

the circulating water discharge canal.

Outfalls 002b is the discharge of industrial well ground water bypass, RO reject, and boiler

blowdown. Outfall 002c is the discharge of diesel generator, turbine fan heater, boiler room floor

drains, and HVAC blowdown. These outfalls discharge to the Missouri River

The only NPDES non-compliance reported in the last 5 years was for total suspended solids

(TSS) at Outfall 004 on August 31, 2008. The TSS averaged 37.4 milligrams per liter (mg/L),

which exceeds the monthly daily permit limit of 30 mg/L. The cause of this small excess was

found to be the presence of fish in the reverse osmosis treatment settling pond. The fish,

introduced to the pond by flooding in 2008, stirred up bottom sediment and caused the sample

to contain higher than average TSS. The treatment system did not cause the excess.

July 2010 2-19 NUREG-1437, Supplement 41
Affected Environment

In addition to the NDEQ industrial wastewater NPDES permit, CNS has an industrial stormwater

discharge Permit No. NER000059 for stormwater discharge outside the power block area..

Inside the power block area, stormwater discharge is directed to stormwater drainage wells

permitted as Class V underground injection wells by the NDEQ under Permit No. NE0208256.

The stormwater enters the storm drains and disperses in the vadose zone (i.e., the portion of

the earth between the top of the ground surface and the water table) above the local water table

before it likely discharges to the Missouri River.

2.1.7.4 Dredging

CNS has a USACE dredging permit NE 01-10322 to conduct maintenance dredging of the CNS

intake structure. A typical dredging event removes approximately 350 cubic yards (yd 3)

(267.6 cubic meters (M3)) of sediment outside the main channel and discharges the dredged

material downstream in the Missouri River (USACE, 2002).

2.2 SURROUNDING ENVIRONMENT

The vicinity of CNS is sparsely populated with zero population within a 1⁄2-mile radius of the

plant. Brownville, Nebraska, the nearest developed community, had a 2005 population of

approximately 137. The largest town within 6 mi (9.6 km), Nemaha, Nebraska, located 2.5 mi

(4 km) southwest, had a 2005 population of approximately 177. The largest town with industry

I within 10 mi (16 km) is Auburn, Nebraska, located to the west, with a 2005 population of

approximately 3,076. Nebraska City, located approximately 24 mi (39 km) northwest of the site,

I is the closest major town with a 2005 population of 7,035. Maryville, Missouri, located

approximately 40 mi (64 km) east of the plant, is the largest community within 50 mi (80 km)

with a 2005 population of approximately 10,567 (NPPD, 2008a).

I CNS is located on the Missouri River at river mile (RM) marker 532.5. In the vicinity of CNS, on

average the Missouri River is approximately 800 ft (244 m) wide and 28 ft (8 m) deep. Under the

I present flow regulation, a minimum Nebraska City flow of 31,000 cfs (878 m3/s) is maintained

for navigational purposes beginning in March and extending through November. During the

I winter months, a minimum flow of 3,000 cfs (85 m3/s) is required for sanitary purposes. The flow

is highly channelized with swift flows and heavy sediment transport.

The site is located on a constructional plain bordering the west bank of the Missouri River

situated on the first bottomland of the broad, nearly level, flood plain. The USACE has stabilized

the channel by use of pile dikes and bank protection. Earthen levees running parallel with the

Missouri River, and flood protection levees were constructed in the area to prevent meandering

of the river within the alluvial flood plain. The eastern bank of the Missouri River is chiefly a

densely forested land similar to the un-farmable bluffs that run parallel to the Missouri River. To

the west, there are bluffs that peak at 1,100 ft (335 m), but average 1,000 ft (305 m) along the

stretch of river from Brownville to Nemaha. Beyond the bluffs, the land is a gently rolling flood

plain.

There are several Native American lands within a 50-mi (80-km) radius of CNS, including the

Sac and Fox Reservation, Iowa Reservation, and Kickapoo Reservation. There are also several

local and county parks, golf courses, forest lands, wildlife areas, and other public recreation

lands within a 50-mi (80-km) radius of CNS (NPPD, 2008a).

NUREG-1437, Supplement 41 2-20 July 2010
Affected Environment

2.2.1 Land Use

CNS is located on approximately 1,359 ac (550 ha) of land owned and operated by NPPD,

including 239 ac (97 ha) on the opposite bank (east) of the Missouri River in Atchison County,

Missouri, see Figure 2.2.1-1. Of the 1,359 ac (550 ha), 949 ac (384 ha) are currently leased for

agricultural activities such as farming and livestock: 234 ac (95 ha) in Missouri and 715 ac

(289 ha) in Nebraska. The 234 ac (95 ha) on the Missouri side of the river intermittently flood

and are mostly wooded wetlands, with 40 of these acres (16 ha) cleared for agricultural

activities. The developed portion of the plant site, consisting of the power plant structure and

associated buildings, maintenance facilities, parking lots, and roads, occupies approximately

55 ac (22 ha) of the site (NPPD. 2008a).

Figure 2.2.1-1. Cooper Nuclear Station Facility Location (Source: NPPD, 2008a)

July 2010 2-21 NUREG-1437, Supplement 41
Affected Environment

The immediate area around the station is completely enclosed by a security fence, with access

to the station controlled at a security gate. The exclusion area, as defined by 10 CFR 100.3,

surrounds the plant site as shown in Figure 2.2.1-2. The plant site can be accessed by road on

the west side or from the Missouri River on the east. Road access to the plant site is from

Nemaha County 648A Avenue. A railroad spur connected to the site during construction was

abandoned by the Burlington Northern Railroad. The Steamboat Trace Recreational Trail runs

north and south through NPPD property west of the station along the abandoned railroad

right-of-way (ROW). The nearest residences lie 0.9 mi beyond the site boundary to the

northwest (NPPD, 2008a).

Figure 2.2.1-2. Cooper Nuclear Station, Site Boundary Map (Source: NPPD, 2008a)

NUREG-1437, Supplement 41 2-22 July 2010
Affected Environment

2.2.2 Climate and Meteorology

Nebraska is located in the middle portion of the Great Plains. The Great Plains occupy a large

region extending from southern Canadian provinces and parts of States such as Montana, North

Dakota, and Minnesota and southward to Texas, New Mexico, and Louisiana (Wishart, 2004).

Nemaha County, where CNS is located, is a part of the Dissected Till Plains that occupy much

of Iowa, eastern Nebraska, northwestern Missouri, and small areas of northwestern Illinois,

southern Minnesota, and northeastern Kansas. Moderately dissected, glaciated, flat-to-rolling

terrain that slopes gently toward the Missouri and Mississippi River valleys characterizes this

area.

Nebraska has a highly variable continental climate, with a large range of both diurnal and

annual temperatures and considerable diversity. There are significant precipitation and

temperature variations from east to west of Nebraska. The climate of eastern Nebraska is

classified as Dfa by the Koppen Climate Classification System: a humid continental climate with

hot summers and year round precipitation.

The State of Nebraska belongs to the High Plains National Oceanic and Atmospheric

Administration (NOAA) Regional Climate Center, which is a Federal-State cooperative effort.

The two closest NOAA National Weather Service (NWS) stations, which provide the most

current meteorological data for the area, are in Lincoln and Omaha, Nebraska, and are located

61 mi (98 km) northwest and 62 mi (100 km) north from CNS, respectively.

Strong northwestern winds during winter bring cold Arctic air masses from Canada. Occasional

low-pressure systems moving from southwestern States cause high winter winds and severe

blizzards. The average annual wind speed for the NWS station located in Lincoln, NEBRASKA,

is 10.1 miles per hour (mph) (8.8 knots) and 10.5 mph (9.1 knots) for the Omaha NWS station

(NCDC, 2009a). In the summer, winds are predominantly from the south. Annual normals for the

1971-2000 30-year period, provided by the University of Lincoln, indicate that the annual mean

temperature was 51.1°F (10.6°C), with a minimum annual temperature of 39.30F (40C), and a

maximum annual temperature of 62.8 0F (17.1°C) (UNL, 2009).

The occurrence of severe weather events in Nebraska is high. During 1950-2009, Nemaha

County reported 274 storm events, mostly consisting of tornadoes and high winds with

thunderstorms and hail. According to the National Climatic Data Center (NCDC), 17 tornadoes

were reported in Nemaha County from January 1950 to February 2009: five at FO, seven at F1,

four at F2, and one at F3 strengths (NCDC, 2009b). Occurrence of floods in Nemaha County is

less than one per year. Usually they do not cause any significant damage; however, the Auburn

flood of 1996 caused $680,000 in property damage and $2.1 million in crop damage.

Nebraska has wide ranges of precipitation from year to year with a steady decrease of rainfall

from east to west. East and southeast areas of Nebraska receive significantly more precipitation

than other areas of the State, where drought is not uncommon. According to the 1971-2000

annual normals for Lincoln, Nebraska, annual precipitation was 28.37 inches (72 cm) (UNL,

2009).

Sections 101 (b)(1), 110, 169(a)(2), and 301 (a) of the Clean Air Act as amended (42 U.S.C.

7410, 7491 (a)(2), 7601(a) established Mandatory Class I Federal reas where visibility is an

important value. There are no Mandatory Class I Federal areas in the State of Nebraska. The

closest Mandatory Class I Federal area is Hercules-Glades Wilderness Area, which is located

July 2010 2-23 NUREG-1437, Supplement 41
Affected Environment

295 mi southeast of CNS in the State of Missouri. Due to the significant distance from the site,

no adverse impacts on Class I Federal areas are anticipated from CNS operation.

2.2.2.1 Air Quality Impacts.

CNS is located in Nemaha County, Nebraska, in EPA Region 7. There are no counties

designated by the EPA as nonattainment or maintenance for any of the criteria pollutants in the

50-mi (81 km) vicinity of CNS. Douglas County, Nebraska, located approximately 72 mi

(116 km) from CNS, is the closest maintenance county for lead.

The Nebraska Division of Air Quality of the NDEQ has primary responsibility for regulating air

emission sources within the State of Nebraska. The NDEQ, with assistance from

Lincoln-Lancaster County Health Department and Douglas County Health Department,

conducts ambient air monitoring in Nebraska, operating 28 sites-throughout the State with 34

monitors. The EPA and National Atmospheric Deposition Program also monitor air quality in

Nebraska, which participates in the EPA's AIRNow Network that allows for continuous

monitoring of the criteria pollutants and informs the public of current environmental conditions.

NDEQ compiles an annual air quality report (NDEQ, 2008). In compliance with 40 CFR 58.10,

NDEQ submitted a Network Plan for EPA review and approval that reflects changes to the

ambient air monitoring program in Nebraska (NDEQ, 2009).

CNS has a number of stationary emission sources, such as three standby emergency power

supply diesel generators, auxiliaries required for safe starting and continuous operation, and

which are tested periodically to ensure their reliability to perform their intended function, and

several petroleum fuel storage tanks. Since CNS's actual annual emissions are less than the

criteria defined in Title V of the Clean Air Act and in Chapter 5, Title 129 of Nebraska

Administrative Code for criteria pollutants and hazardous air pollutants (HAPs),_CNS has been

granted a low emitter status by the NDEQ Air Quality Section. As reported and submitted to

NDEQ, actual total annual emissions at CNS from 2004 to 2008 were 11.52 tons (10.45 MT),

10.73 tons (9.73 MT), 13.21 tons (10.73 MT), 11.43 tons (10.37 MT), and 9.85 tons (8.94 MT),

respectively. From 2004 to 2008, maximum reported annual emmissions were reported in 2006:

0.16 tons (0.15 MT) of PM10 , 2.41 tons (2.19 MT) of CO, 0.22 tons (0.20 MT) of VOC, 9 tons

(8.16 MT) of NO), 1.41 tons (1.28 MT) of SO,, and 0.01 tons (0.009 MT) of single HAP

(NPPD, 2009c). Used oil is collected for offsite disposal;_therefore, no used oil incineration

activities occur on the CNS site. Used oil disposal is discussed further in the waste

management section. (Section 2.1.3.1)

CNS operates a meteorological system that consists of two monitoring sites at the ground

elevation of approximately 889 ft (271 m) above mean sea level (AMSL). These first monitoring

sites consist of a 328-ft (100-m) primary meteorological tower and a 32.8-ft (10-m) backup

tower. The former is located approximately 1,230 ft (375 m) and the latter is located

approximately 1,597 ft (487 m) from the northwest corner of the reactor building, respectively.

A new monitoring site, a 328-ft (100-m) meteorological tower, tower is being planned for 2010,

The design details are incomplete, but the new tower will meet or exceed the performance

standards of the existing tower and will be fully compliant with NRC .There are two independent

but identical dual sensors, system A and system B, mounted onto the 328-ft (100-m) primary

meteorological tower measuring temperature, wind speed, and direction at 32.8 ft (10 m), 197 ft

(60 m), and 328 ft (100 m). Vertical temperature differential is measured with temperature

sensors between all three levels. A relative humidity sensor is positioned at the 32.8 ft (10 m)

level. Precipitation is measured at ground level (NPPD, 2008a).

NUREG-1437, Supplement 41 2-24 July 2010
Affected Environment

The meteorological data (15-minute and hourly average) is run through meteorological data

validation software that checks and flags data discrepancies and inputs it to the CNS plant

computer. In the case of a complete system failure, the NWS office, located in Valley, Nebraska

provides backup meteorological data by telephone or National Warning System (NPPD, 2008a).

2.2.3 Ground Water Resources

As described by the United States Geological Survey (USGS, 1997), the Western Interior Plains

Bedrock Aquifer System is beneath the CNS site but contains no fresh water. The only

freshwater aquifer system beneath the site consists of unconsolidated alluvial deposits of the

Missouri River Stream Valley Aquifer and glacial deposits of the Glacial Drift Aquifer. These

deposits are reworked and difficult to distinguish within the main river valley. All of the onsite

wells are completed in these deposits and the aquifer is under unconfined (water-table)

conditions (NPPD, 2008a).

As part of a hydrogeologic investigation undertaken by CNS for the study of radioisotopes in

ground water, Conestoga Rover Associates (CRA) reviewed water use in the area surrounding

the station and searched the NDNR water-well database for all wells in Nemaha County. Three

irrigation wells, completed in the shallow unconsolidated aquifer, are located between 2 and

3 mi southwest of CNS. Four farm wells within 1 mi of the station, all only 15 ft deep, produce a

limited amount of ground water. None of these wells are impacted by ground water pumping at

CNS because the station wells are screened in an unconfined aquifer and have limited area of

influence. A search of wells by NPPD in Atchison County, Missouri, across the river from CNS

identified no wells within 2 mi of the station. In addition, the Missouri River serves as a ground

water recharge/discharge boundary.

Because of the limited radius of influence of CNS wells completed in the unconfined aquifer, no

public ground water supplies are close enough to CNS to be impacted by ground water use at

the station. There are no well-head protection areas or EPA-designated sole source aquifers in

the vicinity of CNS (CRA, 2007).

2.2.4 Surface Water Resources

CNS is within the Nemaha River Basin whose water resources are managed by the Nemaha

Natural Resources District (NNRD). The basin is defined as those areas south of the Platte

River that drain directly into the Missouri River. The total area of the basin is 2,800 square miles

(mi 2 ) (7,252 square kilometers (km 2)) (NPPD, 2008a).

Flow of the Missouri River at CNS is partially controlled by the Gavins Point Dam located

approximately 200 mi (321 km) upstream near Yankton, South Dakota. The USACE constructed

and operates six of the seven mainstem dams on the Missouri River; the U.S. Bureau of

Reclamation operates the seventh dam located east of Helena, Montana. The confluence of the

Platte and Missouri rivers is located 63 mi (101 km) north of CNS. The Platte River discharges a

significant amount of sediment into the Missouri, much of which is carried downriver to CNS and

beyond (NPPD, 2008a).

At CNS, the Missouri River is approximately 800 ft (244 m) wide and 28 ft (8.5 m) deep in the

main channel. As currently regulated by the USACE, the minimum flow in the river for navigation

purposes in March through November at Nebraska City, NE, 30 mi (48.3 km) north of CNS, is

31,000 cfs (878 m3/s). In December through February, the minimum flow permitted is 4,320 cfs

(122 m3/s. The lowest flow recorded at Nebraska City was 4,320 cfs (122 m3

/s) in 1957. If a

July 2010 2-25 NUREG-1437, Supplement 41
Affected Environment

severe drought occurs, USACE would shorten the navigation season to keep upstream

reservoirs high enough to maintain minimum sanitary flows. Water release schedules and

priorities for the dams are contained in the USACE Master Manual (USACE, 2004a).

Water level elevations in the river at CNS range from 874.5 to 899 ft (266.5 to 274 m) AMSL

with an average level of 880 ft (268 m). The mean annual discharge of the river at Nebraska

City is 42,160 cfs (1,194 m3/s) as measured and calculated for the years since 1948 when the

upstream impoundments started to control flows. Because the river has been channelized and

has a relatively uniform cross-section, flow velocity is up to 3 mph (3.8 kilometers per hour

(kmh)), which is significantly higher than historic flows prior to completion of the major

impoundments (NAS, 2002).

Significant changes in the Missouri River due to management practices include loss of natural

flood and low flow processes, straightening of meanders, bank stabilization, and reduction of

temperature variation. These changes, although ecologically significant, result in a more stable

water supply for CNS.

2.2.5 Description of Aquatic Resources

2.2.5.1 Ecosystem Services Provided by Missouri River Aquatic Ecosystems

The Missouri River has provided and continues to provide many ecological services to people

living within its basin. The phrase ecosystem services "refers to a wide range of conditions and

processes through which natural ecosystems, and the species that are part of them, help

sustain and fulfill human life" (Daily et al., 1997). These services are intrinsic to the river itself

and go beyond the obvious constructed economic services of providing a route for

transportation or a source of water for irrigation and public consumption.

Daily et al. (1997) provide examples of general ecosystem services, and the NRC staff identified

the following ecosystem services specifically provided by the Missouri River. The Missouri River

supports birds and other wildlife through fish, insect, and other food webs and also provides

recreational and commercial fishing. The river supports populations of mussels that once were a

major source of food, tools, and jewelry for Native Americans and later a source of buttons and

starting nuclei for cultured pearls. It provides drinking water that supports many forms of

domestic animals and wildlife and helps maintain biodiversity from which key ingredients are

derived for agricultural, pharmaceutical, and industrial enterprises. The river supports the

aquatic phase of insect predators that help control agricultural and other pests.

Within the Missouri River ecosystem, bacteria, algae, fungi, and invertebrates absorb waste

nutrients and break down, detoxify, and decompose various wastes and, in doing so, purify

water. Living and nonliving components of the aquatic ecosystem participate in the oxygen,

carbon, and nitrogen cycles and help mediate concentrations of oxygen and carbon dioxide in

the air. Bacteria, fungi, and invertebrates, that break down wastes and organic matter, help

make the soil fertile with suspended solids that the river deposits following floods. In doing this,

the river helps cycle and move nutrients. The river also helps disperse seeds of some natural

vegetation. The Missouri River helps maintain the balance of recharge to the ground water and

cycling of water back to air as part of moderating the water cycle. The river also provides

aesthetic beauty, intellectual stimulation, and opportunities for education:

NUREG-1437, Supplement 41 2-26 July 2010
Affected Environment

2.2.5.2 Conceptual Model of Midwestern Rivers

Karr et al. (1985) summarized the history and sources of degradation of Midwestern rivers. The

conclusions, which they illustrate with examples from the Maumee and Illinois rivers, are

applicable to understanding the aquatic resources of the Missouri River near CNS today. Karr et

al. (1985) found that the human activity with the greatest impact on Midwestern fish

communities was agriculture, which lowers the water table and supplies excess nutrients;

navigational locks and channels in large rivers; impoundments, levees, and milldams; discharge

of wastes that consume oxygen and toxic contaminants; overconsumption of water; and

introduction of exotic species. The authors presented a conceptual model to illustrate the links

between these activities and those for recovery and restoration of Midwestern river fish

communities.

In their conceptual model (Figure 2.2.5-1), five primary variables affect the integrity of aquatic

biota:

(1) The energy source may be primarily allochthonous (not formed in situ, but originating in

another place) organic matter or primary production. As well as the amount of energy,

the size distribution of organic particles affects aquatic communities.

(2) Water quality includes such factors as temperature, turbidity, dissolved oxygen

concentration, soluble organic and inorganic materials, metals, and toxic substances.

(3) Habitat structure includes such things as bottom type (e.g., hard substrata, sand); water

depth; current velocity; availability of spawning, nursery, and hiding places; and habitat

diversity.

(4) Flow regime indicates water volume, seasonality and temporal distribution of flow and

water volume, and frequency of flooding.

(5) Trophic interactions among biotic components include such factors as competition,

predation, disease, and parasitism.

Natural changes and human activities act through these five primary variables affecting the

integrity of aquatic biota to cause changes in aquatic communities. The following summary of

natural and human history in the Missouri watershed, represented in Figure 2.2.5-1, shows

continual changes in the factors that influence the structure and function of aquatic communities

in this Missouri River.

July 2010 2-27 NUREG-1437, Supplement 41
Affected Environment

LAND-WATER

INTERFACE

EXTERNAL INTERNAL

Weather I Riparian • Flow Water

Climate Environment Regime Quality

Biotic Fish

Interactions Community

XChannel Structure

Morphometry S

AEnergy

Source

Physical Land Use Habitat

Redrawn after Karr et al. 1985

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

their interactions that govern the integrity of the aquatic biota of Midwestern streams

(After Karr et al., 1985)

2.2.5.3 Description of the Missouri River Basin

The nature of Missouri River aquatic resource communities strongly reflects the formation and

history of the prairie region it drains. The Missouri River basin is large, and its present ecology

was formed fairly recently on a geological and evolutionary time scale. Because of its size, the

basin encompasses many diverse habitats on regional and local levels. Because it is fairly

recent, many species that live in the basin are not endemic but have evolved elsewhere and

moved into the basin. The present ecology of aquatic communities reflects a history of change

both prehistoric and historic and of habitat diversity within seasons and across various

geographic scales.

The modern Missouri River basin is the second largest in the United States and drains about a

sixth of the conterminous United States as well as part of Canada, including all or parts of

10 U.S. States, 2 Canadian provinces, and 25 Native American lands or tribal reservations.

Many of the Missouri River's tributaries drain east to the main stem, which flows roughly

southeast. Starting from the west, the river basin drains three physiographic divisions: the

Rocky Mountain System, which contributes a little over 10 percent of total flow; the Interior

Plains; and the Interior Highlands. Most of the river flows through the highly erodible soils of the

Great Plains and Central Lowlands' physiographic provinces of the Interior Plains division,

which produces high turbidity and sediment transport (Galat et al., 2005b).

Change and perturbation heavily influence the ecology of the Missouri River, including the

aquatic ecology. Glaciers covered much of the basin during the last ice age and helped

determine the course of the modern Missouri River and its tributaries, as well as land forms and

soils. The modern prairie drained by the Missouri River is relatively young and formed in the last

several million years so that much of the flora and fauna have colonized from surrounding

ecosystems and few species evolved in and are endemic to the prairie (Benedict et al., 1996).

Between the last ice age, which ended about 10,000 years ago, and the beginning of recorded

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Affected Environment

history of the prairie, invasion and colonization of the basin by plants and animals, and later

humans, and extinction of nearly all large mammal species brought further change. Early human

settlement probably had limited effects on the ecology of the basin until the 20th century, when

the Federal government intervened to encourage further settlement and development (National

Research Council, 2002).

Increased settlement occurred through the 1800s, and irrigated agriculture resulted in the early

construction of first small and then larger dams in the late 1800s. From the mid-1820s through

the 1870s, the Federal government worked to remove large tree snags from the Missouri River

to improve navigation. The USACE began stabilizing the river banks in the late 1880s.

Construction of hydropower dams began in the late 1800s. Several irrigation projects began in

1904, and by the 1930s, most of the tributaries of the Missouri River had one or more dams. In

the late 1920's, the USACE began a program that combined bank stabilization with dike

construction and strategic dredging designed to narrow the river and eliminate meandering.

Where the USACE eliminated wide bends in the river and narrowed the channel, the river's

velocity increased, and in some places the river became self-scouring. The subsequent Federal

Pick-Sloan Plan in 1944 led to the construction of six main-stem dams and dedicated upstream

storage to three primary uses: hydropower generation, navigation enhancement, and flood

control (National Research Council, 2002).

Today the Missouri River is highly regulated, with about 1,200 single-purpose and

100 multipurpose reservoirs, including six reservoirs on the main stem (Galat et al., 2005a),

(Galat et al., 2005b). The aquatic community has been highly influenced by damming and

channelization. The reservoirs have changed lotic (i.e., pertaining to still or standing water)

habitat into lentic (i.e., pertaining to flowing or running water) habitat and impaired the migration

of fish and other aquatic organisms. The construction of structures such as dikes, levees,

stabilization structures, and dams have added hard substrata, or replaced soft substrata with

hard substrata in aquatic habitats. The reservoirs, channels, and structures affect physical

habitat, water temperature and quality, flow regimes, suspended sediment loads, and light

penetration, and many other attributes of the aquatic ecosystem (Galat et al., 2005a),

(Galat et al., 2005b). The prairie is subject to frequent perturbations on time scales that range

from shorter than a year to those spanning decades or millennia, such as fire, drought, flooding,

grazing, storms, and local events such as digging activities of animals (Benedict et al., 1996). All

of these influences affect aquatic habitats and communities.

The climate in the basin is semi-arid, and both direct precipitation and snow melt contribute to

the flow, which results in a seasonal succession of low and high flows. Before dam construction

and regulation, river flows peaked twice a year: A smaller peak in March through April as snow

and ice melted in the middle and upper basins and the prairie, and a second, larger peak in

June as the result of melting snows in the Rocky Mountains and precipitation over the prairie.

Overbank flooding was common during peak flows. Flows then declined in July and remained

low until spring (Galat et al., 2005a).

Before dam construction and regulation of the river, the variation in flow drove changes in the

river channel's location, form, and volume of sediment transported. The river carried large

amounts of sediment and was known as the "Big Muddy." During high flows, erosion could be

severe. As flooding subsided, the river deposited substantial amounts of sediments on flood

plains. In a dynamic equilibrium, the river redistributed sediments between its channel and

floodplain. The channel was braided to highly sinuous and "characterized by log jams, snags,

whirlpools, chutes, bars, cut-off channels, and secondary channels around bars" (National

Research Council, 2002). Sand bars shifted frequently. "A typical cross-section of the

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pre-regulation Missouri River contained a deep channel, multiple side channels, oxbow lakes,

islands, sand bars and dunes, and backwater habitats interspersed by areas of higher land."

The seasonal pattern of flow and temperature cued many natural processes, such as fish

spawning, insect emergence, and seed germination. The diverse habitat with frequent

disturbance supported high biodiversity and biological productivity (National Research Council,

2002).

In the post-regulation Missouri River, main stem dams dampen the high variation in flows below

them, and the extremely high and low flows no longer occur. Dredging and channelization have

eliminated much of the temporal and spatial variation. In channelized areas, a typical cross

section of the post-regulation Missouri River is trapezoidal rather than varied, and in places,

complex. Suspended sediment loads now drop from suspension in the relatively still water of

reservoirs behind dams, where clearer water supports greater primary productivity and aquatic

species that hunt by vision. Channel degradation occurs below the dams while sedimentation

accumulates in reservoirs, and these processes slowly change aquatic habitats. Seasonal cues

to biological processes are muted. Fish no longer use floodplains seasonally for spawning and

as nursery areas for their young. The water, sediment, and nutrients that once spread across

the flood plains are now contained within the channel and reservoirs. In the change from pre- to

post-regulation, some aquatic species thrived, and some, such as pallid sturgeon

(Scaphirhynchus albus) and sauger (Sander canadense), experienced sharp reductions.

Overall, the less diverse habitat and decreased disturbance of the post-regulation Missouri

River support lower biodiversity and lower biological productivity (National Research Council,

2002).

The biological classifications of its terrestrial ecosystems, land uses, and the distribution of fish

in the entire basin and in the main stem illustrate the spatial diversity of the Missouri River. The

Missouri River flows through and drains six terrestrial ecoregions: North Central Rockies

Forests, Montana Valley and Foothill Grasslands, Northwestern Mixed Grasslands, Northern

Mixed Grasslands, Central Tall Grasslands, and the Central Forest/Grassland Transition Zone

(Galat et al., 2005b). Within 3 mi (5 km) of the river, however, most of the land use is in cropland

(33 percent), grassland (26 percent), and developed land (17 percent) (Galat et al., 2005b).

Abell et al. (2000, 2008) define three aquatic ecoregions of the Missouri River primarily on the

basis of fish distribution: the Upper Missouri, Middle Missouri, and the Central Prairie.

Based on geomorphology and hydrology, Galat et al. (2005a, 2005b) recognize three zones of

the Missouri River main stem: (1) the upper zone, from the origin of the Missouri River to Fort

Peck Lake, Montana, which is the first major impoundment, is unchannelized and largely flows

freely; (2) the middle zone, from the upper end of Fort Peck Lake to the Gavins Point Dam,

which forms Lewis and Clark Lake, is not channelized but has impoundments, and can be

subdivided into a reservoir zone made up of individual impoundments separated by an

inter-reservoir, riverine zone that connects them; and (3) the lower zone, from Gavins Point

Dam to the confluence with the Mississippi River, is channelized and has bank stabilization and

floodplain levees. CNS lies within the lower, channelized zone.

2.2.5.4 Physical Features of the Missouri River near the Cooper Nuclear Station

CNS is located on the west bank of the Missouri River at RM marker 532.5 (1,960 RM). The

bottom contour of the river at CNS is roughly trapezoidal. The Missouri River channel in front of

CNS is at an elevation of about 860 to 865 ft (262 to 265 m) AMSL compared to the natural

grade level of the flood plain around CNS of 890 ft (271 m) AMSL. On average, the river is

about 800 ft (245 m) wide and 28 ft (8.5 m) deep in the vicinity of CNS. Riprap covers some

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areas of shoreline near the CNS, and soft sediments are typically composed of medium to

course sand. Pile dikes and shoreline protection stabilize the channel. Gavins Point Dam,

located about 200 RM (322 river kilometers (RKm)) upstream in Yankton, South Dakota, largely

controls the flow of the Missouri River at CNS. The flow changes seasonally, but the annual

mean river flow from 1930 through 2001 was 38,251 cfs (1,083 m3/s) at the USGS gauging

station located about 30 RM (48 RKm) upstream at Nebraska City, Nebraska. NPPD owns the

345 kV transmission line designated as TL3504 that passes over the Missouri River at CNS; at

the center of the Missouri River, transmission line ownership changes (NPPD, 2008a).

2.2.5.5 Potentially Affected Aquatic Resources

Several publications and reviews provide comprehensive descriptions of the Missouri River

aquatic ecosystems, including National Research Council (2002), Galat et al. (2005a, 2005b),

and USACE (2004). From the headwater streams to the main stem Missouri River, aquatic

communities show the affects of man's activities. Rabeni (1996) summarized the state of the

fish and aquatic resources of the prairie ecosystem as follows:

The ecological integrity of most prairie streams has been compromised, because

every important relation has been affected: flow conditions by dewatering, altered

land-use, and disruption of headwaters; energy source balance by the increase

of instream primary production with nutrients and less shading; water quality by

modern synthetic compounds and organic wastes; physical habitat by

channelization and riparian degradation; and the biotic balance by the

introduction of fish predators and competitors and elimination of important food

sources.

Comparing this description to Karr et al.'s (1985) conceptual model of Midwestern rivers

(Figure 2.2.5-1), one can see that human activities have adversely affected all aspects of the

environment that influence the integrity of aquatic communities.

Much of the information summarized below is from a compendium of studies (Hesse et al.,

1982) conducted in the late 1960s and early 1970s to provide ecological information for

assessing the impacts of Fort Calhoun Station and CNS, both on the Missouri River. Fort

Calhoun Station is a nuclear generating unit located at RM marker 646 (1,040 RKm), about

113.5 RM (183 RKm) north of CNS, which is located at RM marker 532.5 (857 RKm); the

aquatic communities at the two stations are similar.

2.2.5.6 Primary Producers: Phytoplankton, Periphyton, and Aquatic Macrophytes

Before the completion of the dams on the main stem, phytoplankton abundance was low due to

the high turbidity and current velocity and the lack of still water habitats. Although dams now

replace lotic habitat with lentic habitat where sedimentation increases water clarity, the limiting

factor for algal growth in much of the river is still light, not nutrients, due to turbidity (Galat et al.,

2005b).

Galat et al. (2005a) summarized the ecology of planktonic algae and cyanobacteria in the

Missouri River basin. Most of the information dated from the 1980s or before. Reetz (1982)

reported results of phytoplankton studies conducted in the Missouri River in the vicinity of CNS

and Fort Calhoun Station, about 113.5 RM (183 RKm) north of CNS, from 1974 through 1977.

The composition of the phytoplankton community through the year was largely determined by

discharges from Lewis and Clark Lake (RM marker 811, RKm marker 1,305), which is 278.5 RM

(448 RKm) upstream, with modifications due to "production in backwater areas of the

unchannelized river, production in pools behind the trail dikes in the channelized portion, input

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of phytoplankton from tributaries, and the scouring of periphytic forms" (Reetz, 1982, p. 73).

While the species may have changed over the last several decades since Reetz's 1982 studies,

the process he describes likely remains unchanged. Although Reetz (1982) could discern no

I clear trend in phytoplankton abundance at CNS for the 1974-1977 study period, carbon fixation

rates were generally lower in winter and highest in mid-summer. Carbon fixation is the

photosynthetic process by which plants convert carbon dioxide (and water) to sugar (and

oxygen).

Reetz (1982) compared phytoplankton functions at the intake and discharge of both CNS and

Fort Calhoun Station. Initial (7-hour) differences in carbon fixation rates at CNS ranged from an

average of about 17 percent inhibition during summer to no change during winter. The inhibition

in the summer months appeared to depend on absolute discharge temperature and the highest

inhibition rates (above 26 percent) occurred when absolute discharge temperatures exceeded

I 101OF (38.50C). Recovery from initial inhibition at CNS occurred within 48 hours. While the river

would carry phytoplankton far downstream in 48 hours so that a substantial part of the river

I would be affected, Reetz (1982) concluded that the low rate of water use by CNS compared to

river flow combined with the rapid mixing of the thermal plume would make the effects relatively unnoticeable.

Farrall and Tesar (1982) reported results of periphytic algae studies conducted in the Missouri

I River in the vicinity of CNS from 1972 through 1977, and Fort Calhoun Station from 1974 and

1975. Periphytic algae are those algae attached to solid surfaces under water, such as rocks,

logs, pilings, and other structures. Because they remain in one place, periphytic algae

colonizing natural and artificial substrata can be used as indicators of environmental effects.

Algae fix carbon through photosynthesis and are a base of food webs. In some rivers, such as

the Missouri River, organic matter from land and upstream sources is often another base of

local aquatic food webs. Farrell and Tesar (1982) did not detect changes in the diversity,

I density, and biovolume of periphytic algae related to water temperature in the vicinity of CNS,

although species composition did reflect water temperature. Although these results may

I generally be indicative of periphyton responses and processes at CNS today, species

composition and magnitude of response, which depends on the species involved, may have

changed over the decades since Ferral and Tesar's (1982) studies.

High turbidity, unstable substrates, and variable currents almost exclude aquatic macrophytes

from the Missouri River (Galat et al. 2005a), and the NRC staff found no studies of these

macrophytes in the vicinity of CNS.

2.2.5.7 Invertebrates: Zooplankton and Benthos

Repsys and Rogers (1982) reported results of invertebrate zooplankton studies conducted in

the Missouri River in the vicinity of CNS and Fort Calhoun Station from 1972 through 1977.

Zooplanktons are animals suspended in the water column and typically contain permanent

residents of the water column; temporary members swept up by currents, etc.; and organisms

that spend only part of their life cycle in the water column, such as insect and fish eggs and

larvae. Zooplankters eat algae and bacteria, protozoans, other zooplankton, detritus, fish eggs

and larvae, or a combination of these, and, in turn, are eaten by other invertebrates, fish, and

amphibians. In general, zooplanktons are more adapted to the lentic environment of lakes and

reservoirs than the lotic environment of streams and rivers. In flowing water environments,

currents and suspended sand can buffet zooplankters and cause mechanical damage, while

smaller suspended silt and clay particles can adhere to their bodies and interfere with

respiration and feeding.

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Repsys and Rogers (1982) concluded that the zooplankton community near CNS appears to be

largely determined by upstream reservoirs, where the lentic environment encourages their

production. The most common groups they collected include copepods and cladocerans (both

crustaceans) and rotifers. While the general pattern of abundance in the study indicated

relatively high crustacean peaks in late fall to spring and reduced populations during summer

and early autumn, the pattern was poorly defined. The authors concluded that the seasonality of

zooplankton densities in the limnetic Lake Francis Case, which is more like a natural lake and

has high zooplankton production, influenced through releases the pattern of zooplankton

downstream in the smaller and less productive Lewis and Clark Lake, which in turn influenced

through releases the pattern of zooplankton downstream at CNS.

Decreasing zooplankton densities in the river indicated to them that zooplankton populations

originating in the highly productive Lake Francis Case experienced considerable mortality on the

downriver journey to CNS. Repsys and Rogers (1982) also investigated the effects of CNS on

zooplankton populations in 1974 through 1978. High absolute discharge temperatures greater

than or equal to 95 0F (35 0C) critically affected zooplankton survival, as did duration of exposure.

Repsys and Rogers (1982) concluded that entrainment losses were small when compared to

the large downstream decreases in zooplankton. Without further studies, the NRC staff

concludes that these general patterns and processes most likely still occur, although species

composition and magnitude of response, which depends on the species involved, may have

changed over the decades since Repsys and Rogers' (1982) studies.

Carter et al. (1982) reported results of benthic infaunal and epifaunal (called aufwuchs on the

artificial substrate samples employed by Carter et al.) invertebrate studies conducted in the

Missouri River in the vicinity of CNS and Fort Calhoun Station from 1973 through 1977. Benthic

infauna refers to the organisms that live in underwater sediments, and benthic epifauna refers to

organisms that live on underwater surfaces. Benthic invertebrates form a complex community.

Various members may eat algae filtered from the water column, suspended detritus and

organisms, sediments, periphytic algae and bacteria, other benthic organisms, and fish eggs

and larvae. Carter et al. (1982) report that the channel area of the Missouri River in the vicinity

of CNS is largely unsuitable for macroinvertebrates because of continuous shifting and scouring

of bottom sediments. In the lee of wing dikes, sedimentation occurs during periods of low flow

and supports infaunal communities that may be lost due to scouring during periods of high flow.

The seasonal diversity of the benthic community in this area is inversely related to the variability

of the flow as measured on a daily basis (Carter et al., 1982): benthic diversity is higher when

flows are stable. The most common members of the benthic community are oligochaete worms,

primarily tubificids, which live in tubes and may avoid direct contact with the currents, and

secondarily naids, which live in the surface layers of sediments and may be subject to low level

scouring. Another numerically important group was insect larvae of the family Chironomidae, or

non-biting midges (flies). All of these groups are indicative of organically enriched sediments

and tolerate low dissolved oxygen levels and so have been designated as indicators of poor

water quality (Barbour et al., 1999).

Epifaunal invertebrates in this section of the river are typically found on dikes and riprap. Carter

et al. (1982) report that the most common members on dykes and artificial substrate samplers

were chironomid, trichopterid (caddisfly), and ephmeropterid (mayfly) larvae. The caddisfly

larvae found here are typically net spinners and filter feeders whose survival depends on

currents. The chironomid larvae included grazers, predators, and tube-dwellers. The insect

larvae are seasonal members of the macroinvertebrate community that become terrestrial after

emergence. Carter et al. (1982) were not able to detect consistent changes in the epifaunal

invertebrate community due to the operation of CNS.

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2.2.5.8 Larval Fish

Hergenrader et al. (1982) report the results of both field and entrainment studies on larval fish in

the vicinity of CNS in 1974 through 1976. Several life stages of fish may occur in the plankton,

where they are called ichthyoplankton, and may be subject to entrainment at power plants:

eggs; larvae, which include both yolk-sac and post yolk-sac larvae and have little or no fin

development; post larvae, which have fully developed fins but bodies that have not yet reached

the adult form; and juveniles, which have attained the adult form but are still immature. Eggs

I and juveniles in the collections near CNS were not commonly caught, and made up 2 percent

and 1 percent, respectively, of all ichthyoplankton. Larval fish were common in the drift near

I CNS from May through July, and the numerically dominant fish larvae were freshwater drum,

catastomids (e.g., suckers), cyprinids (e.g., minnows), and carp. Larval fish were rare or absent

in other months. Although freshwater drum comprised only about 5 percent of adult fish in the

vicinity of CNS, since they are pelagic spawners, spawning in the open water column, they

contributed 70 to 90 percent of the larvae. Other species commonly found as larvae in the drift,

common carp (Cyprinus carpio), catastomids, gizzard shad (Dorosoma cepedianum), and

goldeneye (Hiodon alosoides), are also either random or pelagic spawners. The larvae of most

of the game fish in the area-white bass (Morone chrysops), sunfish (Lepomis spp.), crappie

(Pomoxis spp.), sauger (Stizostedion canadense), walleye (Sander vitreus), and channel catfish

(Ictalurus punctatus)-were relatively underrepresented because most of these fish either build

nests or spawn randomly, most have adhesive and demersal (sinking) eggs, and some of these

species provide parental care of the eggs and larvae,

Depending on the species, the sources of the larvae near CNS included the upstream Lewis

and Clark Lake, tributaries, cut-off chutes, and backwaters. Densities of ichthyoplankton also

depended on time of year, river flow, horizontal position in the river (cutting bank, mid-channel,

or filling bank), depth and patterns of vertical migration, and growth and mortality rates

(Hergenrader et al., 1982).

Hergenrader et al. (1982) also report on entrainment mortality. The NRC staff conclude that little

can be learned from their direct observations of entrainment mortality because the control

mortality measured at the intake was very high, which makes estimation of plant-induced

mortality impossible, and because they only observed immediate mortality (typically 20 to 40

minutes after collection), which does not provide an estimate of longer-term or chronic mortality.

Injured larvae may not die immediately, and today the standard holding time for fish larvae in

short-term chronic toxicity tests with a survival endpoint is typically 7 days (EPA, 2002) in order

to account for mortality that is not immediate. In order to determine if entrainment (and

impingement) were having an effect on the fish populations in the area, Hergenrader et al.

(1982) looked for changes in adult fish populations resulting from impacts to ichthyoplankton but

detected none. They concluded that either no significant changes occurred or "[t]oo few

resources (financial, technical, equipment, labor) were applied over too small a time frame in too

restricted an area to detect the changes which have occurred."

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2.2.5.9 Fish

Galat et al. (2005a, 2005b) report about 183 fish species from the Missouri River, of which

about 136 were found in the main channel. No fish species are unique to the main stem

(i.e., endemic species), and just two are endemic to the Missouri River basin. About three

quarters of Missouri River fish species are native, that is, they live and survive in the river under

natural conditions and have not been introduced by human activity. The majority of the species

(68 percent) belong to just five families: Cyprinidae (e.g., carp, chub, dace, shiners, minnows),

Catostomidae (e.g., suckers, chubsuckers, redhorse, buffalo), Salmonidae (e.g., trout, salmon,

whitefish), Centrarchidae (e.g., sunfish; crappies; freshwater basses, but not striped bass and

white bass), and Ictaluridae (e.g., catfish, bullhead, madtom). About half of the species are

"Big-River species," meaning that they occur primarily in the main channel. Lists of species from

the Missouri River can be found in Galat et al. (2005a) and USACE (2003, as reproduced in the

ER).

Galat et al. (2005a) present summary data from which the NRC staff made several

observations. The study lists 53 species as prevalent or common in the Central Lowlands

physiographic province that includes CNS. The species were assigned to mutually exclusive

guilds: most (27 spp.) are macrohabitat generalists and the rest distribute evenly between fluvial

specialists and fluvial dependents (12 species each). The generalists may inhabit either

reservoirs or river segments that connect them, while the other two groups are either

specialized for or dependent on flowing river habitat. The high proportion of generalists reflects

the variability and history of continued change in the Missouri River system. In terms of habitat,

46 of the prevalent fish species in the Central Lowlands have been found in the channel and

channel borders, 9 in floodplains, and 8 in reservoirs, including the species that can be found in

more than one of these habitats. The high proportion found in the channel and channel border

reflects the history of the river as a flowing water body before regulation and formation of

reservoirs. Within the main channel and channel borders, 35 species are associated with the

main channel, 9 with channel borders, and 8 are "waifs," that is, removed from their original

habitats.

CNS is located below the Gavins Point Dam, the last of the six major dams, in a riverine

environment that extends unimpeded to the mouth of the Missouri River at St. Louis. The upper

section of this reach is unchannelized north of Sioux City, Iowa with such diverse habitat

characteristics as chutes, backwater marshes, sandbars, islands, snags, deep pools, and

variable current velocities. The environment is changing due to the downstream effects of

Gavins Point Dam and the sedimentation that occurs behind it, as well as some armoring of the

riverbed and bank stabilization, which cause channel degradation and siltation of shallow areas,

with associated loss of marshes, backwaters, and chute habitats (USACE, 2004a, p.100).

Downstream of Sioux City, construction of dikes, revetments, and channelization result in a less

diverse environment. Yet, the most common fish species are similar in the unchannelized and

channelized portions of the river. These include emerald shiner (Notropis antheroides), river

carpsucker (Carpiodes carpio), channel catfish (Ictalurus punctatus), gizzard shad (Dorosoma

cepedianum), red shiner (Notropis lutrensis), shorthead redhorse (Moxostoma macrolepidotum),

common carp (Cyprinus carpio), and goldeye (Hiodon alosoides). Big river fish in the lower river

and its major tributaries include pallid sturgeon (Scaphirhynchus albus), shovelnose sturgeon

(Scaphirhynchus albus), and paddlefish (Polyodon spathula) (USACE, 2004a).

The aquatic community, particularly the fish community, may not be stable and may still be

changing in response to historical changes in land use, river regulation, and other human

activities. For example, USACE (2004) reports that the benthic fish community appears to be

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Affected Environment

changing based on 1996 and 1997 studies. The diversity of species in the unchannelized

section appears to be increasing, possibly due to the diverse habitats. Typically more species

are found at shallow depth (less than 2 m) and slower water velocities (less than

0.6 m/s), and fish in the unchannelized section are most abundant in the backwater areas. In

the channelized segment below Sioux City, most fish are near revetments and dikes. Although

surveys have found the most fish in this segment in side channels, few such habitats remain.

USACE (2004) reported that ecologists know very little of the mechanisms that control fish

production in the channelized segment of the river.

Other investigators have reached similar conclusions. Rabeni (1996) found that "[d]rastic

changes in the streams and rivers of the prairie region and their fish fauna have occurred in the

last 150 years." More recently, the NRC (2003) reported that:

The aquatic resources in the vicinity of Fort Calhoun Station are associated with

the Missouri River. The species composition of the fish community in this reach

of the river has changed significantly (due to channelization) from the 1973 to

1977 fish studies associated with the initial licensing of Fort Calhoun Station and

its operations.

2.2.6 Terrestrial Resources

The CNS site is located within the Missouri alluvial plains level IV ecoregion in Nebraska and

Missouri, and lies near the western limit of a relatively flat, 6-mi wide (10-km) alluvial floodplain.

Natural relief on the CNS site is limited to about 10 ft (3 m). Much of this floodplain has been

ditched and drained for farming, with numerous levees constructed for flood protection.

Immediately west of the CNS site and running north-south are bluffs rising approximately 170 ft

(52 m) above the CNS property and the Missouri River (NPPD, 2008a) that transition into the

Nebraska/Kansas loess hills level IV ecoregion (USGS, 2001).

According to the ER, the CNS facilities are located within 55 ac (22 ha) of a 1,120-ac (454-ha)

site in Nemaha County, Nebraska, adjacent to the western bank of the Missouri River at

RM marker 532.5. There is an additional 239 ac (97 ha) of undeveloped CNS property across

the Missouri River and adjacent to its east bank in Atchison County, Missouri. The CNS property

in Nebraska is bordered on the west by Nemaha County Road 648A Avenue, the Missouri River

on the east, and by agricultural lands on the north and southsides. The CNS property in

Missouri is adjacent to the eastern bank of the Missouri River and is bordered by cropland on its

east and timberland on its north and south sides (Figure 2.2.1-1) (NPPD, 2008a).

On the Nebraska side of the CNS site, approximately 715 ac (289 ha) are currently used for

agricultural activities. There are also more than 120 additional acres (49 ha) of vegetated,

nonagricultural land located primarily contiguous with the riverbank but extending inland in some

areas into the farm fields on the site. Most of these vegetated areas are classified as palustrine

forested, scrub-shrub, and emergent wetlands (USFWS, 2009a) and include two segments of

intermittent streams and, according to NPPD staff, a 55-ac (22 ha) wetland area, which includes

an approximately 1.5-ac mitigation site. One wetland area is located in the middle of a farm field

in the south-central part of the property (Figure 2.2.6-1). The USFWS has identified over 700

wetlands within a 6-mi (10-km) radius of CNS (USFWS, 2007b). The remaining acreage on the

Nebraska side includes the riverbank, streams and canals, and transmission line corridors.

Several segments of intermittent streams are subject to plowing, which may impact wetland

resources (NPPD 2008a). NPPD staff noted that these intermittent streams drain south from the

CNS site into the adjacent USACE Langdon Bend Wetlands Restoration Project and into the

NUREG-1437, Supplement 41 2-36 July 2010
Affected Environment

Little Nemaha River, and finally into the Missouri River (NDNR, 2009). The Langdon Bend

project is one component of the larger Missouri River Mitigation Project (USACE, 2004b).

Additional surface water at the CNS site drains from the wetlands and fields directly into the

Missouri River by way of man-made drainage ditches and into the Little Nemaha River by way

of the intermittent tributary system. However, NPPD staff indicated that the farm fields and

wetland areas still flood, primarily from overland drainage, and occasionally because of

overbank flow from the Missouri River.

PS;,)• S IA

PF

PUBFh

NI

PFOC7% PFOl:C"

NebraskaRUB

PE~ Nemaha PUS~ 4 ~ Langdon

~1

PCC E

_ _ __ __IlA

' }4

, ], Nebraskax

P E M PP FliS %

- ssc~ P

_ _ __pcnter.40" 21" 5 9•+38 1N. 30 W.I

Figure 2.2.6-1. Nontidal Wetlands Located on the Cooper Nuclear Station Site (Source:

USFWS, 2009a; National Wetlands Inventory; Nemaha Quad; NPPD, 2008a). (Note that the

wetlands polygon is approximate and includes the 55-ac (22-ha) NPPD wetlands mitigation

site.)

NPPD staff indicated that a system of levees on the Nebraska side of the CNS site is designed

to protect the CNS reactor and support buildings from a 200-year flood event. Additional levees

have been constructed along both sides of the Missouri River floodplain through the entire CNS

site. Levee construction on the Missouri River was initiated in 1945 as part of a Federal project

implemented in 1912 to deepen and widen the Missouri River for navigation purposes. Earthen

levees were constructed along the eastern border of the CNS property located in Missouri.

July 2010 2-37 NUREG-1437, Supplement 41
Affected Environment

On the Nebraska side of the river, the alluvial bottomland and rolling floodplains are dominated

by cottonwood (Populus deltoides), green ash (Fraxinus pennsylvanica), boxelder (Acer

negundo), elm (Ulmus spp.), lowland tallgrass prairie, big bluestem (Andropogen gerardif),

prairie cordgrass (Spartina pectinata), switchgrass (Panicum virgatum), and several sedges

(USGS, 2001).

In Missouri on the CNS property, approximately 200 ac (81 ha) of the 239 ac (97 ha) are

classified as palustrine forested wetlands and flood periodically. The NRC staff noted during the

site audit evidence of flood water from the Missouri River reaching over 4 ft high on some trees

on the Missouri side of the CNS property. The two transmission line corridors running east-west

through the Missouri property (not in scope) are primarily emergent wetlands where the

transmission lines do not cross cropland. Less than 40 ac (16 ha) of the 239 ac (97 ha) have

been cleared and are used for agricultural activities.

The forested riparian areas on the Missouri side of the CNS property are dominated by

cottonwood, American sycamore (Platenus occidentalis), silver maple (Acer sacharrinum), black

willow (Salix nigra), boxelder, buttonbush (cephalanthus occidentalis), and false indigo

(Amorpha fruticosa) (NRCS, 2007). The two transmission line corridors located on the Missouri

side are dominated primarily by emergent wetlands vegetation, similar to the grasses described

on the Nebraska side, as well as some scrub-shrub wetlands vegetation.

I Several exotic invasive plant species are located along the riverbank of the CNS site, and

include purple loosetrife (Lythrum salicaria) and reed canary grass (Phalaris arundinacea)

(NRCS, 2007). The common reed (Phragmites austrailis) is another exotic invasive species

I found along the riverbank in the vicinity of the CNS site that was recently added to the list of

noxious weeds by the Nebraska Department of Agriculture (NDA, 2008).

While much of the CNS site and vicinity is agricultural land, there are a number of wooded areas

and hedgerows that provide habitat for several species of mammals common to this region,

including coyote (Canis latrans), white-tailed deer (Odocoileus virginianus), raccoon (Procyon

Iotor), eastern cottontail rabbit (Sylvilagus floridanus), muskrat (Ondatra zibethicus), mink

(Mustela vison), bobcat (Lynx rufus), and mice and other small mammals (Bailey, 2007).

The CNS site provides habitat to a variety of game birds and resident and neo-tropical migratory

songbirds primarily along the transmission line corridor and within the wooded wetland and

scrub-shrub habitat on both sides of the river, some of which were observed by the NRC staff

I during the site audit. Species of game birds that are commonly found in the vicinity of CNS

include the northern bobwhite quail (Colinus virginianus), the ring-necked pheasant (Phasianus

I colchicus), and the the wild turkey (Meleagris gallopavo). Other birds commonly found on CNS

property and the transmission line corridor include cliff swallows (Petrochelidon pyrrhonota), the

American kestrel (Falco sparverius), the turkey vulture (Cathartes aura), the killdeer (Charadrius

vociferus), the horned lark (Eremophila alpestris), and the American bald eagle (Halieatus

leucocephalus) (Bailey, 2007), (UNSM, 2007a). There is an active bald eagle nest on the

I Missouri side of the CNS property with a breeding pair of eagles that have produced a number

of chicks over the past several years (NPPD, 2008a). Although no longer protected under the

ESA, the bald eagle is still protected from any take without a permit under the Bald and Golden

Eagle Protection Act (50 CFR Part 22) (NPPD, 2008a).

NUREG-1437, Supplement 41 2-38 July 2010
Affected Environment

CNS is located along an overlapping section of the Mississippi and Central Flyways, with 20

waterfowl species following the Missouri River during fall and spring migrations. These

waterfowl may use the wetlands located on the CNS site (NPPD, 1971) and its vicinity. The ER

contains information on observed bird mortality at CNS from 2003-2006, including a great

horned owl (Bubo virginianus), a number of additional birds, and the death in 2006 from West

Nile Virus of a juvenile bald eagle found near CNS (NPPD, 2008a).

Several amphibians and reptiles are found or are potentially found in the vicinity of CNS and the

transmission line corridor. Reptiles include the painted turtle (Chrysemys picta), the common

snapping turtle (Chelydra serpentine), the eastern rat snake (Elaphe obsoleta), two species of

garter snakes (Thamnophis spp.), and the prairie kingsnake (Lampropeltis calligaster).

Amphibians include the Cope's gray treefrog (Hyla chrysoscelis), the northern cricket frog (Acris

crepitans), the northern leopard frog (Rana pipiens), and the bullfrog (Rana catesbeiana)

(UNSM, 2007b).

2.2.7 Protected Species

The National Marine Fisheries Service (NMFS) and USFWS are responsible for listing aquatic

and terrestrial species as threatened and endangered at the Federal level, as delegated by the

ESA. The State may list additional species that are regionally threatened or endangered. For

the purposes of this SEIS, all Federally- and State-listed species that occur or potentially occur

in Nemaha County, Nebraska (the location of CNS) and Johnson, Gage, Lancaster, Saline,

Fillmore, York, Hamilton, and Merrick counties, Nebraska, as well as Atchison County, Missouri,

have been included (Illinois Wildflowers, 2009), (Kansas Wildflowers and Grasses, 2009),

(MOBOT, 2009), (MDC, 2009b), (MDC, 2009c), (Missouri Plants, 2007), (NatureServe, 2009d),

(NatureServe, 2009e), (NGPC, 2008), (NGPC, 2009c), (NPPD, 2008a), (NRCS, 2009),

(USFWS, 2008a), (USFWS, 2009b), (USGS, 2006), (USGS, 2008), (UWYO, 2002), where

transmission line corridors associated with CNS lie (Table 2.2.7-1). On January 15, 2008, the

NPPD contacted the USFWS regional offices in Nebraska and Missouri, the Nebraska Game

and Parks Commission (NGPC), and the Missouri Department of Conservation (MDC) regarding

any concerns these Federal and State natural resources agencies may have as a result of the

license renewal action at CNS. The NGPC has not commented upon potential impacts to

Federally- or State-listed threatened or endangered species, but has provided an updated list of

Nebraska species of concern (NGPC, 2009c).

July 2010 2-39 NUREG-1437, Supplement 41
Affected Environment

Table 2.2.7-1. Listed Aquatic and Terrestrial Species

The species listed are Federally-listed, Nebraska-listed, and/or Missouri-listed as threatened,

endangered, or State species of concern (SC). State SC may be further classified as S-1, S-2,

S, or SX as described at the bottom of this table. The listed species may occur on the CNS site

or in its vicinity, within the Missouri River, or within the transmission line corridors.

Federal State

Scientific Name Common Name Status(a) Status(b)(c) Habitat

Fish

Acipenser fulvescens Lake sturgeon - T (NE) Large turbid rivers

Cycleptus elongatus Blue sucker - T (NE) Rivers

Fundulus zebrinus Plains killifish - SC (MO) Streams and lakes

Hybognathus argyritis Western silvery minnow - SC (MO) Creeks and backwaters

Hybognathus placitus Plains minnow - SC (MO) Perennial plains streams

Macrhybopsis meeki Sicklefin chub - T (NE) Free-flowing rivers with high

turbidity

Macrhybopsis gelida Sturgeon chub - E (NE) Free-flowing rivers with high

turbidity

Platygobio gracilis Flathead chub - E (MO) Main stem Missouri River and

small streams

Scaphirhynchus albus Pallid sturgeon E E Main stem Missouri and

Mississippi rivers

Reptiles and Amphibians

Agkistrodon contortrix Copperhead

Ambystoma texanum

Carphophis vermis

Crotalus horridus

Elaphe vulpina vulpine

Smallmouth salamander -

Western wormsnake -

Timber rattlesnake -

Western fox snake -

S2 (NE) In or near deciduous forest in

hilly situations; vicinity of rock

outcrops; floodplains; mesic

situations near water in the

arid west

S1 (NE) Adults migrate from upland,

mesic forests to breed in

fishless, seasonal, and

semipermanent wetlands

S2 (NE) Woodlands; forest edge;

moist, rocky, hillsides; riparian

corridors in prairies; burrowing

in or using soil, fallen logs, or

debris

S1 (NE) Riparian; forested and

scrub-shrub wetlands; high,

dry ridges; hilltop rock

outcrops in thick woods

E (MO) Farmlands, prairies, stream

valleys, woods, and dune

habitats

I NUREG-1437, Supplement 41 2-40 July 2010
Affected Environment

Federal State

Scientific Name Common Name Status(a) StatuB(b)(c) Habitat

Eumeces obsoletus Great Plains skink - 32 (MO) Open plains, rolling

grasslands with few trees and

scattered rocks; takes refuge

under rocks, logs, or other

cover

Gastrophryne olivacea

Lampropeltis calligaster

Lampropeltis getula

Liochlorophis vemalis

Ophisaurus attenuatus

Rana pipiens

Regina grahamii

Great Plains

narrowmouth toad

Yellow-bellied

kingsnake

Common kingsnake

Smooth green snake

Slender glass lizard

Northern leopard frog

Graham's crayfish

snake

S2 (NE) Variable: creeks, pools,

temporary pools, grasslands,

rocky wooded hills, rotten

logs; burrows under rocks

S2 (NE) Prairies, (including sand

prairies), open grassland,

forest edge; fields; ditches;

woodlands; stream valleys

and bluffs

S1 (NE) Open coniferous forest,

prairie, desert, woodland,

swamps, coastal marshes,

river bottoms, farmland, and

chaparral.

S1 (NE) Meadows, grassy marshes,

SX (MO) moist grassy fields at forest

edges, stream borders;

mountain shrublands, bogs,

abandoned farmland; vacant

lots; extirpated in Missouri.

S1 (NE) Open grassland; prairie; open

and woodland edge; scrubby

areas; fallow fields; near

streams and ponds; often in

habitats with sandy soil

S2 (MO) Springs, slow streams,

marshes, bogs, ponds, canals,

flood plains, reservoirs, and

lakes; permanent water with

rooted aquatic vegetation; wet

meadows and fields;

overwinters usually

underwater

S2 (NE) Sluggish and still waters and

their vegetated margins;

marshes, swamps; roadside

ditches

T (NE) Wetlands,

E (MO) grassland/herbaceous, old

field, savanna,

shrubland/chaparral,

woodlands

S2 (NE) Semiaquatic; wide range

shrubby habitats near lakes,

ponds, sloughs, ditches,

swamps, and marshes

NUREG-1437, Supplement 41

Sistrurus catenatus Massasauga

rattlesnake

Thamnophis proximus Western ribbon snake

July 2010 2-41
Affected Environment

Federal State

Scientific Name Common Name Status(a) Status(b)(c) Habitat

Birds

Ammodramus henslowii

Bonasa umbellus

Henslow's sparrow

Ruffed grouse

Charadrius melodus Piping plover

Falco peregrinus

Grus americana

Lanius ludovicianus

Peregrine falcon

Whooping crane

Loggerhead shrike

S2 (NE) Grassland; open fields and

meadows; shrubby vegetation;

damp or low-lying areas

SX (NE) Presumed extirpated; dense

forest with some deciduous

trees; both wet and relatively

dry situations

T T (NE) Sandy upper beaches with

sparse vegetation, sparsely

vegetated shores and islands

of shallow lakes, ponds,

rivers, and impoundments

S1 (NE) Various open situations with

S1 (MO) suitable nesting cliffs and tall

buildings with ledges;

non-breeding: occurs in

farmlands, marshes,

lakeshores, river mouths, tidal

flats, and urban areas

E E (NE) Wetlands, wet meadows,

sandbars, and shallow water

in rivers

S2 (MO) Open country with scattered

trees and shrubs, savanna,

desert scrub, open woodland;

often perches on poles, wires,

or fence posts

S1 (NE) Breeding and non-breeding:

S1 (MO) shallow portions of salt,

brackish, and freshwater

marshes; pond borders; wet

meadows; and grassy

swamps

E SX (NE) Possibly extinct;

non-breeding: grasslands,

pastures, plowed fields, and

less frequently, marshes and

mudflats; nests in open Arctic

tundra

S1 (NE) Freshwater marshes,

S1 (MO) upland-wetland marsh edges,

flooded farmlands, shrub

swamps

E E (NE) Bare sand bars and sandy

S1 (MO) shorelines of large rivers,

lakes, and sand pits

S2 (NE) Dense woodland and forest,

swamps, wooded river valleys

Laterallus jamaicensis Black rail

Numenius borealis Eskimo curlew

Rallus elegans King rail

Sterna antillarum athalassos Interior least tern

Strix varia Barred owl

NUREG-1437, Supplement 41 2-42 July 2010
Affected Environment

Federal State

Scientific Name Common Name Status(a) Status(b)(c) Habitat

Thryothorus ludovicianus Carolina wren S2 (NE) Open deciduous woodland,

thickets, undergrowth, parks,

forest edge, pine barrens, and

shrubbery of residential areas

Tryngites subruficollis Buff-breasted sandpiper S1 (NE) Migratory through Nebraska;

short grass plains and dry

uplands; man-altered habitats

such as fields, golf courses,

and runways

Mammals

Glaucomys volans Southern flying squirrel - T (NE) Red oak-basswood-ironwood

forest

Lontra canadensis River otter - T (NE) Streams, lakes, ponds,

swamps, marshes, estuaries

(in some areas), and exposed

outer coast

Microtus pinetorum Woodland vole - S1 (NE) Wide variety of habitats,

prefers upland wooded areas

with thick layers of loose soil

and humus in shallow burrows

Mustela nigripes Black-footed ferret E E (NE) Limited to open habitat and

burrows used by prairie dogs;

grasslands and shrub steppe

Perognathus flavescens Plains pocket mouse - S2 (MO) Tallgrass prairie and

sandy-loose soil prairies

Spermophilus franklinhi Franklin's ground - S2 (MO) Tallgrass and mid-grass

squirrel prairies; riparian areas;

forest-field edges, fields,

hedgerows, unmowed strips of

railroad ROWs, and roadsides

Spilogale putorius interrupta Plains spotted skunk - S1 (NE) Forested areas, habitats with

E (MO) significant cover, open and

brushy areas, rocky canyons

and outcrops in woodlands

and prairies

Myotis sodalis Indiana bat E E (MO) Hibernates in caves; foraging

habitats include riparian

areas, upland forests, ponds,

and fields

Insects

Atrytone arogos iowa Iowa skipper - S1 (NE) Short grass prairie in Colorado

to mesic or dry tall grass

prairie.

Cicindela nevadica lincolnaina Salt Creek tiger beetle E E (NE) Eastern Nebraska saline

wetlands and their associated

streams

July 2010 2-43 NUREG-1437, Supplement 41
Affected Environment

Federal State

Scientific Name Common Name Status(a) Status(b)(c) Habitat

Cicindela togata White-cloaked tiger S1 (NE) Very open saline areas far

beetle from vegetation; salt flats, salt

marshes, and saline

lakeshores

Melanoplus packardii Packard's grasshopper - S2 (MO) Bare, somewhat grassy

beaches; sandy woods,

always on dry sand and not on vegetation

Nicrophorus americanus American burying beetle - S1 (NE) Broad vegetational tolerances;

SH (MO) mature forest, grassland, and

old field shrubland

Plants

Agalinis purpurea Large-purple false

foxglove

Anagallis minima Chaffweed

Anemone cylindrica

Arisaema dracontium

Amoglossum atriplicifolium

Asclepias amplexicaulis

Asclepias purpurascens

Astragalus lotiflorus

Bidens polylepis

Blephilia hirsuta

Bouteloua gracilis

Bouteloua hirsute var. hirsuta

Thimbleweed

Green dragon

Pale Indian-plantain

Clasping milkweed

Purple milkweed

Low milk vetch

Awnless beggar-ticks

Hairy woodmint

S1 (NE) Moist sand prairies; sandy

savannas, paths, and

openings in sandy woodlands;

boggy areas; occasional

disturbance

S1 (NE) Bare damp ground, by

roadsides

S2 (MO) Dry open woods, slopes,

prairies, and along railroad

grades

S2 (NE) Moist deciduous woodlands,

shady seeps, and wooded

areas adjacent to springs and

vernal pools

S2 (NE) Full to partial sun; prairies,

woods; in sandy, loamy soil

S1 (NE) Prairies, glades, rocky open

woods, roadsides, and

railroads

S1 (NE) Rocky open woods, glades;

prairies; stream banks; wet

meadows; valleys; thickets;

and roadsides

S2 (MO) Dry native prairie in areas

where the shortgrasses like

blue grama grow

S2 (NE) Wet prairies and meadows,

swampy woods, roadsides,

and disturbed grounds

S1 (NE) Rich, moist, shady woods,

slopes, and valleys

SI (MO) Dryish soils on upland short

grass prairies and along

railroad tracks

Blue grama

Hairy grama S2 (MO) Shortgrass prairies

NUREG-1437, Supplement 41 2-44 July 2010
Affected Environment

Federal State

Scientific Name Common Name Status(a) Status(b)(c) Habitat

Brachyelytrum erectum

Buchloe dactyloides

Carex bushii

Carex crus-corvi

Carex frankii

Carex sprengelii

Castilleja sessiliflora

Coeloglossum viride

Corallorhiza wisteriana

Comus racemosa

Corydalis aurea

Cypripedium calceolus

Cypripedium candidum

Dalea enneandra

Dasistoma macrophylla

Desmodium cuspidatum

Bearded shorthusk

Buffalo grass

Bush's sedge

Ravenfoot sedge

Frank's sedge

Longbeak sedge

Downy painted cup

Long-bract Green orchis

Spring coralroot

Gray dogwood

Golden Corydalis

Yellow lady's-slipper

Small white lady's

slipper

Nine-anther dalea

Mullein foxglove

Toothed tick-trefoil

S2 (NE) Mesic upland forests,

bottomland forests, and

occasional dry upland forest

SH (MO) Possibly extirpated

S1S2 (NE) Moist prairies, fields, and

meadows in full sun

(ODNR, 1998).

S1 (NE) Wet meadows and swamps

(MSU, 2007)

S1S2 (NE) Edges of wet woods and

seasonally wet meadows

(USU, 2006)

S1 (MO) Moist soil on bottomlands and

streambanks; cliffs and rocky

slopes

S2 (MO) Dry prairies and rocky hillsides

S1 (NE) Sub-arid soil in damp open

woods; mesic to wet

woodlands, thickets, and

shrub boarders; disturbed

areas

S1 (NE) Terrestrial in moist hardwood

forests and hammocks;

Mycorrhizal with fungi

S1 (NE) Thickets and moist soil in

riparian zones, roadsides, on

sandy slopes and limestone

ridges

51 (NE) Rocky or sandy soils along

lakes or ponds or in open

woods

S1 (NE) Rich, humus and decaying

leaf litter in wooded areas,

often on rocky wooded

hillsides

T (NE) Mesic/wet blacksoil prairie;

S1 (MO) glacial till hill prairie, sedge

meadow, glade; calcareous

soils; extirpated/possibly

extirpated in Missouri

S2 (MO) Grassland and prairie

SI (NE) Rich woodlands, often along

streams

S2? (NE) Dry or rocky woods, thickets,

bluffs, base of slopes, ridges,

ravines, and valleys

July 2010 2-45 NUREG-1437, Supplement 41
Affected Environment

Federal State

Scientific Name Common Name Status(a) Status(b)(c) Habitat

Dracocephalum parviflorum

Eleocharis atropurpurea

Eleocharis wolfii

Erysimum inconspicuum

Erythronium mesochoreum

Galearis spectabilis

Gentiana alba

Helianthemum bicknel/li

Heliotroplum curassavicum var.

curassavicum

Isoetes me/anopoda

Lactuca tatarica var. pu/chella

Lespedeza violacea

Leucospora multifida

Liatris squarrosa var. hirsuta

Mel/ica nitens

American dragonhead

Purple spikerush

Wolf s spikerush

Small-flower prairie

wallflower

Midland fawnlily

Showy orchis

Yellow gentian

Plains frostweed

Seaside heliotrope

Blackfoot quillwort

S1 (NE) Woodland, shrublands, and

openings

S1 (NE) Banks, hammocks, irrigation

S1 (MO) ditches, and lake and pond

margins

S2 (NE) Marshes, wet to wet-mesic

prairies, wetland margins; wet

ditches, sandy roadsides, and

mud flats

S2 (NE) Dry native prairie; found

where grazing is light or

moderate

S2 (NE) Prairies and open woods;

occasionally found in cut-over

woods

S1 (NE) Floodplains

S1 (NE) Mesic black soil prairies,

upland forests, and rocky

bluffs

S1S2 (NE) Sandy soil of open woodlands

and prairie areas

S1 (NE) Dry or moist saline and

S (MO) alkaline areas; seasonal

flooding

S1 (NE) Submerged or in wet soil of

swales and temporary ponds

S1 (MO) Plains, foothills, montane;

meadows and roadside

ditches

S1 (NE) Edges of open upland woods,

roadsides; thickets; rocky

prairies; dry, rocky soils

S1 (NE) Shores and stream banks,

often where sandy

S? (NE) Diverse; including dry, sandy,

upland prairies

S1 (NE) Open woods, moist canyon

slopes, canyon bottoms,

roadsides, rocky grasslands,

and streambanks

S1 (NE) Non-green herb parasitic on

roots of pines

S1 (NE) Wet sandy or muddy stream

SH (MO) banks and alluvial bar

(possibly extirpated)

Blue lettuce

Violet bush-clover

Narrowleaf paleseed

Glades gayfeather

Three-flower melicgrass

Monotropa uniflora

Neeragrostis reptans

Indian-pipe

Hairy creeping

lovegrass

NUREG-1437, Supplement 41 2-46 July 2010
Affected Environment

Federal State

Scientific Name Common Name Status(a) Status(b)(c) Habitat

Nothocalais cuspidate

Nymphaea odorata

Orobanche uniflora

Oxytropis lambertii var. lambertii

Packera glabella

Panax quinquefolius

Paronychia canadensis

Pediomelum argophyllum

Pellaea atropurpurea

Penstemon grandiflorus

Prairie false dandelion

American water-lily

One-flowered

broomrape

Stemless point vetch

Grassleaf ragwort

American ginseng

Forked nailwort

Silvery scurfpea

Purple-stem cliffbrake

Large beard-tongue

S2 (MO) Dry upland areas of prairies,

hill prairies, and rocky slopes

S2 (NE) Lakes, lake margins, ponds,

quiet bays in lakes and rivers,

slow-moving streams, and

ponds

S1 (NE) Parasitic; wooded slopes,

lowland, and rocky base of

bluffs

S2 (MO) Extirpated/possibly extirpated

S1 (NE) Moist-to-wet habitat

(UT, 2009)

T (NE) Rich, cool, moist but not

extremely wet woods, under a

closed canopy; slopes;

ravines

SI (NE) Dry sandy or rocky places

S2 (MO) Moist prairies, rocky hillsides,

lowlands, stream valleys, and

open woodlands

S2 (NE) Crevices of rock outcrops,

bluffs and boulders; sinkholes;

dry soils adjacent to dolomite

glades

Si (MO) Prairie bluffs in open grassy

places

SI (NE) Rich loam or sand loam soil

from open prairies to

deciduous forests; disturbed

areas; rocky glades; along

railroads

T T (NE) Tallgrass prairie; moist,

E (MO) calcareous or subsaline

prairies and sedge meadows

(many flooded for a period of

1-2 weeks during the year)

- S2 (NE) Rich cove forests; mesic

hardwood forests; low

topographic positions

- S1 (NE) Deciduous forests; mesic;

bottomland soil

- S2 (NE) Moist woods, around ponds

and lakes, along streams

- S1 (NE) Saline or alkaline soil of flats,

shores, seepage areas, and

ditches

Penstemon tubiflorus White-wand

beardtongue

Platanthera praeclara Western prairie fringed

orchid

Podophyllum peltatum Mayapple

Quercus alba White oak

Ruellia strepens

Salicornia rubra

Limestone wild petunia

Western glasswort

July 2010 2-47 NUREG-1437, Supplement 41
Affected Environment

Federal State

Scientific Name Common Name Status(a) Status(b)(c) Habitat

Schoenoplectus saximontanus

Senna marilandica

Sparganium chlorocarpum

Spiranthes vemalis

Symphoricarpos occidentalis

Trifolium reflexum

Triodanis perfoliata var. biflora

Verbena simplex

Veronicastrum virginicum

Rocky Mountain bulrush

Maryland senna

Greenfruit bur-reed

Twisted ladies'-tresses

Wolfberry

Buffalo clover

S1 (NE) Damp soils to emergent,

S1 (MO) freshwater ponds; ditches,

often drying; disturbed and

sandy areas

- S1S2 (NE) Prairie ravines, open woods,

thickets, disturbed areas, and

bases of slopes and bluffs;

dry, gravelly soils

- S2 (NE) Shallow water or mud of

marshes, streams, ditches,

and ponds, where the water is

fairly fresh

- S2? (NE) Moist open areas, meadows,

swales, and bogs

- S1 (MO) Open prairies, and moist, low

ground around streams or

lakes

- S1 (NE) Rocky open woods, glades,

old fields, and prairies

- S1 (NE) Dry sandy or gravelly prairies,

pastures, waste ground, and

occasionally woodlands

- S1 (NE) Dry, open waste areas, rocky

prairie hillsides, and roadsides

S1 (NE) Varied habitats; moist

tallgrass prairie and prairie

remnants, moist woods,

woodland borders, thickets,

fields and meadows, stream

banks and terraces

S2 (NE) Dry upland woodlands, rocky

wooded slopes, and thinly

wooded bluffs

S1 (NE) Low woods, floodplains, along

streams, marshes,

bottomlands

S2 (MO) Loess hill prairies

Claspingleaf

Venus'-looking-glass

Narrowleaf vervain

Culver's-root

Viola palmata

Vitis cinerea

Yucca glauca

Palmate-leaved violet

Pigeon grape

Small soapweed yucca

(a) E = Endangered; T = Threatened

(b) NE = Nebraska; MO = Missouri

(c) S = State listing; S1 = critically imperiled; S2 = imperiled; SX = presumed extirpated; SH = possibly extirpated.

Note that S3 species ("vulnerable") such as Bald Eagle are not included in this list in order to maintain a

less-expansive list.

Sources: NGPC, 2008; NGPC, 2009c; MDC, 2009b; MDC, 2009c; USFWS, 2008a; USFWS, 2009b; UW, 2009

NUREG-1437, Supplement 41 2-48 July 2010
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2.2.7.1 Aquatic Species

Table 2.2.7-1 presents aquatic species that are listed as protected by the USFWS, the State of

Nebraska, and the State of Missouri that have the potential to occur in counties near CNS or

along the transmission corridors. One fish species is listed by the USFWS for Nemaha County,

Nebraska: the pallid sturgeon (Scaphirhynchus albus) (USFWS, 2007a). Regarding State-listed

species, Hesse et al. (1982) report the identification of several fish species then listed as

threatened or endangered by Iowa, Missouri, or Nebraska, based on studies from 1971 through

1977 from the channelized Missouri River in the reach from Fort Calhoun Station to CNS. These

included skipjack herring (Alosa chrysochloris, listed in Iowa), sturgeon chub (Macrhybopsis

gelida, listed in Iowa and Missouri), blue sucker (Cycleptus elongateus, listed in Missouri),

plains killifish (Fundulus kansae, listed in Missouri), and burbot (Lota Iota, listed in Missouri). Of

these, they collected a single sturgeon chub (in 1977), 3 plains killifish (in 1971), 10 burbot, and

consistently low numbers of blue suckers near CNS. MDC (2009) no longer lists sturgeon chub,

plains killifish, or burbot, and Iowa no longer lists the sturgeon chub (Iowa Administrative Code,

Chapter 77). Fish species that the States of Missouri and Nebraska currently list and that Hesse

et al. (1982) collected near CNS or in the reach between CNS and Fort Calhoun Station in the

1971 through 1977 studies include sturgeon chub, blue sucker, and plains killifish. The NRC

staff did not find more recent data on fish species living in the Missouri River near CNS, but lack

of captures does not necessarily indicate absence of uncommon species in any case.

Life History of Pallid Sturqeon

Sturgeon are members of an order of fish (Acipenseriformes) that probably evolved in the

Devonian age. Living members of this order in North America include the paddlefish and eight

sturgeon species. The paddlefish (Polyodon spathula) and three sturgeon species, the lake

sturgeon (Acipenser fulvescens), pallid sturgeon (Scaphirhynchus albus), and the shovelnose

sturgeon (S. platorynchus), live in the Missouri and Mississippi rivers. In the past, commercial

fishermen harvested all three of the sturgeon species in the Missouri and Mississippi rivers.

Today pallid sturgeon are a Federally-listed endangered species, and lake sturgeon are listed

as endangered by Nebraska. The life history information below is from Dryer and Sandvol

(1993) and the USFWS (2007) if not otherwise cited.

Pallid sturgeon have a flattened snout, a long tail, and rows of bony armor plates. The upper

side is convex and the lower side is straight. They have an inferior (bottom-facing) mouth and

eat invertebrates, such as the immature stages of insects, and fish. The body shape is well

adapted for swimming close to the bottom of relatively fast flowing, large rivers. The diet, inferior

mouth, and barbels in front of the mouth are well adapted to feeding on or near the bottom in

highly turbid environments.

The USFWS listed pallid sturgeon as endangered in 1990. The historic abundance of pallid

sturgeon is somewhat vague since biologists did not recognize it as a separate species from

shovelnose sturgeon until 1905, but its historical range probably extended from the middle and

lower Mississippi River in the south up through the Missouri River and lower reaches of the

Platte, Kansas, and Yellowstone rivers in the north and west. The pallid sturgeon is one of the

largest fish species in those rivers. Available information suggests that the pallid sturgeon was

not a common species since the time of European settlement. Today pallid sturgeon are among

the rarest fish of the Missouri and Mississippi River basins, and the present range includes the

States of Montana, North and South Dakota, Nebraska, Iowa, Kansas, Missouri, Illinois,

Kentucky, Arkansas, Mississippi, and Louisiana. The populations consist mostly of older fish

that will likelydie off in the near future.

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Fisheries biologists know little about pallid sturgeon reproduction or even preferred spawning

habitats and conditions. Hurleya et al. (2004) tracked sonically-tagged pallid sturgeon in the

Mississippi River and found that they exhibited positive selection for the main-channel border,

downstream island tips, between-wing-dam, and wing-dam-tip habitats; they showed negative

selection for main-channel, downstream of wing dams, and upstream of wing dam habitats. The

sturgeon exhibited little habitat selection for temperature or dam discharge. The authors

concluded that habitat enhancement and restoration of habitat diversity might be necessary for

the recovery of pallid sturgeon.

Reports of pallid sturgeon reproduction are rare. The USGS (2007), NGPC, and the USACE

confirmed spawning of two female pallid sturgeon in the upstream reaches of the lower Missouri

River in May 2007. The capture of young pallid sturgeon that would verify natural reproduction

are also rare: none were captured between 1978 and a Mississippi River trawl survey in 1998

through 2000 using equipment designed to capture larval fish in deep, turbulent water (Hrabik et

al., 2007). Hrabik et al. (2007) concluded that those latest captures verified reproduction,

possibly from the lower Missouri River to the upper and lower Mississippi River, although they

also found no evidence of recruitment of pallid sturgeon because they captured no juveniles

after 374 trawl hauls that captured over 21,735 fish in that 1998 through 2000 survey. Wildhaber

et al. (2007) suggest that one or more of the following factors may be responsible for the lack of

finding larval pallid sturgeon and of recruitment: lack of successful spawning, low recruitment,

high mortality, ineffective sampling methods, inadequate sampling of drift and settling locations,

or rapid dispersal and washout of sturgeon larvae in the Missouri and Mississippi rivers. Pallid

sturgeon larvae are indistinguishable from those of the congeneric shovelnose sturgeon, which

may also help to explain the paucity of reported collections in the past. Also, the construction of

dams and other structures with resulting habitat change and the elimination of shallow areas in

the river with little or no flow have probably deprived sturgeon of critical nursery areas needed

for the survival of immature sturgeon (MDC, 2009c).

Larval pallid and shovelnose sturgeon become strongly photopositive and migrate upwards

toward the light starting the first day after hatching. As a result, they remain far above the

bottom, even at the water surface, and migrate far downriver (Kynard et al., 2002). Cultured

yearling pallid sturgeon in laboratory studies also migrate downstream during summer and fall,

which suggests a two-stage (larval, then yearling) downriver migration in the first year of life.

Adult sturgeon are also highly migratory and often migrate hundreds of miles in a year.

The young of both shovelnose and pallid sturgeon eat invertebrates, but as pallid sturgeon

grow, they become more piscivorous. Gerrity and Guy (2006) found that the diet of juvenile

pallid sturgeon of age 6 and 7 was mostly fish, compared to the diet of shovelnose sturgeon,

which is mainly aquatic insects. Sturgeon chub (Macrhybopsis gelida) and sicklefin chub (M.

meeki) together comprised 79 percent of the number of identifiable fish in juvenile pallid

sturgeon stomachs. Populations of these two cyprinid minnows have declined throughout much

of the Missouri River due to the construction of dams and man's other alterations of river

habitat. While the population of the piscivorous pallid sturgeon has declined in the Missouri and

Mississippi rivers, the population of its similar, insectivorous congener, shovelnose sturgeon,

has not declined. Gerrity and Guy (2006) concluded that the prevalence of sicklefin chub and

sturgeon chub as a food resource of juvenile pallid sturgeon may help explain the decline of

pallid sturgeon populations and that recovery and management of native cyprinids is a

potentially important step in the recovery of pallid sturgeon.

Male pallid sturgeon are believed to mature at 7 to 9 years after which they spawn at intervals of

2 to 3 years. Females may reach sexual maturity at 7 to 15 years and spawn at intervals up to

NUREG-1437, Supplement 41 2-50 July 2010
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10 years. Individuals may reach ages of 60 years or more and reach lengths of 6 ft (2 m). Like

many other fish species, the largest individuals are found farthest north in the species' range

and maximum size decreases with distance south. For example, the maximum weight of pallid

sturgeon in the upper Missouri River in Montana and North Dakota is 86 lbs (39 kg), in the

Missouri River in South Dakota and Nebraska 46 lbs (21 kg), and in the Mississippi River 26 lbs

(12 kg). They become much larger than shovelnose sturgeon, which rarely weigh more than

8 lbs (3.6 kg).

While they were successful in the historical Missouri and Mississippi rivers, with the high flow

and turbidity and diverse habitats of floodplains, backwaters, chutes, sloughs, islands, sand and

gravel bars, and both braided and main channels, they are not so well adapted to the Missouri

and Mississippi rivers today with the construction of dams that isolated subpopulations,

channelization, controlled flow, and elimination of habitat diversity. The USFWS (2007)

concludes that man's activities have adversely affected all of the 3,350 mi (5,390 km) of river

habitat within their range, and habitat alteration and loss may be the biggest threat to their

existence. Other threats may include hybridization with shovelnose sturgeon, commercial

fishing, and exposure to environmental contaminants such as polychlorinated biphenyls,

cadmium, mercury, selenium, chlordane, dichlorodiphenyltrichloroethane (DDT),

dichlorodiphenyldichloroethylene (DDE), and dieldrin, all of which have been found in pallid

sturgeon tissue in the past.

During the early 1990s, the MDC developed "action plans" for lake and pallid sturgeon with a

goal of reestablishing self-sustaining populations so they can be delisted as endangered

species and ultimately provide limited sport fisheries. These plans stress the restoration of both

species through habitat improvement, artificial propagation, protection, research, management,

and education (MDC, 2009c). As part of this effort, the MDC's Blind Pony Fish Hatchery has

raised and stocked over 13,000 fingerling pallid sturgeon and 200,000 fingerling lake sturgeon

into the Missouri and Mississippi rivers (MDC, 2009c). In addition to these efforts, the USGS

(Wildhaber et al., 2007) has developed a conceptual life history to organize the understanding

about the complex life history of Scaphirhynchus sturgeon and improve understanding of the

effects of management actions on the ecological requirements of pallid and shovelnose

sturgeon. The USFWS's Pallid Sturgeon Recovery Plan (Dryer and Sandvol, 1993) designated

six recovery priority management areas (RPMAs) for implementation of recovery tasks, and

CNS is located within RPMA 4.

In 2000, the USACE, which provides the primary operation management of the Missouri River,

asked the USFWS for formal consultation under the ESA on the operations of the Missouri River

Main Stem System, and related operations of the Kansas River Tributary Reservoirs, and the

operations and maintenance of the Missouri River Bank Stabilization and Navigation Project

(USFWS, 2000b). The USACE prepared biological assessments for these projects and

determined that their operations may affect listed species, including the endangered pallid

sturgeon. The USFWS found that the proposed actions were likely to jeopardize the continued

existence of pallid sturgeon, as well as the endangered least tern and threatened piping plover,

though not the then-threatened bald eagle. Working together, the USACE and the USFWS

developed Reasonable and Prudent Alternatives under the ESA to help ensure the continued

existence of the three species by returning some natural form and function to sections of the

Missouri and Kansas rivers. Under the Alternatives, the following five actions are designed for

pallid sturgeon: (1) enhance flow by including a spring release from Fort Peck dam and a spring

rise and summer drawdown from Gavins Point dam to provide spawning clues and enhance

aquatic habitat; (2) restore, create, enhance, acquire, or conserve habitat; (3) unbalance the

upper reservoirs, (4) use an adaptive management process combined with monitoring; and

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(5) increase pallid sturgeon propagation and augmentation efforts while the habitat and

hydrology improvements are being implemented.

The USFWS (2003a, 2003b) issued a supplemental biological opinion that applied only to

operations in 2003 due to a continuing drought. It represented a collaborative effort between the

USFWS and the USACE and considered habitat conditions and new information not considered

in the November 2000 biological opinion. The USACE changed flow regime in the Missouri

River and the USFWS stocked year-old pallid sturgeon, both as interim measures in 2003. The

USFWS (2003a, 2003b) reported that the long-term survival of pallid sturgeon will depend on a

more natural hydrograph consisting of an increase in spring flows and declining summer flows.

2.2.7.2 Terrestrial Species

Federally Protected Species

Eight animal and plant species Federally-listed as threatened or endangered (Table 2.2.7-1) are

known to occur or to potentially occur on terrestrial habitat within the vicinity of CNS or along the

associated in-scope transmission line corridor. The ranges of four of these species, the Indiana

bat (Myotis sodalis), the western prairie fringed orchid (Platanthera praeclara), the piping plover

(Charadrius melodus), and the interior least tern (Stema antillarum athalassos) may include the

CNS site. The Indiana bat and interior least tern are listed as endangered, and the western

prairie fringed orchid and piping plover are listed as threatened (USFWS, 2008a), (USFWS,

2009b).

Seven Federally-listed species are potentially present along the transmission line corridor,

including the western prairie fringed orchid. The endangered species are the Salt Creek tiger

beetle (Cicindela nevadica lincolniana), the black-footed ferret (Mustela nigripes), the interior

least tern, the Eskimo curlew (Numenius borealis), and the only known wild population of

whooping crane (Grus americana). The Eskimo curlew is extirpated from Nebraska and is

globally extinct or near-extinct. The piping plover is listed as a threatened species and may be

found along the western limit of the transmission line corridor by the Platte River, along with the

interior least tern and whooping crane (NatureServe, 2009e), (USFWS, 2008a), (USFWS,

2009b), (USFWS, 2009c).

While threatened piping plovers have not been observed along the CNS shoreline, they have

been found along the Missouri River in close proximity to CNS and along the Platte River near

the western limit of CNS transmission line NPPD TL3502 (USFWS, 2002), (USFWS, 2009c),

(NatureServe, 2009a). The piping plover is a small shorebird with a white underbelly and pale

brownish upper parts, with an average length of 6-7 inches (16-18 cm) and a wingspan of

about 15 inches (38 cm). The plover has a small black ring around the base of its neck and a

black band over its eyes on its forehead (NatureServe, 2009a), (USFWS, 1997). Piping plover

habitat includes river channels, their associated sandbars and islands, and their sparsely

vegetated shorelines and peninsulas (USFWS, 2002). Even though the shoreline along the

Missouri River at CNS does not contain the characteristics required by piping plovers for

nesting, they have been reported in the vicinity of CNS. Critical habitat has been designated for

the northern Great Plains breeding population of the piping plover along portions of the Platte

River in Hamilton County and Merrick County, which is the location of the transmission line

I crossing of the Platte River near Grand Island, Nebraska. Interior least terns are found along

portions of the Missouri River in North Dakota, and also nest along portions of the Platte River

I and its tributaries in Hamilton County and Merrick County, Nebraska, near the western limit of

transmission line NPPD TL3502 (NatureServe, 2009b), (NGPC, 2009b). The interior least tern is

a swallow-like bird 8-9 inches (22-24 cm) long with a wingspan of about 20 inches (31 cm). It

NUREG-1437, Supplement 41 2-52 July 2010
Affected Environment

has a pale gray and white body with a glossy black crown, and a long, black-tipped,

yellow-orange bill. The interior least tern nests in habitat similar to that used by piping plovers.

Threats to the interior least tern are also similar to those of the piping plover, with sand and

gravel pits now providing some of the only available nesting habitat for least terns (NGPC,

2009b), (USFWS, 2008b).

The current range of the Indiana bat includes Atchison County, Missouri, on the east side of the

Missouri River from CNS but does not include Nebraska (USFWS, 2008a), (MDC, 2009b),

(MDC, 2009c). The Indiana bat is a medium-sized bat about 2 inches (5 cm) long and weighing

about 1/4 ounce (7 grams) (NYSDEC, 2009) with a wingspan of about 8 inches (20 cm) and

brownish-gray fur (MDC, 2009a). The Indiana bat hibernates in caves during the winter and

migrates to streams and rivers in wooded areas in the summer where they roost under loose

tree bark (NYSDEC, 2009), (MDC, 2009a). Critical habitat for the Indiana bat has been

designated in Missouri, but not in Atchison County (USFWS, 2008a). A number of factors have

contributed to population declines for the Indiana bat; a primary cause for their decline has been

from humans disturbing bats hibernating in caves during the winter. Stream channelization,

deforestation, and agricultural development threaten the habitat of Indiana bats in their summer

range (MDC, 2009a).

The western prairie fringed orchid occurs both in Nebraska and Missouri. It is found in Otoe

County, located immediately north of Nemaha County, which is the location of CNS. It is also

found in Atchison County, Missouri, the location of the Missouri portion of the CNS property

(USFWS, 2008a), (USFWS, 2009b). The western prairie fringed orchid produces flower stalks

up to about 4 ft (133 cm) tall, with up to 40 one inch (2.5 cm) white flowers, attached to the stalk

(USFWS, 2003a), (MNDNR, 1991). It grows in moderately wet to wet prairies and meadows and

is occasionally found in old fields and roadside ditches. Habitat loss through conversion to

cropland is the greatest threat to populations of the western prairie fringed orchid

(USFWS, 2003a).

The only known existing wild population of whooping cranes migrates along the Platte River at

the western limit of the CNS transmission line corridor near Grand Island. The whooping crane

is a large white crane standing as tall as 5 ft (1.5 m) with a wingspan of 8 ft (2.5 m) and

weighing over 17 lbs (8 kg), making it the largest bird in North America and one of the three

largest cranes in the world (NGPC, 2009a). Adult whooping cranes have a red crown and black

forehead with black primary feathers visible during flight (USFWS, 2009h). Whooping cranes

live and breed in wetlands, and feed primarily on crabs, small fish, and other invertebrates

(NGPC, 2009a), (NatureServe, 2008a). Whooping cranes declined to the brink of extinction in

the first half of the 20th century mainly caused by a loss of habitat to agriculture, human

disturbance of nesting areas for eggs, and uncontrolled hunting for meat and plumage. By 1941,

only 14 whooping cranes existed (NatureServe, 2008a), (NGPC, 2009a). Current threats to their

population include habitat degradation, low productivity associated with drought and/or winter

malnutrition, collisions with power lines along their migration routes, and severe weather

phenomena during nesting season (NatureServe, 2008a), (USFWS, 2009c).

There are currently two populations of whooping cranes totaling less than 400 adult and juvenile

birds, including one wild population and one experimental, nonessential population. The wild

population of whooping cranes overwinters in the Aransas National Wildlife Refuge in Texas,

and migrates north in the spring to one small breeding area in Canada (USFWS, 2009d). The

wild population uses the Platte River and its tributaries and surrounding wetlands along its

migratory corridor in the spring and fall. CNS transmission line NPPD TL3502 crosses the Platte

River along the whooping crane migratory corridor 1 mile from the endpoint of the transmission

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line near Grand Island, Nebraska. Critical habitat has been designated for whooping cranes on

the Platte River, located approximately 25 mi (40 km) southwest of Grand Island (USFWS,

1978). The experimental population breeds in Wisconsin and overwinters in Florida and several

other southeastern States (NatureServe, 2008a).

Captive breeding programs over the past several decades have increased whooping crane

populations sufficiently to allow creation of the two experimental populations. As of April 2008,

however, there were still less than 400 adult and juvenile whooping cranes in existence between

these three flocks. Both the wild population and the experimental populations still suffer

mortality attributable to severe weather, lack of food, and collisions with power lines. The wild

Aransas population lost 57 adult and juvenile whooping cranes between spring 2008 and winter

2009, for a loss of 21 percent of its population in 12 months. The spring 2009 flock of whooping

cranes at Arkansas totaled 247 birds (Stehn, 2009).

The NPPD has coordinated efforts with the USFWS to address the potential risk of bird

collisions with transmission line NPPD TL3502, which crosses the Platte River near the end of

the CNS transmission line corridor, located approximately 4 mi (6 km) east of Grand Island,

Nebraska. The Federally-endangered whooping crane (Grus americana), the interior least tern

(Sterna antillarum athalassos), and the Federally-threatened piping plover (Charadrius

melodius) use the Platte River and associated wetlands around Grand Island for different

portions of their life cycle, such as for migration, resting, feeding, and nesting, and risk collisions

with the NPPD transmission line. The USFWS has indicated that collisions with transmission

I lines are the main known cause of whooping crane mortality during their migrations (USFWS,

2009c). On May 8, 2009, NPPD informed the USFWS that NPPD had agreed to mark that

portion of the NPPD transmission line that crosses the Platte River with bird flight diverters to

increase the visibility of the transmission line and reduce the risk of birds colliding with the line

I (NPPD, 2009c). The USFWS replied to NPPD on June 8, 2009, informing them that NPPD had

satisfactorily addressed the concerns of the USFWS regarding bird collisions (USFWS, 2009i).

The extremely rare Salt Creek tiger beetle is found only in the northern third of Lancaster

County, Nebraska (Cornell University, 2008), (USFWS, 2005), (NatureServe, 2008b). The

transmission line corridor for CNS traverses the southern portion of Lancaster County

(NPPD, 2008a). The Salt Creek tiger beetle is about 1/2 inch (1.0 cm) long and is metallic brown

to dark, olive green above with a metallic, dark green underside (USFWS, 2005), (USFWS,

2009e). The tiger beetle is an active predator, grasping other small invertebrates for prey with its

mandibles. The Salt Creek tiger beetle, limited to three populations totaling less than 150 adults,

is found only in saline wetlands and along muddy banks of associated streams and tributaries of

Little Salt Creek in Lincoln, Nebraska. Threats to the remaining populations of the Salt Creek

tiger beetle include habitat loss and degradation caused by development, increased water runoff

and sediment runoff from urban areas, eroding banks associated with development, bank

stabilization projects, pollution, pesticides, and habitat loss and degradation from grazing and

cultivation (Cornell University, 2008), (USFWS, 2005). On December 12, 2007, the USFWS

proposed the designation of critical habitat for the Salt Creek tiger beetle (USFWS, 2009f).

The black-footed ferret is considered to be one of the most endangered mammals in the United

States, and has the potential to survive in Hamilton County and Merrick County, Nebraska, near

the western limit of transmission line NPPD TL3502 (USFWS, 2009b), (NPPD, 2008a). It is a

member of the weasel family (Mustelidae), and is the only ferret native to North America. The

black-footed ferret's distinctive coloration includes a black face mask, black feet, and a

black-tipped tail, with a light yellow-buff color on its back and body. It is approximately 6 inches

(15 cm) tall, 18-24 inches (50-60 cm) long including a 6-inch (15 cm) tail, and weighs

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Affected Environment

1.5-2.5 lbs (0.7-1.1 kg) (Defenders of Wildlife, 2009), (NatureServe, 2009c), (USFWS, 2000a),

(USFWS, 2009g).

Black-footed ferrets once ranged throughout the Great Plains region of the United States and

part of southern Canada. They live primarily on the open prairie and spend most of their time

underground in prairie dog burrows, relying on prairie dogs as their prey. Through the first half

of the twentieth century, the conversion of open prairie to farmland, the shooting and poisoning

of prairie dogs to eliminate them from livestock grazing areas, and sylvatic plague wiped out

large numbers of prairie dogs and correspondingly decimated the black-footed ferret population.

The black-footed ferret was feared extinct by the mid-1 970s, until a small population of 130 was

identified in Wyoming in 1981 (Black-footed Ferret Recovery Implementation Team, 2009),

(Defenders of Wildlife, 2009), (USFWS, 2000a). A captive breeding program over the last

25 years has increased their population from a low of 18 wild black-footed ferrets to their

present number of 750 living in the wild, including an experimental nonessential population and

250 living in captive breeding facilities (USFWS, 2000a), (USFWS, 2009g). Current threats to

the black-footed ferret still include their reliance on prairie dogs as their food source, the

corresponding prairie dog management practices implemented by agricultural interests

competing for land, and the reduction and fragmentation of prairie dog populations to less than

5 percent of their historic range (Defenders of Wildlife, 2009), (NatureServe, 2009c).

State Protected Species

A total of 115 terrestrial species (41 terrestrial animal species and 74 terrestrial plant species)

are protected by Nebraska and Missouri, and are listed as endangered, threatened, or species

of special concern (S1, S2, SX, SH) (Table 2.2.7-1). Ninety-three of the protected species occur

in Nebraska, and 37 of the protected species are in Atchison County, M. These 115 species

have the potential to inhabit the counties within the vicinity of CNS and/or the transmission line

corridor, including Nemaha County, Johnson County, Gage County, Lancaster County, Saline

County, Fillmore County, York County, Hamilton County, and Merrick County, Nebraska, and

Atchison County, Missouri. These 41 animal species include 14 bird species, 12 reptile species,

2 amphibian species, 8 mammal species, and 5 insect species (NGPC, 2008), (NGPC, 2009c),

(MDC, 2009b), (MDC, 2009c), (USFWS, 2008a), (USFWS, 2009b). NPPD has indicated that no

currently Federally- or State-listed terrestrial plant or animal species have been observed on the

CNS property (NPPD, 2008a).

Forty-nine of the protected species inhabit Nemaha County, Nebraska, the location of CNS,

including 15 species of mammals, birds, reptiles, and amphibians, and 34 species of plants

(Table 2.2.7-1). Nebraska lists two mammals, the southern flying squirrel (Glaucomus volans)

as threatened and the woodland vole (Microtus pinetorum) as a species of concern. Both

species occur in Nemaha County. Six bird species protected by Nebraska that occur in Nemaha

County include the ruffed grouse (Bonasa umbellus), the whip-poor-will (Caprimulgus

vociferous), the peregrine falcon (Falco peregrinus), the barred owl (Strix varia), the blue-gray

gnatcatcher (Polioptila caerula), and the Carolina wren (Thryothorus ludovicianus)

(NatureServe, 2009e), (NGPC, 2009c). The peregrine falcon was once a Federally-listed

species, but was delisted in 1999. The bald eagle (Haliaeetus leucocephalus), an S3

designation, has been observed on both sides of the Missouri River on the CNS property. The

bald eagle was likewise a listed species, but was delisted in 2007. Both the peregrine falcon and

the bald eagle are protected under the Migratory Bird Treaty Act, and the bald eagle is also

protected under the Bald and Golden Eagle Protection Act. There is an active bald eagle nest

adjacent to a field on the Missouri side of the CNS property. Six Nebraska State protected

reptiles and one amphibian known to inhabit Nemaha County include the western wormsnake

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Affected Environment

(Carphophis vermis), the yellow-bellied kingsnake (Lampropeltis calligaster), the common

kingsnake (Lam propeltis getula), the smooth green snake (Liochlorophis vernalis), Graham's

crayfish snake (Regina grahami), the Massasauga rattlesnake (Sistrurus catenatus), and the

smallmouth salamander (Ambystoma texanum) (NatureServe, 2009e), (NGPC, 2009c).

Nebraska lists 27 animal species and 39 plant species that are protected and occur or

potentially occur in the counties traversed by the transmission line. Species listed as

endangered by Nebraska that occur or potentially occur in the counties traversed by the

transmission line corridor include the whooping crane, interior least tern, Salt Creek tiger beetle,

American burying beetle (Nicrophorus americanus), Eskimo curlew, and black-footed ferret.

Species listed as threatened by Nebraska that occur or potentially occur in the counties

traversed by the transmission line corridor include the Massasagua rattlesnake, the piping

plover, and the river otter (Lontra canadensus) (NatureServe, 2009e), (NGPC, 2009c).

I The 37 protected species in Atchison, County, Missouri (the eastern portion of the CNS site),

include 16 species of mammals, birds, reptiles, amphibians, and insects, and 21 species of

plants. Two mammals that potentially occur on the CNS site in Missouri include the State

endangered Indiana bat (Myotis sodalis) and the plains spotted skunk (Spilogale putorius

interrupta). Other State protected mammals include the plains pocket mouse (Perognathus

flavescens) and Franklin's ground squirrel (Spermophilus franklinil). Five bird species protected

by Missouri also are in Atchison County, and include the peregrine falcon, the loggerhead shrike

(Lanius ludovicianus), the black rail (Laterallusjamaicensis), the king rail (Rallus elegans), and

the interior least tern. Four reptiles protected by Missouri and known to inhabit Atchison County

are the western fox snake (Elaphe vulpine), the smooth green snake, the Massasauga

rattlesnake, listed as State endangered, and the Great Plains skink (Eumeces obsoletus). One

amphibian protected by Missouri and known to inhabit Atchison County is the northern leopard

frog (Rana pipiens). Two insect species are protected by Missouri and found in Atchison

County, and include Packard's grasshopper (Melanoplus packardii) and the American burying

beetle. The western prairie-fringed orchid is State listed as endangered (MDC, 2009b), (MDC,

2009c), (NatureServe, 2009d).

2.2.8 Socioeconomic Factors

This section describes current socioeconomic factors that have the potential to be directly or

indirectly affected by changes in operations at CNS. CNS and the people and communities

surrounding it can be described as a dynamic socioeconomic system. The nuclear power plant requires people, goods, and services from local communities to operate the plant; and the

communities, in turn, provide the people, goods, and services to run the plant. CNS employees

residing in the community receive income from the plant in the form of wages, salaries, and

benefits, and spend this income on goods and services within the community, thereby creating

additional opportunities for employment and income. People and businesses in the community

also receive income for the goods and services sold to CNS. Payments for these goods and

services create additional employment and income opportunities in the community. The

measure of a communities' ability to support the operational demands of

CNS depends on the ability of the community to respond to changing socioeconomic conditions.

The socioeconomics region of influence (ROI) is defined by the areas where CNS employees

and their families reside, spend their income, and use their benefits, thereby affecting the

economic conditions of the region. The CNS ROI consists of a four-county area (Nemaha, Otoe,

and Richardson counties in Nebraska and Atchison County in Missouri) where approximately

90 percent of CNS employees reside. The following sections describe the housing, public

NUREG-1437, Supplement 41 2-56 July 2010
Affected Environment

services, offsite land use, visual aesthetics and noise, population demography, and the

economy in the ROI surrounding CNS.

NPPD employs a permanent workforce of approximately 750 employees (NPPD, 2008a).

Approximately 90 percent live in Nemaha, Otoe, and Richardson counties, Nebraska, and

Atchison County, Missouri (Table 2.2.8-1). Most of the remaining 10 percent of the workforce

are divided among 23 counties in Iowa, Kansas, Missouri, and Nebraska with numbers ranging

from 1 to 13 employees per county. Given the residential locations of CNS employees, the most

significant impacts of plant operations are likely to occur in Nemaha, Otoe, Richardson, and

Atchison counties. The focus of the socioeconomic impact analysis in this SEIS is, therefore, on

the impacts of CNS on these four counties.

Table 2.2.8-1. Cooper Nuclear Station Employee Residence by County

County Number of Employees Percentage of Total

Nemaha, NE 359 48

Otoe, NE 108 14

Atchison, MO 106 14

Richardson, NE 100 13

Fremont, IA 13 2

Holt, MO 12 2

Cass, NE 11 2

Other 41 5

Total 750 100

Source: NPPD, 2008a

Refueling outages at CNS normally occur at 18-month intervals. During refueling outages, site

employment increases by as many as 700 to 900 workers for approximately 30 days (NPPD,

2008a). Most of these workers are assumed to be located in the same geographic areas as

CNS employees.

2.2.8.1 Housing

Table 2.2.8.1-1 lists the total number of occupied and vacant housing units, vacancy rates, and

median value in the four-county ROI. According to the 2000 Census, there were approximately

17,700 housing units in the socioeconomic region, of which approximately 15,800 were

occupied. The median value of owner-occupied housing units in the three Nebraska counties

ranged from $38,900 in Richardson County to $78,000 in Otoe County. The vacancy rate was

the lowest in Otoe County (7.7 percent) and highest in Richardson County (12.4 percent).

Atchison County, M, has the smallest number of total and vacant housing units among the four

counties (USCB, 2009).

By 2007, the estimated number of housing units grew in all three counties by approximately

3 percent of their total inventories. In Nemaha County, the number of housing units grew to an

estimated total of 3,540 units in 2007, an increase of more than 100 units. In Otoe County, the

number of housing units grew by more than 390 units to an estimated total of 6,955 units or

July 2010 2-57 NUREG-1437, Supplement 41
Affected Environment

approximately 6 percent. The estimated total number of housing units also increased slightly in

Atchison County, Missouri. (USCB, 2009).

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

Atchison County in Missouri

Nernaha Otoe Richardson Atchison ROI

2000

Total 3,439 6,567 4,560 3,103 17,669

Occupied housing units 3,047 6,060 3,993 2,722 15,822

Vacant units 392 507 567 381 1,847

Vacancy rate (percent) 11.4 7.7 12.4 12.3 10.5

Median value (dollars) 58,200 78,000 38,900 49,800 56,225

2007*

Total 3,540 6,955 4,563 3,129 18,187

* Estimated occupied housing units, vacancy, and median value data is not available for all counties.

Source: USCB, 2009.

2.2.8.2 Public Services

This section presents information regarding public services including water supply, education,

and transportation.

Water Supply

Because 90 percent of workers at CNS reside in Nemaha, Otoe, and Richardson counties,

Nebraska and Atchison County, Missouri, the discussion of public water supply systems is

limited to these counties. In Table 2.2.8.2-1, information about municipal water suppliers in

these counties, their permitted capacities and/or maximum design yields, reported annual peak

usage, and population served are presented. The primary source of potable water in the vicinity

of CNS is ground water. Most of Nemaha, Atchison, and Richardson counties are not served by

community water supplies. Private ground water wells supply much of the water to residents in

the area.

There are four wellhead protection areas within 10 mi of CNS: Village of Nemaha, Nemaha

County Rural Water District (RWD) No. 1, City of Auburn, and Village of Stella. CNS does not

use public water systems for cooling or process water systems. NPPD relies on ground water

I wells and surface water from the Missouri River for all of its water needs at the CNS. Two wells

supply potable water to the facility (NPPD, 2008a).

Community water supply systems in Nemaha County include the City of Auburn, the City of

Nemaha, Nemaha County RWD No. 1, Nemaha County RWD No. 2, and the City of Peru. The

Village of Brownville no longer uses its own supply wells, but is connected to Nemaha County

RWD No. 1 (NPPD, 2008a). The Auburn Board of Public Works operates the Auburn Municipal

Water System. Eleven wells can provide up to 1,728,000 gallons of water per day. The system

provides an average of 700,000 gallons of water per day and can meet a peak demand of

1,181,700 gallons per day. The system has a storage capacity of 1,650,000 gallons (NDED and

NUREG-1437, Supplement 41 2-58 July 2010
Affected Environment

NPPD, 2008). The Nemaha municipal water system serves the Village of Nemaha and provides

an average of 17,500 gallons of water per day and can meet a peek demand of 30,000 gallons

per day. The system has a rated capacity of 216,000 gallons per day (NPPD, 2008a).

Nemaha County RWD No. 1 has a rated capacity of 100,000 gallons per day with a peak

demand of 90,000 gallons per day. The Nemaha County RWD No. 1 public water system serves

rural Nemaha County including the Village of Brownville. Nemaha County RWD No. 2 has an

average service demand of 206,300 gallons per day. The storage capacity is reported to be

230,000 gallons (NPPD, 2008a).

The Peru Municipal Water System serves the municipality of Peru in Nemaha County. The Peru

system has a rated capacity of 576,000 gallons per day with an average of 83,000 gallons and a

peak demand of 113,500 gallons per day (NPPD, 2008a).

Nebraska City Utilities provides water to the residents of Nebraska City in Otoe County. This

water system has a rated capacity of 6,300,000 gallons per day with an average of 2,500,000

gallons and a peak demand of 3,500,000 gallons per day (Great Plains Energy, 2009).

Falls City provides water to approximately 4,800 residents in Richardson County. The water

system has a rated capacity of 2,160,000 gallons per day with an average of 690,000 gallons

and a peak demand of 1,528,000 gallons per day (Great Plains Energy, 2009).

Richardson County RWD No. 1 and the Village of Shubert have community water systems

within 10 mi of CNS. Richardson County RWD No. 1 system has a capacity of 230,000 gallons

per day with an average demand of 100,000 gallons per day. The Village of Shubert operates a

municipal water system with a capacity of 204,000 gallons per day, with an average daily

demand of 22,800 gallons (NPPD, 2008a).

Almost all potable water use within Atchison County is from ground water supplied from wells,

with the exception of Westboro, Missouri, which purchases water from a surface water source.

The Rock Port Municipal Water System on average supplies approximately 300,000 gallons per

day with a system capacity of approximately 720,000 gallons per day (MDNR, 2008).

July 2010 2-59 NUREG-1437, Supplement 41
Affected Environment

Table 2.2.8.2-1. Public Water Supply Systems (thousand gallons per day)

Average Daily Population

Water Supplier(l) Water Source(a) Demand SystemCapacity Served(a)

Nemaha County, Nebraska

City of Auburn GW 1,182 1,728 3,217

Village of Nemaha GW 30 216 188

City of Peru GW 114 576 923

Nemaha County RWD No. 1 GW 90 100 800

Nemaha County RWD No. 2 GW 206 230 1,315

Otoe County, Nebraska

City of Nebraska City GW 2,500 6,300 7,192

Richardson County, Nebraska

City of Falls City GW 690 2,160 4,761

Richardson County RWD No. 1 GW 100 230 805

Village of Shubert GW 23 204 240

Atchison County, Missouri

Fairfax GW 185 308 645

Public Water System District No. 1 GW 171 1,310 831

of Atchison County

City of Rock Port GW 300 720 726

Tarkio Board of Public Works GW 225 756 1,957

Westboro SW 20 75 160

GW = ground water; SW = surface water; RWD = rural water district

(a) EPA, 2009b

Source: EPA, 2009b; NDED and NPPD, 2008; NPPD, 2008a; Great Plains Energy, 2009; MDNR, 2008

Education

The CNS is located in the Auburn Public School District, Nemaha County, which has an

enrollment of approximately 882 students in the 2008-2009 school year (NDE, 2009). Nemaha

County has two public school districts with over 1,100 enrolled students (NDE, 2009). Otoe and

Richardson counties have four school districts each (NDE, 2008). Total enrollment in Otoe and

Richardson County schools in the 2008-2009 school years was approximately 2,900 and 1,600

students, respectively (NDE, 2009).

Transportation

Several highways serve as transportation corridors within Nemaha and Atchison counties. The

primary highways in Nemaha County include U.S. Highways 75 and 136 and Nebraska State

Highways 62, 67, and 105. Access to the site is by Nemaha County Road 648A Avenue located

on the west side of the CNS property. County Road 648A Avenue intersects U.S. Highway 136

NUREG-1437, Supplement 41 2-60 July 2010
Affected Environment

which runs east to west, north of CNS in Brownville, Nebraska. State Highway 67 traverses

Nemaha County north to south to the west of CNS. U.S. Highway 75 bisects Nemaha County

running north to south. Plant workers living east and west of CNS travel on U.S. Highway 136 to

Nemaha County Road 648A Avenue to the site access road, and workers living north and south

travel on U.S. Highway 75 and Nebraska State Highway 67 to U.S. Highway 136.

The primary highways in Atchison County, Missouri, on the east side of the Missouri River

include Interstate 29 (1-29), U.S. Highways 136, 59, and 275; Missouri State Highways 46 and

111; and County Roads B, M, and T. 1-29 runs north to south through Atchison County roughly

parallel to the river between Council Bluffs, Iowa northeast of CNS and St. Joseph, Missouri,

southeast of CNS. CNS employees who reside in Missouri can access the site by using either

U.S. Highways 136 or 159, which cross the Missouri River in Brownville and Rulo, Nebraska (in

Richardson County), respectively. U.S. Highway 136 bisects Atchison County east to west in

Missouri, similar to Nemaha County on the west side of the river. Atchison County is also

bisected by U.S. Highway 59 which runs north to south through the central portion of the county.

Primary highways in Richardson County include U.S. Highways 73, 75, and 159 and State

Highways 8, 62, 67, and 105. U.S. Highway 75 runs north and south through both Nemaha and

Richardson counties. U.S. Highway 159 crosses the river downstream of CNS in Rulo,

Nebraska, from Holt County, Missouri.

The primary highways in Otoe County include U.S. Highways 50 and 75 and Nebraska State

Highways 2, 43, 66A, 67, and 128. Otoe County is bisected north to south by U.S. Highway 50

and Nebraska State Highway 2. Access to Otoe County directly from CNS is primarily from

Nebraska State Highway 67 and U.S. Highway 75.

Table 2.2.8.2-2 lists commuting routes to CNS and average annual daily traffic (AADT) volume

values. The AADT values represent traffic volumes for a 24-hour period factored by both day of

the week and month of the year.

July 2010 2-61 NUREG-1437, Supplement 41
Affected Environment

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

2006 Average Annual Daily Traffic Count

Roadway and Location AADT (a)

U.S. Highway 136 (between State Highway 67 and 2,905

Brownville, NE)

U.S. Highway 136 (between Brownville, NE and Missouri 2,615

River)

U.S. Highway 136 (between Interstate 29 and the Missouri 2,487

River in Missouri)

U.S. Highway 136 at Rock Port, MO 3,194

U.S. Highway 136 (between Auburn, NE and State Highway 3,205

67)

State Highway 67 (between Nemaha, NE and Brownville, NE 960

State Highway 67 at Nemaha, NE 770

State Highway 67 south of CNS 625

State Highway 67 at Peru, NE 1,025

U.S. Highway 75 (between State Highway 67 and U.S. 5,220

Highway 136, Auburn, NE)

U.S. Highway 75 (near Julian, NE) 4,640

U.S. Highway 75 (south of Nebraska City, NE) 5,585

Interstate 29 north of U.S. Highway 136 in Missouri 10,325

Interstate 29 south of U.S. Highway 136 in Missouri 11,832

Source: NDOR, 2007; MOBOT, 2007

(a) All AADTs represent traffic volume during the average 24-hour day during 2006.

U.S. = United States

2.2.8.3 Offsite Land Use

Offsite land use conditions in Nemaha County, Otoe County, Richardson County, and Atchinson

County are described in this section. In addition to property taxes, Nemaha and other counties

in the vicinity of CNS receive revenue from sales taxes and fees paid by NPPD and its

employees residing in the region. Changes in the number of workers at CNS and tax payments

to local jurisdictions could affect land use conditions in these counties.

CNS is located in eastern Nemaha County. Otoe, Richardson, and Atchison counties are

located along the Missouri River, north, south, and east of Nemaha County, respectively. The

four-county area near CNS is rural and largely unincorporated. Less than half of the population

in the four-county area lives in incorporated towns and villages. Most of the land in the

four-county area is in agricultural use or is forest or open land. Only a small percentage of the

land has been developed for residential, commercial, or industrial purposes. Forested areas are

generally limited to narrow strips of land along streams and rivers and steep, hilly areas

unsuitable for agriculture.

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Affected Environment

Nemaha, Richardson, and Atchison counties have seen a steady decline in population over the

past 50 years as residents leave farms to seek employment in larger cities and towns. Most

towns and villages located within a 50-mi radius of CNS are small and primarily support

agricultural communities. The closest communities to CNS are the Village of Brownville, located

approximately 2 mi northwest of CNS, and the town of Nemaha to the south. Industrial

developments in the four-county area are located in the larger communities of Auburn and

Nebraska City, Nebraska, and Marysville, Missouri.

Nemaha County occupies approximately 409 mi 2 (262,000 ac) (USCB, 2009). Approximately

213,000 ac or 81 percent of the land in Nemaha County was used for agriculturally related

activities in 2007. There were 449 farms, with most of the agricultural land devoted to cropland

(80 percent) and pasture (12 percent) (USDA, 2009). Nemaha County does not have

county-wide zoning regulations, although the city of Auburn has local zoning regulations

(NPPD, 2008a).

Otoe County occupies roughly 616 mi2 (394,000 ac) (USCB, 2009). The largest category of land

use, approximately 322,000 ac or 82 percent, is devoted to agriculture in Otoe County, with 804

farms in 2007. Approximately 80 percent of the agricultural land is in cropland and

approximately 11 percent pasture (USDA, 2009). Otoe County has county-wide zoning

regulations to manage future growth and development in the county.

Richardson County occupies roughly 553 mi 2 (354,000 ac) (USCB, 2009). The largest category

of land use, approximately 279,000 ac or 79 percent, is devoted to agriculture in Richardson

County, with 707 farms in 2007. Approximately 75 percent of the agricultural land is cropland

and approximately 14 percent is pasture (USDA, 2009). Richardson County does not have

county-wide zoning regulations, although the City of Falls city has local zoning regulations

(NPPD, 2008a).

Atchison County, Missouri occupies approximately 545 mi 2 (349,000 ac) (USCB, 2009).

Approximately 87 percent of Atchison County land is used for agricultural purposes. In 2007, the

county had 501 farms on approximately 304,000 ac. Major agricultural uses consist of croplands

(87 percent) and 6 percent pasture (USDA, 2009). Atchison County currently does not have

county-wide zoning regulations to manage future growth and development (NPPD, 2008a).

No significant change in land use is anticipated for the future in these four counties. Land use

trends reflect a slow, but steady overall decline in population in the region. Limited potential

commercial and urban development occurs in the small urban areas where public services and

utilities are available. No significant changes in future agricultural acreage, farm size, and land

uses are anticipated for the four-county region near CNS.

2.2.8.4 Visual Aesthetics and Noise

CNS can be seen from the river, but is partly shielded by vegetation along the river.

Predominant features are the reactor building, which is approximately 290 ft tall, the elevated

release point (325 ft), and meteorological tower (328.8 ft). The turbine building and reactor

containment structures dominate the landscape of the site. The 239 undeveloped acres of the

CNS site on the Missouri (east) side of the river provides a wooded view from the river.

Noise from nuclear plant operations can be detected offsite. Sources of noise at CNS include

the turbines and large pump motors. Given the industrial nature of the station, noise emissions

from the station are generally nothing more than an intermittent minor nuisance. The EPA uses

the 55 decibels adjusted (dBA) level as a threshold level to protect against excess noise during

July 2010 2-63 NUREG-1437, Supplement 41
Affected Environment

outdoor activities (EPA, 1974). However, according to the EPA this threshold does "not

constitute a standard, specification, or regulation," but was intended to provide a basis for State

and local governments establishing noise standards.

2.2.8.5 Demography

According to the 2000 Census, approximately 18,318 people lived within 20 mi of CNS, which

equates to a population density of 15 persons per mi 2 (NPPD, 2008a). This density translates to

Category 1, most sparse (less than 40 persons per mi 2 and no community with 25,000 or more

persons within 20 mi). Approximately 160,211 people live within 50 mi of CNS (NPPD, 2008a).

This equates to a population density of 20 persons per mi 2. Applying the Generic Environmental

Impact Statement for License Renewal of Nuclear Plants (GELS), NUREG-1437, proximity

measures, CNS is classified as proximity Category 1 (no city with 100,000 or more persons and

less than 50 persons per mi 2 within 50 mi). Therefore, according to the sparseness and

proximity matrix presented in the GELS, CNS rankings of sparseness Category 1 and proximity

Category 1 result in the conclusion that CNS is located in a low population area.

Table 2.2.8.5-1 shows population projections and growth rates from 1970 to 2050 in Nemaha,

Otoe, and Richardson counties, Nebraska, and Atchison County, Missouri. The growth rate in

Nemaha County showed a decrease of 5.1 percent for the period of 1990 to 2000. County

populations are expected to continue to decline in Nemaha, Richardson, and Atchison counties

in the next decades, although Otoe County's population is expected to increase through 2050.

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

Counties, Nebraska, and Atchison County, Missouri, from 1970 to 2000 and Projected for

2007 to 2050

Nemaha, NE Otoe, NE Richardson, NE Atchison, MO

Percent Percent Percent Percent

Year Population Growth(a) Population Growth(a) Population Growth(a) Population Growth(a)

1970 8,976 - 15,576 - 12,277 - 9,240 -

1980 8,367 -6.8 15,183 -2.5 11,315 -7.8 8,605 -6.9

1990 7,980 -4.6 14,252 -6.1 9,937 -12.2 7,457 -13.3

2000 7,576 -5.1 15,396 8.0 9,531 -4.1 6,430 -13.8

2007 7,039 -7.1 15,647 1.6 8,351 -12.4 6,108 -5.0

2010 6,767 -10.7 15,704 2.0 8,408 -11.8 5,927 -7.8

2020 6,456 -4.6 16,399 4.4 7,892 -6.1 5,559 -6.2

2030 6,033 -6.6 17,414 6.2 7,398 -6.3 5,280 -5.0

2040 5,685 -5.8 18,216 4.6 6,889 -6.9 4,942 -6.4

2050 5,318 -6.5 19,071 4.7 6,384 -7.3 4,618 -6.5

- = No data available.

(a) Percent growth rate is calculated over the previous decade.

Sources: Population data for 1970 through estimated population data for 2006 (USCB, 2009); population projections

for 2010-2030 by Bureau of Business Research (BBR) (2008), University of Nebraska-Lincoln, Nebraska Population

Projections and Missouri State Demographer, Office of Administration, No Date; population projections for 2040 and

2050 (calculated).

NUREG-1437, Supplement 41 2-64 July 2010
Affected Environment

Demogqraphic Profile

The 2000 and 2006 (estimate) demographic profiles of the four-county ROI population are

presented in Tables 2.2.8.5-2 and 2.2.8.5-3. In 2000, minorities (race and ethnicity combined)

comprised 3.8 percent of the total four-county population. The minority population is composed

of Hispanic or Latino and American Indian residents.

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

Four-County Socioeconomic Region of Influence in 2000

Nemaha, NE Otoe, NE Richardson, NE Atchison, MO ROI

Total Population 7,576 15,396 9,531 6,430 38,933

Race (percent of total population, Not-Hispanic or Latino)

White 97.1 96.3 95.1 96.6 96.2

Black or African American 0.4 0.2 0.2 2.1 0.5

American Indian and Alaska

Native 0.2 0.2 2.1 0.2 0.7

Asian 0.6 0.2 0.1 0.1 0.3

Native Hawaiian and Other

Pacific Islander 0.0 0.0 0.0 0.0 0.0

Some other race 0.0 0.0 0.0 0.0 0.0

Two or more races 0.6 0.6 1.4 0.3 0.7

Ethnicity

Hispanic or Latino 76 377 100 43 596

Percent of total population 1.0 2.4 1.0 0.7 1.5

Minority Population (including Hispanic or Latino ethnicity)

Total minority population 218 574 469 219 1,480

Percent minority 2.9 3.7 4.9 3.4 3.8

Source: USCB, 2009

According to the USCB's 2007 estimates published in 2009, minority populations in the

four-county region were estimated to have increased by over 500 persons and comprised

5.4 percent of the total four county population (see Table 2.2.8.5-3). Most of this increase was

due to an estimated influx of Hispanic or Latinos (over 320 persons), an increase in population

of over 55 percent from 2000. This was the largest percentage increase of any minority

population and a 1 percent increase in Hispanic or Latino population when compared to the total

four-county population. The next highest percentage increase in minority population was Asian,

an increase of over 51 percent from 2000. However, this resulted in only a very slight increase

in population as a percentage of the total four-county population.

July 2010 2-65 NUREG-1437, Supplement 41
Affected Environment

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

Four-County Socioeconomic Region of Influence in 2007, Estimated

Region of

Nemaha, NE Otoe, NE Richardson, NE Atchison, MO Influence

Total Population 7,039 15,647 8,351 6,108 37,145

Race (percent of total population, not Hispanic or Latino)

White 95.9 94.1 93.9 95.6 94.6

Black or African American 0.6 0.5 0.3 2.3 0.7

American Indian and Alaska

Native 0.3 0.4 2.6 0.3 0.9

Asian 0.8 0.3 0.5 0.3 0.4

Native Hawaiian and Other

Pacific Islander 0.0 0.0 0.0 0.0 0.0

Some other race .....

Two or more races 0.6 0.8 1.4 0.3 0.8

Ethnicity

Hispanic or Latino 126 612 111 73 922

Percent of total population 1.8 3.9 1.3 1.2 2.5

Minority Population (including Hispanic or Latino ethnicity)

Total minority population 288 930 506 269 1,993

Percent minority 4.1 5.9 6.1 4.4 5.4

* Some other race was eliminated from the Census estimate.

Source: USCB, 2009

Transient Population

Within 50 mi (80 km) of the CNS, colleges and recreational opportunities attract daily and

seasonal visitors who create demand for temporary housing and services. In 2009, there were

approximately 8,018 students attending colleges and universities within 50 mi (80 km) of the

CNS (IES, 2009).

In 2000 in Nemaha County, 1.6 percent of all housing units are considered temporary housing

for seasonal, recreational, or occasional use. By comparison, seasonal housing accounted for

0.6 percent, 1.3 percent, and 1.6 percent of total housing units in Otoe and Richardson counties

and Nebraska, respectively (USCB, 2009). Seasonal housing accounted for 1.2 percent and

2.7 percent of total housing units in Atchison County and Missouri, respectively (USCB, 2009).

Table 2.2.8.5-4 provides information on seasonal housing for the 24 counties located all or

partly within 50 mi of the CNS.

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Affected Environment

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

Nuclear Station

Vacant housing units: for seasonal,

County(a) Housing Units recreational, or occasional use Percent

Iowa 1,232,511 16,472 1.3

Fremont 3,514 56 1.6

Mills 5,671 64 1.1

Montgomery 5,399 38 0.7

Page 7,302 47 0.6

Taylor 3,199 19 0.6

County Subtotal 25,085 224 0.9 (avg.)

Kansas 1,131,200 9,639 0.9

Atchison 6,818 47 0.7

Brown 4,815 36 0.7

Doniphan 3,489 28 0.8

Jackson 5,094 42 0.8

Marshall 4,999 46 0.9

Nemaha 4,340 35 0.8

County Subtotal 29,555 234 0.8 (avg.)

Missouri 2,442,017 66,053 2.7

Andrew 6,662 58 0.9

Atchison 3,103 38 1.2

Holt 2,931 391 13.3

Nodaway 8,909 60 0.7

County Subtotal 21,605 547 4.0 (avg.)

Nebraska 722,668 11,912 1.6

Cass 10,179 541 5.3

Gage 10,030 56 0.6

Johnson 2,116 14 0.7

Lancaster 104,217 303 0.3

Nemaha 3,439 56 1.6

Otoe *6,567 37 0.6

Pawnee 1,587 78 4.9

Richardson 4,560 59 1.3

Sarpy 44,981 211 0.5

County Subtotal 187,676 1,355 1.7 (avg.)

County Total 263,921 2,360 1.2 (avg.)

Source: USCB, 2009

(a) Counties within 50 mi of CNS that are totally or partially located within the 50-mi radius

avg. = percent average for counties within the CNS 50-in radius and excludes State percentage

July 2010 2-67 NUREG-1 437, Supplement 41
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Miqrant Farm Workers

Migrant farm workers are individuals whose employment requires travel to harvest agricultural

crops. These workers may or may not have a permanent residence. Some migrant workers

follow the harvesting of crops, particularly fruit, throughout rural areas of the United States.

Others may be permanent residents near CNS who travel from farm to farm harvesting crops.

Migrant workers may be members of minority or low-income populations. Because they travel

and can spend a significant amount of time in an area without being actual residents, migrant

workers may be unavailable for counting by census takers. If uncounted, these workers would

be "underrepresented" in USCB minority and low-income population counts.

Information on migrant farm and temporary labor was collected in the 2007 Census of

Agriculture. Table 2.2.8.5-5 provides information on migrant farm workers and temporary farm

labor (less than 150 days) within 50 mi of CNS. According to the 2007 Census of Agriculture,

approximately 7,000 farm workers were hired to work for less than 150 days and were

employed on 3,300 farms within 50 mi of CNS. The county with the largest number of temporary

farm workers (774 workers on 280 farms) was Lancaster County, Nebraska (USDA, 2009).

In the 2007 Census of Agriculture, farm operators were asked for the first time whether or not

any hired migrant workers, defined as a farm worker whose employment required travel that

prevented the migrant worker from returning to their permanent place of residence the same

day. A total of 87 farms in the 50-mi radius of CNS reported hiring migrant workers in the 2007

Census of Agriculture. Nodaway County, Missouri, and Lancaster County, Nebraska, reported

the most farms (18 and 17, respectively) with hired migrant workers, followed by Nemaha

County, Nebraska , with 10 farms (USDA, 2009).

According to the 2007 Census of Agriculture estimates, 195 temporary farm laborers (those

working fewer than 150 days per year) were employed on 84 farms in Nemaha County, and 311

and 323 temporary farm workers were employed on 145 and 143 farms in Otoe and Richardson

counties, respectively (USDA, 2009). Atchison County, Missouri, had 226 temporary farm

workers employed on 99 farms (USDA, 2009).

NUREG-1437, Supplement 41 2-68 July 2010
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Table 2.2.8.5-5. Migrant Farm Workers and Temporary Farm Labor in Counties Located

within 50 Miles of the Cooper Nuclear Station

Number of Number of farms Number of farm Number of farms

farms with hired hiring workers for workers working for reporting migrant

County(a) farm labor(b) less than 150 days(b) less than 150 days(b) farm labor(b)

Iowa 23,287 19,204 50,266 123

Fremont 126 95 247 2

Mills 91 70 NA 0

Montgomery 118 100 187 0

Page 189 158 276 0

Taylor 134 103 259 1

County Subtotal 658 526 969 3

Kansas 14,437 11,558 30,682 193

Atchison 115 105 231 0

Brown 171 142 333 3

Doniphan 130 108 211 0

Jackson 145 128 319 2

Marshall 246 209 498 3

Nemaha 289 250 584 10

County Subtotal 1,096 942 2,176 18

Missouri 18,263 15,052 33,424 745

Andrew 134 113 258 2

Atchison 134 99 226 2

Holt 136 105 214 1

Nodaway 308 251 472 18

County Subtotal 712 568 1,170 23

Nebraska 14,603 11,261 29,583 468

Cass 148 119 273 4

Gage 322 272 585 7

Johnson 120 105 NA 5

Lancaster 310 280 774 17

Nemaha 107 84 195 3

Otoe 175 145 311 2

Pawnee 91 83 NA 0

Richardson 164 143 323 3

Sarpy 87 69 218 2

County Subtotal 1,524 1,300 2,679 43

County Total 3,990 3,336 6,994 87

Source: 2007 Census of Agriculture - County Data (USDA, 2009)

(a) Counties within 50 mi of CNS that are totally or partially located within the 50-mi radius

(b) Table 7. Hired Farm Labor - Workers and Payroll: 2007

July 2010 2-69 NUREG-1437, Supplement 41
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2.2.8.6 Economy

This section contains a discussion of the economy, including employment and income,

unemployment, and taxes.

Employment and Income

Between 2000 and 2007, the civilian labor force in Nemaha County decreased 9.4 percent from

3,931 to 3,560. During the same time period, the civilian labor force in Otoe County grew by

13 percent. By 2007, the civilian labor force in Richardson and Atchison counties decreased by

6.3 and 2.4 percent, respectively (USCB, 2009).

In 2000, educational, health, and social services represented the largest sector of employment

in the four-county region followed by manufacturing. The educational, health, and social

services sector employed the most people in Nemaha County followed by transportation,

warehousing, and utilities sectors. A list of some of the major employers in Nemaha County is

provided in Table 2.2.8.6-1. As shown in the table, the largest employer in Nemaha County is

CNS.

Table 2.2.8.6-1. Major Employers in Nemaha County

Firm Number of Employees

Cooper Nuclear Station 750

Armstrong Cabinets 162

Peru State College 160

Auburn Public Schools 142

Nemaha County Good Samaritan Home 75

Magnolia Metals, Inc. 65

Nemaha County Hospital 65

Nemaha County Government 48

Johnson-Brock Public Schools 44

Source: NDE, 2009 and NPPD, 2009

I Estimated income information for the CNS region of influence is presented in Table 2.2.8.6-2.

According to the USCB's 2007 estimates, median household income averages in Nemaha,

Otoe, Richardson, and Atchison counties were below their respective State median household

income averages. In 1999, per capita income in the four counties was also below both State

averages. In 2007, an estimated 13.3 and 13.4 percent of the county populations in Nemaha

and Richardson counties were living below the official poverty level, while the percentage for the

State of Nebraska as a whole was 11.1 percent. Conversely, Otoe County was estimated to

have the smallest percentage of persons living in poverty (9.4 percent). In Atchison County, an

estimated 14 percent of the county population was living below the official poverty level, while

the percentage for the State of Missouri as a whole was 13.3 percent.

NUREG-1437, Supplement 41 2-70 July 2010
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Table 2.2.8.6-2. Estimated Income Information for the Cooper Nuclear Station Region of

Influence in 2007

Nemaha Otoe Richardson Nebraska Atchison Missouri

Median household income (dollars) 41,024 45,018 36,092 47,072 38,114 45,012

Per capita income in 1999 (dollars) 17,004 17,752 16,460 19,613 16,956 19,936

Percent of individuals living below

the poverty level 13.3 9.4 13.4 11.1 14.0 13.3

Source: USCB 2009

Unemployment

According to the USCB's 2007 estimates, the unemployment rates in Nemaha, Otoe, and

Richardson counties were 3.9, 3, and 4 percent, respectively, which was slightly lower than the

unemployment rate of 4.8 percent for the State of Nebraska (USCB, 2009). The unemployment

rate in Atchison County was 4.3 percent, which was much lower than the 6.5 percent for the

State of Missouri (USCB, 2009).

Taxes

As a not-for-profit public corporation and political subdivision of the State of Nebraska, NPPD is

exempt from paying income or property taxes. Instead, in lieu of tax, other payments are made

to State, county, and local governments in which NPPD provides retail electric power.

According to the Nebraska State Constitution Article VIII, Section 11:

Every public corporation and political subdivision organized primarily to provide

electricity or irrigation and electricity shall annually make the same payments in

lieu of taxes as it made in 1957, which payments shall be allocated in the same

proportion to the same public bodies or their successors as they were in 1957.

The legislature may require each such public corporation to pay to the treasurer

of any county in which may be located any incorporated city or village, within the

limits of which such public corporation sells electricity at retail, a sum equivalent

to five (5) per cent of the annual gross revenue of such public corporation derived

from retail sales of electricity within such city or village, less an amount

equivalent to the 1957 payments in lieu of taxes made by such public corporation

with respect to property or operations in any such city or village. The payments in

lieu of taxes as made in 1957, together with any payments made as authorized in

this section shall be in lieu of all other taxes, payments in lieu of taxes, franchise

payments, occupation and excise taxes, but shall not be in lieu of motor vehicle

licenses and wheel taxes, permit fees, gasoline tax and other such excise taxes

or general sales taxes levied against the public generally.

So much of such five percent as is in excess of an amount equivalent to the

amount paid by such public corporation in lieu of taxes in 1957 shall be

distributed in each year to the city or village, the school districts located in such

city or village, the county in which such city or village is located, and the State of

Nebraska, in the proportion that their respective property tax mill levies in each

such year bear to the total of such mill levies (Neb. Const. art. VIII, sec. 11

(1958); Adopted 1958).

July 2010 2-71 NUREG-1437, Supplement 41
Affected Environment

NPPD is Nebraska's largest electric utility, with a chartered territory including all or parts of 91 of

Nebraska's 93 counties. NPPD pays monies in lieu of property taxes to the counties in which it

provides retail electric power. As part of NPPD's generation capacity, a portion of the in lieu of

tax payments and payments to retail communities may be attributed to CNS.

NPPD paid approximately $6.6 million in 2006 and $7 million in 2007 in lieu of taxes to the

I 91 counties in which NPPD is chartered (NPPD, 2008c). Each county receives 5 percent of the

total gross revenues NPPD receives from electricity sales within the county. The actual in lieu of

tax allocation attributable to CNS is not recorded by NPPD. NPPD's power generation units

provide power to the grid, and county retail sales are then from the grid. However, CNS

represents approximately 24 percent of NPPD's power generation capacity. Based on

I 24 percent generation, the payments in lieu of tax that could be attributed to CNS were

approximately $1.6 million in 2006 and $1.7 million in 2007 (see Table 2.2.8.6-3).

NPPD also pays back 12 percent of the total gross revenues received from retail communities,

which amounted to approximately $17.5 million in 2006 and $18.3 million in 2007 (NPPD,

2008c). Based on 24 percent of NPPD's total generation capacity, CNS's contribution to retail

communities was $4.2 million in 2006 and $4.4 million in 2007 (see Table 2.2.8.6-3).

NPPD pays sales/use taxes on purchases made by CNS. As shown in Table 2.2.8.6-3,

CNS paid $943,020 in sales/use taxes in 2007 and $1,353,435 in 2006. City sales taxes are

I paid to the town of Auburn, Nebraska. NPPD also pays a special assessment for the

Brownville-Nemaha Levee District that is paid to the county treasurer (NPPD, 2008c). As shown

in Table 2.2.8.6-3, the total taxes and payments to the State, counties, and retail communities

attributable to CNS were approximately $7.2 million in 2006 and $7.1 million in 2007.

Table 2.2.8.6-3. Cooper Nuclear Station Estimated Tax Distribution, 2005-2007

Tax 2005 2006 2007

Nebraska State Sales/Use Tax $1,082,780 $1,353,435 $943,020

City of Auburn, NE Sales/Use Tax 240 455 40

Special Assessment on Brownville-Nemaha Levee Paid to 5,090 5,090 5,090

Nemaha County

Nemaha County, NE Real Estate Taxes 10,865 10,980 11,140

Atchison County, MO Real Estate Taxes 145 145 140

Nebraska in Lieu of Taxes to Counties with NPPD Retail 1,607,135 1,595,752 1,687,056

Electric Sales Attributed to the CNS

Payments to Retail Communities Attributed to CNS 4,267,771 4,233,381 4,436,089

Total $6,976,031 $7,201,244 $7,084,582

Source: NPPD, 2008c

NUREG-1437, Supplement 41 2-72 July 2010
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2.2.9 Historic and Archaeological Resources

This section discusses the cultural background and the known historic and archaeological

resources at the CNS site and in the surrounding area.

2.2.9.1 Cultural Background

CNS is located on a 1,120 ac tract in the floodplain on the west bank of the Missouri River in

Nemaha County, Nebraska. To the west of the site are bluffs. CNS also owns an additional

239 ac on the eastern side of the river in Atchison County, Missouri. The eastern bank is a

densely forested area that periodically floods, with bluffs that run parallel to the river. The region

around the CNS site contains prehistoric and historic Native American and Euro-American

cultural resources. Twelve properties in Nemaha County are listed in the National Register of

Historic Places (NRHP) (NPS, 2009). The nearest NRHP property is the Captain Meriwether

Lewis Dredge. Seven NRHP properties are located in Atchison County.

2.2.9.2 Prehistoric Periods

First Arrivals

CNS is situated in the Missouri River Valley on the eastern edge of the Central Great Plains and

northwest edge of the Missouri Prairie-Timberlands. The first peoples began emigrating into the

region toward the end of the Pleistocene (pre-Clovis circa 11,500 years ago). There is a growing

body of evidence indicating that a "First Arrivals" archeological period (circa. 13,000 and 17,000

years ago) preceded the Paleo-lndian Period. A handful of sites in the Central Plains date

between about 13,000 and 17,000 years ago, however, most of these sites have limited

evidence of human occupation (Hofman, 1996). Acceptance of archeological remains older than

the long accepted Clovis Culture remains controversial (Hofman, 1996), (Holen, 1994).

Paleo-lndian Period

The Clovis Culture (circa 11,500 years ago) is the earliest dated and accepted evidence of

human habitation during the Paleo-lndian Period in the New World. The climate during the

Paleo-lndian Period was much cooler and wetter than today. The eastern edge of the Central

Plains was broad open grassland occupied by great herds of now extinct animals. Paleo-lndian

populations were highly mobile and left little evidence of their activities. Most Paleo-lndian sites

would have been short-term occupations (campsites). Paleo-lndian peoples subsisted on

hunted game and gathered plant material. Distinctive point styles and variations in other tool

types defined the Clovis, Folsom, Midland, and later Paleo-lndian groups (Hofman, 1996). To

date, no early sites have been identified in Nemaha or Atchison counties, but such resources

may exist as deeply buried deposits along relic terraces.

Archaic Period

During the Archaic Period, subsistence hunting and gathering underwent changes to adapt to

resource availability. As glaciers retreated northward and larger animals disappeared from the

region, humans adapted to modern plants and smaller game animals. The Dalton Culture

(circa 8,500 to 7,500 years ago) is generally identified as the late Paleo-lndian or Early Archaic

Period or as a transition between the two (O'Brien and Wood, 1995). The Archaic Period is

subdivided into the following periods: Early Archaic Logan Creek Complex (circa 7,500 to 6,000

years ago), Middle Archaic Jacomo Complex (circa 5,500 to 5,000 years ago) and Late Archaic

Nebo Hill Complex (circa 4,500 to 2,500 years ago). Early Archaic people did not appear to

establish permanent settlements, though there is evidence that some locations were used

July 2010 2-73 NUREG-1437, Supplement 41
Affected Environment

frequently. Archaic people collected, hunted, and gathered most of what they needed for

survival in their home territory with a wider range of tools.

Climatic conditions during the Archaic Period entered a warmer/dryer phase around 5,500 years

ago. Late Archaic cultures began to settle in the Missouri River Valley about 3,000 years ago.

Archaeological evidence indicates that larger, semi-permanent warm weather settlements were

established along the higher terraces, while winter encampments were located in upland areas

along small streams. Archaic sites identified in the CNS area typically consist of lithic scatters

with various dart points identified as "Archaic."

Woodland Period

The Woodland Period (circa 2,500 to 1,000 years ago) is defined by the introduction of

agriculture to augment subsistence hunting and gathering. The reliance on agriculture led to the

establishment of permanent settlements during this period. Other characteristics of Woodland

culture include increased population, emergence of social hierarchy, expanded interregional

trade, elaborate ceremonialism with stone-lined graves and burial mounds, and the introduction

of the bow and arrow.

During the middle Woodland Period (circa 2,000 to 1,500 years ago), indigenous groups began

increasing in population. Woodland peoples spread along valleys over the entire eastern half of

Nebraska, western part of Iowa, and parts of South Dakota and Kansas. These people were

forager-gardeners living in small villages along the higher valley terraces. Several Middle

Woodland sites have been identified in Nemaha and Atchison counties.

During the late Woodland Period (circa 1,500 to 1,100 years ago), larger middle Woodland

villages were abandoned in favor of smaller camps and individual home sites, generally in the

uplands away from the river bottoms. The number of burial mounds increased dramatically.

Most of the mounds were small and low with distinctive rock structures. Many mounds have

been lost to plowing, but rock structures around graves are commonly found on bottom terraces

and points on both sides of the river.

Plains Village Period

Around 1,000 years ago, most groups had established permanent villages. The Plains Village

peoples were farmers and bison hunters living in larger villages along the river terraces. Smaller

hamlets, hunting camps, and kill sites have also been recorded in the uplands. This culture

disappeared about 700 years ago for unknown reasons. Climatic conditions during this time

were becoming warmer and dryer, and drought may have forced people out of traditional

farming areas. Additionally, there was an influx of people coming onto the Plains from the

northeast and west that may have made living in the region untenable.

2.2.9.3 Historic Period

Historic Tribes and Fur Traders

The 18th and 19th centuries brought the first wave of Europeans to the east Central Plains

region. French, and later Spanish land claims inspired trade and exploration of the Missouri

River Valley. French fur traders were known to visit the area. Indian populations were

subsequently displaced.

Traffic along the Missouri River increased after the Louisiana Purchase in 1803. The Lewis and

Clark expedition of 1804 paved the way for subsequent U.S. military expeditions and the

NUREG-1437, Supplement 41 2-74 July 2010
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establishment of trading posts and missions. On July 13, 1804, the Lewis and Clark expedition

passed the remains of a trading post said to have been where Benet of St. Louis traded with the

Otoe and Pawnee for 2 years. Other American Indian groups that passed through the area

included the Omaha, Osage, Delaware, Pottawatomi, Sauk and Fox, Winnebago, and Miami.

On July 15, 1804, the Lewis and Clark party camped along a rise on the west side of a bend in

the river. There is some dispute about the actual location of the encampment. Nebraska

researchers place the camp on the Missouri side of the present river channel and Missouri

historians place the camp roughly where the CNS is located.

Historic accounts of the Lewis and Clark expedition describe a beautiful valley filled with grape

vines and wild cherries, which first attracted settlers to the area in the 1840s

(Plamondon, 2000). Settlement was gradual, but steadily spread along the eastern side of the

river (National Historical Company, 1882). The Kansas-Nebraska Act of 1854 created the

Nebraska Territory. Nemaha County. was established a year later (Heritage, 2004). Settlement

along the river increased in the 1850s with Brownville, Nebraska, being established as a major

steamboat port and shipping point. The towns of Nemaha, Brownville, and Peru prospered

along the bluffs above the Missouri River, and settlement of the interior away from the river

remained low until the Nebraska Railway Company reached the area in 1874 (Heritage, 2004).

An 1865 Government Land Office plat showed two farmsteads located on or near the area

occupied by CNS. By 1911, there were nine homesteads and a school.

The arrival of railroads spurred the development of the interior areas away from the river at the

expense of the towns located along the bluff tops. Brownville rapidly declined because of this.

The building of the Brownville Bridge in 1939 connected the two sides of the river but did little to

alleviate the town's economic downfall.

Construction of CNS began in 1968. Consumers Public Power District (CPPD) planned and

financed the construction and became NPPD on January 1, 1970 (NPPD, 2008a).

2.2.10 Historic and Archaeological Resources at the Cooper Nuclear Station Site

No prehistoric or historic sites listed or eligible for listing on the NRHP or the State historic

registers are located on the CNS site. Historic archaeological sites have been identified within a

6-mi radius of the site. A great deal of archaeological and historical research has been

conducted within both Nemaha County, Nebraska, and Atchison County, Missouri. The bluffs

along either side of the Missouri River and the higher terraces along the river valley bottom

lands were favored habitation sites for prehistoric and historic people.

Only one previous historical survey has been conducted on the CNS property. This survey

evaluated the eligibility of the William Dawson House located in the southwest corner of the

CNS site near the bluff for listing on the NRHP. The William Dawson House (Site # NHOO-69)

was recorded in Nebraska historic archives but was not included on the NRHP. The Dawson

House was torn down in 1970, shortly after it was recorded.

A formal survey of the entire CNS property has not been completed, however, a number of

archaeological surveys have been conducted in the surrounding area. In the 1930s, A.T. Hill

and Paul Cooper walked the bluffs along both sides of the river valley in search of Woodland

mound sites. The Whitten Archeological Site, Archeological Survey No. 25NH4, was excavated

along the bluffs north of the CNS site. Despite the fact that the mounds were reportedly leveled

by cultivation, excavations succeeded in locating two concentrations of human remains along

July 2010 2-75 NUREG-1437, Supplement 41
Affected Environment

with grave goods and other artifacts (Hill and Cooper, 1937). The Nebraska State Historical

Society Site Survey Form notes that, "... (two) skeletons were sent to U.S. National Museum in

accordance with our WPA (Works Progress Administration) contract." The note is dated June

21, 1944. It is unclear from the archaeological site description if the Whitten site extended onto

the CNS property.

In April 2007 and March 2008, NPPD contracted with Enercon Services, Inc. to conduct a

Phase 1A Literature Review and Archeological Sensitivity Assessment for the CNS site. The

55 ac occupied by CNS were heavily disturbed. The Enercon study identified two probable

prehistoric lithic scatters and three former historic home sites on the CNS site. The report also

noted the potential for additional prehistoric and historic resources to be found throughout the

area. Enercon also noted the potential for a camp site occupied by the Lewis and Clark

Expedition in 1804 being located on the CNS property. The exact location of this campsite

remains unknown.

2.3 RELATED FEDERAL AND STATE ACTIVITIES

The NRC staff reviewed the possibility that activities of other Federal agencies might impact the

renewal of the operating license for CNS. Any such activity could result in cumulative

environmental impacts and the possible need for a Federal agency to become a cooperating

agency in the preparation of the CNS SEIS.

The NRC has determined that there are no Federal projects that would make it desirable for

another Federal agency to become a cooperating agency in the preparation of the SEIS.

Federal lands, facilities, national wildlife refuges, forests, and parks within 50 mi of CNS are

listed below:

* Langdon Bend, 1 mi south-southeast (USACE)

* Derion Bend, 8 mi southeast (USACE)

0 Nishnabotna, 9 mi north-northwest (USACE)

0 Corning, 12 mi southeast (USACE)

0 Kansas Bend, 12 mi north-northwest (USACE)

* Thurnau, 15 mi southeast (USACE)

* Lower Hamburg Bend, 15 mi north-northwest (USACE)

* Hamburg Bend, 17 mi north-northwest (USACE)

* Rush Bottom Bend, 22 mi southeast (USACE)

* Sac and Fox Reservation, 23 mi south-southeast (U.S. Department of the

Interior, Bureau of Indian Affairs)

* Iowa Reservation, 26 mi south-southeast (U.S. Department of the Interior,

Bureau of Indian Affairs)

NUREG-1437, Supplement 41 2-76 July 2010
Affected Environment

* Squaw Creek National Wildlife Refuge, 28 mi southeast (USFWS)

a Copeland Bend, 29 mi north-northwest (USACE)

0 Auldon Bar, 36 mi north-northwest (USACE)

0 Noddleman Island, 39 mi north-northwest (USACE)

• Tobacco Island, 43 mi north-northwest (USACE)

The NRC is required under Section 102(2)(c) of the National Environmental Policy Act of 1969

(NEPA) to consult with and obtain the comments of any Federal agency that has jurisdiction by

law or special expertise with respect to any environmental impact involved. Federal Agency

consultation correspondence and comments on the SEIS are presented in Appendix E.

2.4 REFERENCES

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10 CFR Part 61. Code of Federal Regulations, Title 10, Energy, Part 61, "Licensing

Requirements for Land Disposal of Radioactive Waste."

10 CFR Part 71. Code of Federal Regulations, Title 10, Energy, Part 71, "Packaging and

Transportation of Radioactive Material."

40 CFR PART 190 Code of Federal Regulations, Title 40, Protecion of the Environment, Part

190 Environmental Radiation Protection Requirements for Normal Operations of Activities in the

Uranium Fuel Cycle, Final Environmental Statement.

40 C.F.R. PART 239. Code of Federal Regulations, Title 40, Protecion of the Environment, Part

239, Requirements for State Permit Program Determination of Adequacy.

Abell, R., Olson, D., et al. (Abell et al.) 2000. Freshwater Ecoregions of North America, Island

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Abell, R., et al. 2008. "Freshwater Ecoregions of the World: A New Map of Biogeographic Units

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Bailey, G. 2007. Personal communication with K. Shannon, Enercon Services, Nebraska Game'

and Park Commission, January 25, 2007, Lincoln, Nebraska, Agencywide Documents Access

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Barbour, M.T., J. Gerritsen, B.D. Snyder, and J.B. Stribling (Barbour et al.). 1999. Rapid

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Benedict, R.A., P.W. Freeman, and H.H. Genoways. 1996. "Chapter 11: Prairie LegaciesMammals," in F.B. Samson and F.L. Knopf (eds.), Prairie Conservation: Preserving North

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Black-footed Ferret Recovery Implementation Team. 2009. "Black-Footed Ferret Recovery

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Carter, S.R., K.R. Bazata, and D.L. Anderson (Carter et al.). 1982. "Chapter 7:

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(eds.), The Middle Missouri River: A Collection of Papers on the Biology with Special Reference

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Conestoga Rover and Associates (CRA). 2007. "Hydrogeologic Investigation Work Plan,"

Ground Water Protection Initiative, Cooper Nuclear Station, Brownsville, Nebraska.

Cornell University. 2008. Insect Conservation Biology. "Cicindela nevadica lincolniana, Salt

Creek Tiger Beetle." Available URL:

http://courses.cit.corne!1.edu/icb344/abstracts/salt-creek-tiqer-beetle.htm (accessed March 9,

2009).

Daily, G.C., S. Alexander, P.R. Ehrlich, L. Goulder, J. Lubchenco, P.A. Matson, H.A. Mooney,

S. Postel, S.H. Schneider, D. Tilman, and G.M. Woodwell (Daily et al.). 1997. "Ecosystem

services: Benefits supplied to human societies by natural ecosystems," Issues in Ecology 2:1-

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Defenders of Wildlife. 2009. "Black-Footed ferret (Mustela nigripes)." Available URL:

http://www.defenders.orq/wildlife and habitat/wildlife/black-footed ferret.php

(accessed March 9, 2009).

Dryer, M.P. and A.J. Sandvol. 1993. "Recovery plan for the pallid sturgeon, Scaphirhynchus

albus," U.S. Fish and Wildlife Service, Bismarck, ND, 55 pp.

Environmental Protection Agency (EPA). 1974. "Information on Levels of Environmental Noise

Requisite to Protect Public Health and Welfare with an Adequate Margin of Safety," Report

550/9-74-004, Washington, D.C., March 1974. Available URL:

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Spawning in the Missouri River in 2007," USGS Fact Sheet 2007-3053, July 2007.

NUREG-1437, Supplement 41 2-86 July 2010
Affected Environment

U.S. Geological Survey (USGS). 2008. Search USGS. September 2008. Available URL:

http://search.usqs.qov/ (accessed March 9, 2009).

U.S. Nuclear Regulatory Commission (NRC). 2003. Generic Environmental Impact Statement

for License Renewal of Nuclear Plants Supplement 12 Regarding Fort Calhoun Station,

NUREG-1437, Supplement 12, ADAMS Accession No. ML032230075.

Utah State University (USU) 2006. "Fact Sheet, Carex frankii Kunth." Available URL:

http://utc.usu.edu/factsheets/CarexFSF/Carex frankii.htm (accessed May 11, 2009).

University of Texas (UT). 2009. "Native Plant Database," Lady Bird Johnson Wildflower Center,

February 2009. Available URL: http://www.wildflower.org/plants/resuIt.php?id plant=PAGL17

(accessed May 11, 2009).

University of Wisconsin (UW). 2009. "Robert W. Freckmann Herbarium." Available URL:

http://wisplants.uwsp.edu/scripts/searchrhotographer.asp?photographer=Robert%20R.%20Kow

a (accessed April 21, 2009).

University of Wyoming (UWYO). 2002. "State Species Abstract, Wyoming Natural Diversity

Database, Dalea enneandra, Nine-Anther Prairie-Clover Fabaceae," January 2002. Available

URL: http://www.uwyo.edu!wVnddsupport/docs/Reports/SpeciesAbstracts/Dalea enneandra.pdf

(accessed May 6, 2009).

Wildhaber, M.L., A.J. DeLonay, D.M. Papoulias, D.L. Galat, R.B. Jacobson, D.G. Simpkins,

P.J. Braaten, C.E. Korschgen, and M.J. Mac. 2007. "A conceptual life-history model for pallid

and shovelnose sturgeon," U.S. Geological Survey Circular 1315, U.S. Geological Survey,

Reston, VA, 18 pp.

Wishart, D.J., ed. 2004. Encyclopedia of the Great Plains, University of Nebraska Press

July 2010 2-87 NUREG-1437, Supplement 41

3.0 ENVIRONMENTAL IMPACTS OF REFURBISHMENT

Environmental issues associated with refurbishment activities are discussed in the, Generic

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

Volumes 1 and 2 (NRC, 1996). The GElS includes a determination of whether or not the

analysis of the environmental issues can be applied to all plants and whether or not additional

mitigation measures are warranted. Issues are then assigned a Category 1 or a Category 2

designation. As set forth in the GELS, Category 1 issues are those that meet all of the following

criteria:

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

all plants, or for some issues, apply only to plants having a specific type of cooling

system or other specified plant or site characteristics.

(2) A single significance level (SMALL, MODERATE, or LARGE) has been assigned to the

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

high-level waste and spent fuel disposal).

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

analysis. It has been determined that additional plant-specific mitigation measures are

likely not to be sufficiently beneficial to warrant implementation.

For issues that meet the three Category 1 criteria, no additional plant-specific analysis is

required in this supplemental environmental impact statement (SEIS) unless new and significant

information is identified.

Category 2 issues are those that do not meet one or more of the criteria for Category 1,

therefore, an additional plant-specific review of these issues is required.

License renewal actions include refurbishment for the extended plant life. These actions may

have an impact on the environment that requires evaluation, depending on the type of action

and the plant-specific design. Environmental issues associated with refurbishment, which were

determined to be Category 1 issues, are listed in Table 3-1.

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Environmental Impacts of Refurbishment

Table 3-1. Category 1 Issues for Refurbishment Evaluation

ISSUE-10 CFR Part 51, Subpart A, Appendix B, Table B-1 GElS Section

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

Impacts of refurbishment on surface water quality 3.4.1

Impacts of refurbishment on surface water use 3.4.1

Aquatic Ecology (for all plants)

Refurbishment 3.5

Ground Water Use and Quality

Impacts of refurbishment on ground water use and quality 3.4.2

Land Use

Onsite land use 3.2

Human Health

Radiation exposures to the public during refurbishment 3.8.1

Occupational radiation exposures during refurbishment 3.8.2

Socioeconomics

Public services: public safety, social services, and tourism and recreation 3.7.4; 3.7.4.3; 3.7.4.4; 3.7.4.6

Aesthetic impacts (refurbishment) 3.7.8

Environmental issues related to refurbishment considered in the GElS that are inconclusive for

all plants, or for specific classes of plants, are Category 2 issues. These are listed in Table 3-2.

Table 3-2. Category 2 Issues for Refurbishment Evaluation

ISSUE-10 CFR Part 51, Subpart A, 10 CFR 51.53 (c)(3)(ii)

Appendix B, Table B-1 GElS Section Subparagraph

Terrestrial Resources

Refurbishment impacts 3.6 E

Threatened or Endangered Species (for all plants)

Threatened or endangered species 3.9 E

Air Quality

Air quality during refurbishment F

(nonattainment and maintenance areas)

Socioeconomics

Housing impacts 3.7.2 1

Public services: public utilities 3.7.4.5 1

Public services: education (refurbishment) 3.7.4.1 1

Offsite land use (refurbishment) 3.7.5

Public services, transportation 3.7.4.2 J

Historic and archaeological resources 3.7.7 K

Environmental Justice

Environmental justice(a) Not addressed Not addressed

(a) Guidance related to environmental justice was not in place at the time the U.S. Nuclear Regulatory

Commission (NRC) prepared the GElS and the associated revision to 10 CFR Part 51. If an applicant plans to

undertake refurbishment activities for license renewal, the applicant's environmental report (ER) and the NRC

staffs environmental impact statement must address environmental justice.

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The potential environmental effects of refurbishment actions are identified, and the analysis will

be summarized within this section, if such actions are planned. Nebraska Public Power District

(NPPD) indicated that it has performed an evaluation of systems, structures, and components

pursuant to Section 54.21 of Title 10 of the Code of Federal Regulations (10 CFR 54.21) to

identify the need to undertake any major refurbishment activities that are necessary to support

continued operation of CNS during the requested 20-year period of extended operation. Items

that are subject to aging and might require refurbishment to support continued operation during

the renewal period are listed in Table B.2 of the GElS.

The results of the evaluation of systems, structures, and components for CNS, as required by

10 CFR 54.21, do not identify the need to undertake any major refurbishment or replacement

actions associated with license renewal to support the continued operation of

CNS beyond the end of the existing operating license.

3.1 REFERENCES

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

Protection Regulations for Domestic Licensing and Related Regulatory Functions."

10 CFR Part 54. Code of Federal Regulations, Title 10, Energy, Part 54, "Requirements for

Renewal of Operating Licenses for Nuclear Power Plants."

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

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

Agencywide Documents Access and Management System (ADAMS) Accession Nos.

ML040690705 and ML040690738

July 2010 3-3 NUREG-1437, Supplement 41

4.0 ENVIRONMENTAL IMPACTS OF OPERATION

This chapter addresses potential environmental impacts related to the period of extended

operation of Cooper Nuclear Station (CNS). These impacts are grouped and presented

according to resource. Generic issues (Category 1) rely on the analysis provided in the Generic

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

(May 1996), prepared by the U.S. Nuclear Regulatory Commission (NRC, 1996) and are

discussed briefly. The NRC staff analyzed site-specific issues (Category 2) for CNS and

assigned them a significance level of SMALL, MODERATE, LARGE or not applicable to CNS

because of site characteristics or plant features. Section 1.4 of this report explains the criteria

for Category 1 and Category 2 issues and defines the impact designations of SMALL,

MODERATE, and LARGE.

4.1 LAND USE

Section 2.2.1 of this report describes the land use around CNS.

Table 4-1, "Land Use Issues," lists Category 1 issues (from Title 10 of the Code of Federal

Regulations (CFR) Part 51, Subpart A, Appendix B, Table B-1i), which are applicable to onsite

land use and power line right-of-way impacts during the renewal term. As stated in the GElS,

the impacts associated with the Category 1 issues were determined to be SMALL, and

site-specific mitigation measures would not be sufficiently beneficial to be warranted.

The NRC staff reviewed and evaluated the CNS environmental report (ER), scoping comments,

other available information, and visited CNS in search of new and significant information that

would change the conclusions presented in the GELS. No new and significant information was

identified during this review and evaluation. The staff did not identify any Category 2 issues for

land use. Therefore, it is expected that there would be no impacts related to the Category 1

issues during the renewal term beyond those discussed in the GELS.

Table 4-1. Land Use Issues

Issues GElS Section Category

Onsite land use 4.5.3 1

Power line right-of-way 4.5.3 1

4.2 AIR QUALITY

Section 2.2.2 of this report describes air quality in the vicinity of CNS. One Category 1 air quality

issue is applicable to CNS: air quality impacts of transmission lines. No Category 2 issues have

been identified for air quality. The NRC staff did not identify any new and significant information

during the review of NPPD's ER, the site audit, or during the scoping process. No major facility

construction or refurbishments are planned to occur during the license renewal period.

Therefore, there are no impacts related to this issue beyond those discussed in the GELS. For

these issues, the GElS concluded that the impacts are SMALL and site-specific mitigation

measures are not warranted.

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4.3 GROUND WATER

4.3.1 Generic Ground Water Issues

Section 2.2.3 of this report discusses ground water use and quality at CNS. The staff did not

identify any new and significant information in regard to Category 1 or generic ground water

issues during the review of the NPPD's ER, the site visit, or the scoping process. Therefore, no

impacts are related to these issues beyond those discussed in the GELS. For these issues, the

NRC staff in the GElS concludes that the impacts are SMALL and additional site-specific

mitigation measures are not warranted.

4.3.2 Ground Water Use Conflicts

The Category 2 ground water issue applicable to CNS is ground water use conflicts (potable

and service water, plants using greater than 100 gallons per minute (gpm)). CNS has two

potable water supply wells completed in the alluvial aquifer that have a combined pumping

capacity of 250 gpm. Normal operations require only one well to be pumped at a time, supplying

125 gpm. The water is chlorinated, distributed onsite, and operated with preventive

maintenance and cross connection or backflow prevention programs. The two drinking water

wells are scheduled to be replaced with two similar new wells in the near future (NPPD, 2008a).

A third alluvial aquifer well at CNS is used for fire protection training and has a capacity of

750 gpm. Two additional wells, River Wells A and B, are used to supply water for facility pump

seals. These wells each have a capacity of 150 gpm (NPPD, 2008a).

If all five existing production wells on site pumped at maximum capacity, the total pumping rate

would be 1,300 gpm, compared to the 636,000 gpm of total water usage. This scenario does not

occur, but represents the maximum impact possible on the alluvial aquifer. The aquifer is in

hydraulic contact with the Missouri River and most ground water pumped is induced from

surface water. The amount of ground water used is insignificant when compared to surface

water use. Ground water not consumed is discharged to the Missouri River or is spread on

nearby fields.

The National Pollutant Discharge Elimination System (NPDES) permit only provides one outfall

(#001) with a chlorine limit. CNS does not chlorinate/brominate any water used except for the

potable water supply system (250 gpm). Chlorine residuals from a potable system are

insignificant compared to flow in the river.

As part of a hydrogeologic investigation for the study of radionuclides in ground water and water

use in the area surrounding the station, NPPD searched the Nebraska Department of Natural

Resources (NDNR) water well database for all wells in Nemaha County. Three irrigation wells,

completed in the shallow unconsolidated aquifer, are located between 2 and 3 miles (mi)

southwest of CNS. Four farm wells within 1 mi of the station, all only 15 feet (ft) deep, produce a

limited amount of ground water. None of these wells are impacted by ground water pumping at

CNS because the station wells are screened in an unconfined aquifer and have limited radii of

influence. A search of wells by NPPD in Atchison County, MO, across the river from CNS,

identified no wells within 2 mi of the station. In addition, the Missouri River serves as a ground

water recharge and discharge boundary. Therefore, the NRC staff concludes the effect of

pumping the shallow aquifer at CNS would not likely be measurable on the Missouri side of the

river.

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Because of the limited radii of influence of CNS wells completed in the unconfined aquifer, no

public ground water supplies are close enough to CNS to be impacted by ground water use at

the station. There are no well-head protection areas or EPA designated sole source aquifers in

the vicinity of CNS (CRA, 2007). Therefore, the impact of ground water use by CNS is SMALL

and no mitigation measures are warranted.

4.4 SURFACE WATER

4.4.1 Generic Surface Water Issues

The following sections discuss the surface water quality issues applicable to CNS, which are

listed in Table 4-2. The staff did not identify any Category 2 issues related to surface water

issues in the GELS. In addition, the staff did not identify any new and significant information with

respect to the Category 1 issues below during the review of NPPD's ER, the site audit, or the

scoping process. Therefore, no impacts are related to these issues beyond those discussed in

the GELS. For these issues, the NRC staff in the GElS concludes that the impacts are SMALL,

and additional site-specific mitigation measures are not warranted.

Table 4-2. Category I Surface Water Issues

Issues GElS Section Category

Altered current patterns at intake and discharge structures 4.2.1.2.1 1

Temperature effects on sediment transport capacity 4.2.1.2.3 1

Scouring caused by discharged cooling water 4.2.1.2.3 1

Discharge of chlorine or other biocides 4.2.1.2.4 1

Discharge of sanitary wastes and minor chemical spills 4.2.1.2.4 1

Discharge of other metals in wastewater 4.2.1.2.4 1

Water use conflicts for plants with once-through cooling 4.2.1.3 1

systems

The following briefly describes the GElS conclusions for these issues:

Altered current patterns at intake and discharge structures. 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.

Temperature effects on sediment transport capacity. 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. 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.

Discharge of chlorine or other biocides. The effects are not a concern among

regulatory and resource agencies, and are not expected to be a problem during

the license renewal term.

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Discharge of sanitary wastes and minor chemical spills. Effects are readily

controlled through the NPDES permit. Periodic modifications are granted, if

needed, and are not expected to be a problem during the license renewal term.

Discharge of other metals in wastewater. These discharges have not been found

to be a problem at operating nuclear power plants and are permitted through the

NPDES system. They are not expected to be a problem during the license

renewal term.

Water use conflicts for plants with once through cooling systems. Continuing

operation of CNS depends on the availability of water from the Missouri River.

The volume of water available may be susceptible to droughts and to competing

water uses within the basin. In cases of extreme drought, these facilities may be

required to curtail operations if the volume of water available is not sufficient

(NRC 1996). As described in Section 2.0, the flow in the Missouri River is not

expected to decrease to the point cooling water restrictions would be imposed on

CNS, This remains a Category 1 issue with small impact.

For all of these Category 1 issues in Table 4-2, the NRC staff has not identified any new and

significant information during its review of the NPPD's ER, the staffs site visit, the scoping

process, or the evaluation of other available information. Therefore, the NRC staff concludes

that there were no other surface water issues.

Because of the complex nature of modeling climate change, current modeling only provides

regional-level projections with confidence. The most comprehensive, authoritative report is the

Global Climate Change Impacts in the United States (USGCRP, 2009), which discusses the

impacts of climate change on the Great Plains region, which includes Cooper and large portions

of the Missouri River watershed. The report states that significant trends in regional climate are

apparent over the last few decades, including an overall warming and an increase in

precipitation.

Projections of future climate change relied upon in the USGCRP report show that the northern

Great Plains region is anticipated to become wetter. The United States Global Change

Research Program (USGCRP) report expresses serious concerns about water resources in the

region, largely driven by increased evaporation and an unsustainable depletion of the Ogallala

aquifer. However, anticipated climate change by itself is not expected to reduce Missouri River

flows due to the anticipated increases in precipitation for most of the Missouri River watershed.

CNS does not use the Ogallala aquifer.

4.4.2 Water Use Conflicts

There were no Category 2 surface water issues identified for the CNS license renewal term.

4.5 AQUATIC RESOURCES

Section 2.1.6 of this report describes the CNS cooling water system and Section 2.2.5 describes

the aquatic resources. The Category 1 and Category 2 issues related to aquatic resources

applicable to CNS are discussed below and listed in Table 4-3.

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Table 4-3. Aquatic Resources Issues

Issues GElS Section Category

For All Plants

Accumulation of contaminants in sediments or biota 4.2.1.2.4 1

Entrainment of phytoplankton and zooplankton 4.2.2.1.1 1

Cold shock 4.2.2.1.5 1

Thermal plume barrier to migrating fish 4.2.2.1.6 1

Distribution of aquatic organisms 4.2.2.1.6 1

Premature emergence of aquatic insects 4.2.2.1.7 1

Gas 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 4.2.2.1.10 1

exposed to sublethal stresses

Stimulation of nuisance organisms 4.2.2.1.11 1

For Plants with Once-Through and Cooling Pond Heat Dissipation Systems

Entrainment of fish and shellfish in early life stages 4.1.2 2

Impingement of fish and shellfish 4.1.3 2

Heat shock 4.1.4 2

4.5.1 Generic Aquatic Ecology Issues

The NRC staff did not identify any new and significant information related to the Category 1

issues listed above during the review of the NPPD's ER, the site audit, or the scoping process.

Therefore, there are no impacts related to these issues beyond those discussed in the GELS.

For these issues, the GElS concludes that the impacts are SMALL, and additional site-specific

mitigation measures are not likely to be sufficiently beneficial to be warranted.

I

4.5.2 Entrainment and Impingement

4.5.2.1 Introduction

Entrainment and impingement of aquatic organisms are site-specific (Category 2) issues for

assessing impacts of license renewal at plants with once-through cooling systems. Entrainment

is the taking in of organisms with the cooling water. The organisms involved are generally of

small size, dependent on the screen mesh size, and include phyto- and zooplankton, fish eggs

and larvae, shellfish larvae, and many other forms of aquatic life. Impingement is the

entrapment of organisms against the cooling water intake screens.

A particular life stage of a species can be subject to both entrainment and impingement if some

individuals are impinged on screens while others pass through and are entrained (EPA, 1977).

Section 316(b) of the Clean Water Act (CWA) (33 United States Code (U.S.C.) § 1326(b))

requires that:

Any standard established pursuant to section 1311 of this title or section 1316 of

this title and applicable to a point source shall require that the location, design,

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construction, and capacity of cooling water intake structures reflect the best

technology available for minimizing adverse environmental impact.

The adverse environmental impacts of cooling water intake occur through both

impingement and entrainment. Exhaustion, starvation, asphyxiation, descaling, and

physical stresses may kill or injure impinged organisms. Heat, physical stress, or

chemicals used to clean the cooling system may kill or injure the entrained organisms.

4.5.2.2 History of Cooper Nuclear Station's 316(b) Compliance

I Section 4.2.5 of NPPD's ER provides the history of CNS's compliance with Section 316(a) and

316(b) of the CWA (33 United States Code (U.S.C.) § 1326(a) and 1326(b)). The Nebraska

I Department of Environmental Quality (NDEQ) (1977) found, after reviewing CNS's revised

316(b) documentation on the effects of the intake structure on fish populations, that the

structure met the minimum requirements of Section 316(b) of the CWA. The NDEQ (1977) also

voiced concerns regarding the fate of fish entrapped in the forebay area, however, and noted

that, "should problems develop in this area in the future, more adequate fish protection devices

I may be warranted." NPPD (2008a, pages 4-25) discontinued entrapment monitoring at CNS

about a year later in January 1978.

CNS conducted impingement sampling from 1974 through 1978. NPPD (2008a) lists the annual

impingement rates from 1975, 1976, and 1977 as follows: 45,990 fish, 63,245 fish, and 40,296

fish, respectively. NPPD (2008a) does not present the annual impingement rate for 1974, but

gives the daytime and nighttime rates as 19.8 and 38.1 fish per hour. Assuming 12-hour day

and night sampling periods (Hazleton, 1979) and extrapolating to 365 days per year, the NRC

staff calculated a yearly rate of 253,600 fish impinged in 1978. NPPD (2008a) did not present

the annual rate for 1978. The total impingement for 27 hours of sampling in 1978 was 266 fish

(Hazleton, 1979). Extrapolating to 365 days per year, the NRC staff calculated a yearly rate of

about 86,300 fish impinged in 1974. These annual rates can only be rough estimates

accompanied by a moderate degree of uncertainty, but they are reasonable for understanding

the order of magnitude of impingement.

NPPD (2008a) reports that gizzard shad, freshwater drum, and river carpsucker make up the

majority of impinged fish in the 1974 through 1978 studies. Based on data from the ER (NPPD,

2008a, Table 1.3-1), the contribution of these three species to total impingement numbers

ranged from 73 to 91 percent for the period of 1974 through 1978. Hazleton (1979, Table 7.1)

categorizes the occurrence of gizzard shad, freshwater drum, and river carpsucker in the area

around the CNS as "common" based on electroshocking and seining during the pre- and

post-operational period, 1970 through 1978. The age class of the majority of fish impinged each

year was young of the year, and most impingement occurred at night (NPPD, 2008a, page

4-24).

According to NPPD's (NPPD, 2008c) 316(b) Compliance Strategy Report for 2007, "to help

address the 316(b) requirements, NPPD installed Brackett-Green dual flow screens with

modified Ristroph fish buckets in 2005 and 2006." CNS has not yet completed the fish

protection system. The intention is to install a fish handling and return system to mitigate fish

impingement. The CNS implementation date and the final design of the fish handling system are

dependent upon the content of the final 316(b) CWA requirements. CNS's original 316(a) and

316(b) demonstration (Nalco, 1975, Tables 4.4-48 through 4.4-50) reported entrainment

mortality (intake vs. discharge and after an unspecified holding period) but not the number of

fish entrained, both of which are necessary for a full assessment of the effects of entrainment.

Nalco (1975, Tables 4.4-50 and 4.4-51) also reported mortality of fish larvae after an

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unspecified holding period, after passage through the thermal plume. Following NDEQ's (1977)

review of CNS's revised 316(b) documentation, NPDES permits have not required subsequent

entrainment monitoring and assessment (NPPD, 2008a, page 4-11). The U.S. Atomic Energy

Commission (AEC) (1973, page V-15) found that it could describe the potential loss of fish eggs

and larvae only in terms of the fraction of river flow taken by the plant, which in spring and early

summer when many of the fish species spawned, was about 4 percent. During unusually low

summer flows, this fraction would be greater and the fraction of river flow taken by the plant

should be no more than 20 percent (NPPD, 2008a). The AEC (1973) found that the percentage

loss of fish eggs and larvae originating upstream of the plant was probably much less than the

fractional flow because the sampled fish species were spawning in protected areas.

In its guidelines for ecological risk assessment, the Environmental Protection Agency (EPA)

(1998) recommends the use of multiple lines of evidence for characterizing and describing risk.

The use of lines of evidence can be quantitative or qualitative. The NRC staff adopted a

qualitative approach for the impact analysis here. One line of evidence is the regulatory history

itself. Although any final determinations regarding CNS's 316(b) demonstration await the EPA's

publication of new Phase II rules. Phase II rules were published in 2004, suspended in 2007,

and are awaiting new Phase II rules at the time this supplemental environmental impact

statement (SEIS) was developed.

The NRC staff find that the history of regulation reviewed above does not show regulatory

concern that the potential effects of impingement and entrainment constitute adverse impacts.

4.5.2.3 Analysis

At NRC's environmental audit at CNS in 2009 and in scoping comments (EPA, 2009c), the EPA

voiced concern regarding the age of the data (over three and a half decades) used in the ER to

support NPPD's assertion in their ER that CNS's impingement and entrainment produced a

SMALL impact level on aquatic populations. To assess whether the Missouri River aquatic

resources near CNS are stable (as described in Section 2.2.5 of this SEIS), the NRC staff

performed the following analysis.

The NRC staff examined the question of how the age of the data might affect the conclusions

regarding entrainment and impingement at CNS. The NRC staff found that the argument used in

the NPPD's ER is inconsistent because it assumed at different points that the aquatic resources

are both stable and unstable, although in fact they cannot be both. In describing the aquatic

resources, the ER stated that fish communities have long been responding to changes in the

river brought on by man's activities.

The NRC staff reached the conclusion of resource instability from a review of literature

(presented in Chapter 2) on the natural and human history of the watershed. The changes are

well documented. the present Missouri River is relatively new in geological terms and was partly

formed by the last glaciation. As a result, most species in the region have not evolved in place

but have colonized from surrounding environments that may have had somewhat different

ecologies. Man has changed the river almost constantly, particularly since European settlement.

Particularly influential were the early impoundments and withdrawals for irrigation and later

dams built for various purposes (e.g., flood control, hydroelectric power, transportation,

irrigation). Numerous diversions now withdraw river water for both consumptive and

non-consumptive uses. Dredging, bank stabilization, construction of levees, dikes, revetments,

and other structures have changed the course of the river, its hydrological cycles, water current

velocity, water levels, patterns of sediment suspension and deposition, suspended sediment

levels, substrate types, and other aspects of fish habitat. Agriculture, industrialization, the CWA,

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and other regulations and associated activities have affected levels of contaminants in water

and sediments, dissolved oxygen levels, and other water quality parameters that affect aquatic

populations. Future changes to the Missouri River, for example, those flowing from the Missouri

River Ecosystem Restoration Plan, can be foreseen. Aquatic populations respond to these

habitat changes.

The effects of impingement and entrainment on fish populations depend in part on the identity,

numbers, and population structure of the affected populations. But the reviews of aquatic

resources in the NPPD's ER and Section 2.2.5 in this SEIS show that the aquatic populations

are not static or stable.

The observation that the aquatic resources of the Missouri River are not static or stable affects

NRC's assignment of its level of impact in two ways. First is the concern voiced by the EPA

(2009b): the age of the impingement and entrainment data brings into question "whether these

data are representative of current river condition and ecological impact." Second, NRC partially

defines its levels of impact in terms of stability: for example, NRC's definition of a small impact

level is that "environmental effects are not detectable or are so minor that they will neither

destabilize nor noticeably alter any important attribute of the resource" and the definition of large

impact is that "environmental effects are clearly noticeable and are sufficient to destabilize

important attributes of the resource." In applying its definitions of impact levels to effects of CNS

on Missouri River aquatic resources, NRC chose an approach that can accommodate the

observations that the aquatic resources are changing constantly in response to many

environmental variables and are not stable in the sense of unchanging or static.

Another line of evidence is the ecology of adult and juvenile fish living in the Missouri River. The

ER reports that water velocity at CNS's intake screens is about 2 feet per second, whereas

"historical river velocities were usually 0.98-2.62 feet per second, but downstream from Gavins

Point Dam velocities between 2.62 feet per second and 4.27 feet per second occur more

frequently than they did historically (Berry et al., p. 6)." These observations suggest that fish in

the Missouri River should be adapted to living in water with velocities well in excess of the

current that occurs at the intake screens. So while the identity, numbers, and population

structure of the potentially affected fish populations may have changed over the last decades,

present fish populations are most likely no less able to escape or avoid adverse impact than

those present when the impingement and entrainment studies were performed.

A third line of evidence lies in the general ecology of fish eggs and larvae subject to

entrainment. The generalities about the pattern of fish eggs and larvae in the Missouri River drift

vulnerable to entrainment at CNS are probably similar to those reported by Hergenrader et al.

(1982) in the vicinity of CNS in 1974 through 1976, although the relative and absolute

abundances, and perhaps some species, may have changed. Fish eggs and juveniles are

probably still a small part of all ichthyoplankton and most common from May through July. The

numerically dominant fish larvae are probably still those of pelagic spawners, such as

freshwater drum, catastomids (e.g., suckers), cyprinids (e.g., minnows), common carp (Cyprinus

carpio), gizzard shad (Dorosoma cepedianum), and goldeneye (Hiodon alosoides). The larvae

of fish that build nests or spawn randomly have adhesive and demersal (sinking) eggs, or

provide parental care of the eggs and larvae, such as centrarchids (e.g., white bass (Morone

chrysops), sunfish (Lepomis spp.), and crappie (Pomoxis spp.), percids (e.g., sauger

(Stizostedion canadense) and walleye (Sander vitreus), and channel catfish (Ictalurus

punctatus) are probably still relatively underrepresented.

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Another line of evidence is the fraction of Missouri River flow withdrawn by CNS. The AEC

(1973, page V-15) found that it could describe the potential loss of fish eggs and larvae only in

terms of the fraction of river flow taken by the plant, which in spring and early summer when

many of the fish species spawned was estimated at 4 percent. During unusually low summer

flows, the fraction of river flow taken by the plant should be no more than 20 percent (NPPD,

2008a). The AEC (1973) also found that the percentage loss of fish eggs and larvae originating

upstream of the plant was probably much less than this because of the protected areas that

these species used for spawning. These are very general ways of analyzing impact, and, within

their limitations, these generalities are probably still true today, although once again, the identity

of the species affected may have changed over time.

The available lines of evidence for assessing impact level for aquatic resources subject to

impingement and entrainment at CNS are as follows: (1) the lack of a history of regulatory

action indicates no appreciable adverse impact; (2) while fish populations may have changed

over the decades, present fish populations are most likely no less able to escape or avoid

adverse impact than those present when the impingement and entrainment studies were

performed; (3) the generalities about the pattern of fish eggs and larvae in the Missouri River

drift vulnerable to entrainment at CNS are probably similar to those reported in past studies that

found little or no adverse effects of plant operation; (4) the relative fraction of river flow

withdrawn by the plant remains small, and most fish species still have refugia that protect the

populations from adverse effects of impingement and entrainment; (5) CNS now has dual flow

screens with modified Ristroph fish buckets and NPPD plans to install a fish handling and return

system whose final design is dependent upon the content of the final 316(b) CWA requirements;

and (6) the NDEQ conclusion based on monitoring and studies conducted by the Omaha Public

Power District near both Fort Calhoun Station and CNS that losses due to entrainment were

within the acceptable range.

Although the NRC staff reached the conclusion that aquatic resources are not stable, the NRC

staff finds that, although these changes may have occurred, the impact on aquatic resources

due to impingement and entrainment at CNS is SMALL. The NRC staff has reviewed the

available information, including that provided by the applicant, the staffs site visit, the State of

Missouri, the 316(b) demonstration, and other public sources. Although no recent impact studies

have been performed, the NRC staff concludes that the weight of evidence from past studies,

biological inference, and regulatory history indicates a SMALL level of impact on aquatic

resources due to impingement and entrainment at CNS. NPPD has implemented some

impingement mitigation measures and plans to implement others.

4.5.3 Thermal Effects

For plants with once-through cooling systems and cooling pond heat dissipation systems,

NRC's GElS (1996) lists the effects of heat shock as an issue requiring plant-specific evaluation

before license renewal (Category 2). The NRC (1996) made impacts on fish and shellfish

resources resulting from heat shock a site-specific issue because of continuing concerns about

thermal discharge effects and the possible need to modify thermal discharges in the future in

response to changing environmental conditions.

Information considered includes the type of cooling system (once-through in this case),

evidence of a CWA Section 316(a) variance or equivalent State documentation, and other

information. To perform this evaluation, the staff reviewed the CNS's ER (NPPD, 2008a); visited

the CNS site; reviewed the facility's 316(a) demonstration (Nalco, 1975) dated October 23,

1975, and submitted to the NDEQ; and reviewed the applicant's State of Nebraska NPDES

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Permit No. NE0001244 issued on July 1, 2007, and in force until July 30, 2012 (found in

Attachment C of NPPD, 2008a).

The latest fact sheet for the NPDES permit summarizes the thermal limits for the effluent and

the bases of the limits. The EPA assisted NDEQ in conducting the assessment of mixing cooling

water from CNS with ambient Missouri River water for the permit. The permit limits are based on

a modeled limit of a 90'F "heat cap" or maximum at the end of the 5,000-ft mixing zone.

According to the fact sheet, "Based on a AT of 23.9°F, the permit limit for the Cooper Nuclear

power plant is 109.4°F. The maximum instream river temperature where the heat cap is met is

85.54°F (29.7-C)" (NDEQ, 2007).

The NPDES permit limits are set for the protection of aquatic life (NDEQ, 2007). In addition to

upper thermal limits, shutdown of the plant in winter could cause sudden decreases of

temperature that could cause thermal shock and mortality in fish attracted to or living in the

thermal discharge and discharge canal (NPPD, 2008a), although these events would probably

be rare.

After reviewing the available information, the NRC concludes that the level of thermal impacts to

the aquatic community due to renewing CNS's operating license is designated as SMALL.

4.5.4 Total Impacts on Aquatic Resources

In addition to the information presented for impingement, entrainment, and thermal effects

individually, the results of some field studies performed in the past and summarized in Section

I 2.2.5 provide information on the total impacts of CNS's cooling water system operation on

aquatic resources. Field studies comparing aquatic communities at locations upstream and

downstream from CNS reflect the total impact of entrainment, impingement, and thermal effects.

Reetz (1982) reported that initial (7-hour) differences in carbon fixation rates of phytoplankton at

I CNS between intake and discharge sampling locations ranged from an average of about

17 percent inhibition during summer to no change during winter. The inhibition in the summer

months appeared to depend on absolute discharge temperature: the highest inhibition rates

(above 26 percent) occurred when absolute discharge temperatures exceeded 101°F (38.5°C).

Recovery from initial inhibition at CNS occurred within 48 hours. While the river would carry

phytoplankton far downstream in 48 hours so that a substantial part of the river would be

I affected, Reetz (1982) concluded that the low rate of water use by CNS compared to river flow

combined with the rapid mixing of the thermal plume would make the effects relatively

unnoticeable.

Periphytic algae are those algae that are attached to solid surfaces under water, such as rocks,

logs, pilings, and other structures. Farrell and Tesar (1982) reported results of periphytic algae

I studies conducted in the Missouri River in the vicinity of CNS from 1972 through 1977. Because

they remain in one place, periphytic algae colonizing natural and artificial substrata are used as

indicators of environmental effects. Farrell and Tesar (1982) did not detect changes in the

diversity, density, and biovolume of periphytic algae related to water temperature in the vicinity of CNS, although species composition did reflect water temperature. Although these results may

generally be indicative of periphyton responses and processes at CNS today, species

composition and magnitude of response, which depends on the species involved, may have

changed over the decades since Farrell and Tesar's (1982) studies.

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Repsys and Rogers (1982) investigated the effects of CNS on zooplankton populations in 1974

through 1978. High absolute discharge temperatures (at or about equal to 35°C or 95°F)

critically affected zooplankton survival, as did the duration of exposure. Repsys and Rogers

(1982) concluded that entrainment losses were small when compared to the large downstream

decreases in zooplankton. Without further studies, the NRC concludes that these general

patterns and processes most likely still occur, although species composition and magnitude of

response, which depends on the species involved, may have changed over the decades since

Repsys and Rogers' (1982) studies.

Carter et al. (1982) reported results of benthic infaunal and epifaunal invertebrate studies

conducted in the Missouri River in the vicinity of CNS and Fort Calhoun Station from 1973

through 1977. Benthic infauna refers to the organisms that live in underwater sediments, and

benthic epifauna refers to organisms that live on underwater surfaces. Like periphyton, benthic

invertebrates are often used as indicators of impacts because they are relatively immobile and

sensitive to local environmental conditions. Carter et al. (1982) were not able to detect

consistent changes in the epifaunal invertebrate community due to operation of CNS.

Hergenrader et al. (1982) reported the results of both field and entrainment studies on larval fish

in the vicinity of CNS in 1974 through 1976. In order to determine if entrainment (and

impingement) were having an effect on the fish populations in the area, Hergenrader et al.

(1982) looked for changes in adult fish populations resulting from impacts to larval fish, but

detected none. They concluded that either no significant changes occurred or "Too few

resources (financial, technical, equipment, labor) were applied over too small a time frame in too

restricted an area to detect the changes which had occurred."

The aquatic community, particularly the fish community, may not be stable and may still be

changing in response to historical changes in land use, river regulation, and other human

activities. For example, the U.S. Army Corps of Engineers (USACE) (2004) reports that the

benthic fish community appears to be changing based on 1996 and 1997 studies. Whatever the

total effects of CNS on the fish community were in the past, the installation of the modified

dual-flow traveling screens in 2006 and future installation of a fish handling and return system

(dependent upon the content of the final 316(b) CWA requirements) would mitigate those

impacts.

While the species and their numbers would have changed over the last decades, the results

summarized above reflect general ecological responses.

The NRC staff concludes that the level of impact on aquatic resources due to all aspects of

CNS's cooling system operation is SMALL.

4.6 TERRESTRIAL RESOURCES

Section 2.2.6 of this document provides a description of the terrestrial resources at CNS and in

the surrounding area. The issues related to terrestrial resources applicable to CNS are

discussed below and listed in Table 4-4. No Category 2 issues are related to terrestrial

resources for license renewal. The NRC staff did not identify any additional new and significant

information during review of NPPD's ER, the site audit, the scoping process, or the evaluation of

other available information. Therefore, the NRC staff concludes that there would be no impacts

related to these issues beyond those discussed in the GElS (NRC, 1996). The GElS concludes

that the impacts are SMALL and additional site-specific mitigation measures are not warranted.

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Table 4-4. Terrestrial Resources Issues

Issues GElS Section Category

Power line right-of-way management (cutting herbicide application) 4.5.6.1 1

Bird collisions with power lines 4.5.6.1 1

Impacts of electromagnetic fields on flora and fauna (plants, 4.5.6.3 1

agricultural crops, honeybees, wildlife, livestock)

Floodplains and wetlands on power line right-of-way 4.5.7 1

4.7 THREATED AND ENDANGERED SPECIES

4.7.1 Aquatic Species

Section 2.2.7 of this document describes the threatened or endangered species on or near

CNS. The impact to threatened and endangered species is a Category 2 issue and is discussed

below.

One Federally-listed aquatic species may occur in the Missouri River near CNS: pallid sturgeon.

NPPD (2008a) summarizes interactions between NPPD and both State and Federal agencies

regarding conservation of pallid sturgeon.

In March 2006, before filing a license renewal application with the NRC, NPPD voluntarily

participated in meetings with the U.S. Fish and Wildlife Service (USFWS), the Nebraska Game

and Parks Commission (NGPC), the NDEQ, the NDNR, the EPA, and the USACE regarding

conservation actions to improve the habitat of pallid sturgeon. NPPD (2008a) summarizes those

meetings. Early in the discussions, the USFWS and NGPC showed interest in developing

existing habitat on a parcel of property south of CNS at Langdon Bend and later also on CNS

property on the Nebraska side of the Missouri River adjacent to Langdon Bend. They hoped to

enhance pallid sturgeon habitat by building a chute to connect the active river channel with the

old river area.

NPPD had problems with this proposal. Implementing the proposal would reduce CNS's mixing

zone, which now extends 5,000 ft south of CNS along the Nebraska side of the Missouri River,

to less than 2,500 ft. Reducing the mixing zone would reduce CNS's capacity to generate

electricity, particularly during summer. The proposal also posed other negative safety and

I environmental concerns for CNS. As an alternative, NPPD then offered to contribute funds

toward other new or existing projects on the Missouri River. The USFWS rejected this funding alternative in favor of increasing the amount of land for habitat development.

To meet the goal of improving habitat for pallid sturgeon, NPPD offered a conservation

easement of about 239 acres (ac) of land that it owns on the Missouri side of the Missouri River,

opposite CNS, for the purposes of habitat development. The USFWS indicated interest in the

proposal and asked NPPD to also acquire an adjacent property of about 150 ac so that the

entire bend in the river could be developed into better habitat. When the property owner refused

to sell the land, NPPD offered a revised, final proposal to participate in and promote habitat

development along the Missouri River. It proposed to revisit the USFWS's and the NGPC's

interest in a suitable conservation easement and Memorandum of Understanding (MOU) to

enable habitat development on NPPD's approximately 239 ac parcel on the Missouri side of the

river. Furthermore, because NPPD recognized that this parcel alone would not meet the

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USFWS's and the NGPC's conservation habitat development goals, NPPD indicated its

willingness to make an additional payment of $250,000 to be applied toward another

conservation habitat development project on the Missouri River at the direction of the USFWS

and the NGPC. The deed restriction for conservation has been placed upon the 239 ac that

NPPD owns on the Missouri side of the river, and the MOU, including conditions regarding the

additional payment of $250,000, has been finalized and signed by the parties.

Plans for and construction of a chute on the parcel may also involve the owners of the

transmission lines and supports that cross the property. NPPD does not own these lines,

although CNS provides power to them.

The probability that CNS will entrain, impinge, or otherwise affect pallid sturgeon eggs or larvae

is low. Hazleton (1979) collected adult and juvenile fish from seven locations in the vicinity of

CNS from 1970 through 1978 and reported no pallid sturgeon captured. They also conducted

impingement sampling from 1974 through 1978 and reported no pallid sturgeon impinged.

Based on 374 trawl hauls that captured over 21,735 fish in a 1998 through 2000 survey, Hrabik

et al. (2007) concluded that pallid sturgeon may reproduce in the lower Missouri River and the

upper and lower Mississippi River, although no fish may survive to recruitment. NPPD's

involvement in the conservation agreement for pallid sturgeon; however, could have a positive

impact on the population.

The best information available indicates that the NRC level of impact associated with license

renewal is SMALL. Although the NRC also concludes that the continued operation of CNS for

an additional 20 years may affect, but is not likely to adversely affect, the pallid sturgeon, the

NRC staff prepared a biological assessment, which appears in Appendix D.

4.7.2 Terrestrial Species

An evaluation of impacts to threatened and endangered terrestrial species requires consultation

with appropriate agencies to determine whether or not such species are present and whether or

not these species would be adversely affected by continued operation of the CNS site during

the license renewal term.

NPPD has coordinated efforts with the USFWS to address the potential risk of

Federally-listed migratory birds colliding with transmission line NPPD TL3502, as discussed in

Section 2.2.7.

Four Federally-listed endangered and threatened species, the Indiana bat (Myotis sodalis), the

western prairie fringed orchid (Platanthera praeclara), the piping plover, and the interior least

tern are potentially found in the vicinity of the CNS site (NPPD, 2008a). Seven Federally-listed

species are also found or potentially found within the counties spanning the transmission line

corridor, including the western prairie fringed orchid, the Salt Creek tiger beetle (Cicindela

nevadica lincolniana), the black-footed ferret (Mustela nigripes), the interior least tern, the piping

plover, the Eskimo curlew (Numenius borealis), and the only known wild population of whooping

cranes (USFWS, 2007), (USFWS, 2008), (USFWS, 2009b). The Eskimo curlew is listed as

extirpated from Nebraska and is globally extinct or near-extinct (NatureServe, 2009).

There are 115 State-listed threatened or endangered species that occur or have the potential to

occur in the vicinity of CNS in Nemaha County, within the counties spanning the transmission

line corridor in Nebraska, and in Atchison County, Missouri (NGPC, 2008), (MDC, 2009b).

These 115 species are listed in Table 2.2.7-1 along with information on their habitat

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requirements. No longer included in this list is the American bald eagle (Haijeatus

leucocephalus), which was formerly a Federally-listed bird. There is an active bald eagle's nest

on the Missouri side of the CNS property with a breeding pair of eagles that have produced a

number of chicks over the past several years (NPPD, 2008a). Although no longer protected

under the Endangered Species Act (ESA), the bald eagle is still protected under the Migratory -

Bird Treaty Act, and is also protected under the Bald and Golden Eagle Protection Act from any

take of a bald eagle without a permit. According to the ER, NPPD attempts to minimize

disturbance to the eagles during the infrequent site activities performed on the Missouri side of

the CNS site (NPPD, 2008a).

NPPD is required to promptly report to the appropriate wildlife management agencies and to

NRC, any evidence of injury to, or mortality of, migratory birds or threatened or endangered

species observed within the transmission line corridor, especially injury to, or mortality of,

Federally-listed whooping cranes, interior least terns, and piping plovers along the Platte River

near the western limit of CN S transmission line NPPD TL3502, near Grand Island, NE. From

the review of the available information, the NRC staff finds that operation of the CNS site and its

associated transmission lines has not been known to, nor is it expected to harm any threatened

or endangered species during the license renewal term. Mitigation measures currently in place

at the CNS site include bird flight diverters on the transmission lines within the CNS facility,

minimization of activity near the eagle's nest on the Missouri side of the CNS site, a right-of-way

(ROW) vegetation management program, and best management practices.

NPPD has coordinated with the USFWS staff and has installed bird diverters on transmission

line NPPD TL3502 where it traverses the Platte River. These bird flight diverters will minimize

potential impacts to whooping cranes, interior least terns, piping plovers, and other migratory

birds. All of these current and proposed mitigation measures minimize the effects of plant

operation on terrestrial species and are found to be adequate. Therefore, the NRC staff

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

term would be SMALL.

4.8 HUMAN HEALTH

Table B-1 of Appendix B to Subpart A of 10 CFR Part 51 contains more information on these

issues. The human health issues applicable to CNS are discussed below and listed in Table 4-5

for Category 1, Category 2, and uncategorized issues.

Table 4-5. Human Health Issues

Issues GElS Section Category

Microbiological organisms (occupational health) 4.3.6 1

Microbiological organisms (public health, for plants using small 4.3.6 2

rivers)

Noise 4.3.7 1

Radiation exposures to public (license renewal term) 4.6.1,4.6.2 1

Occupation radiation exposures (license renewal term) 4.6.3 1

Electromagnetic fields - acute effects (electric shock) 4.5.4.1 2

Electromagnetic fields - chronic effects 4.5.4.2 Uncategorized

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4.8.1 Generic Human Health Issues

The staff did not identify any new and significant information during its review of NPPD's ER, the

site audit, or the scoping process. Therefore, there are no impacts related to these issues

beyond those discussed in the GELS. For these issues, the NRC staff in the GElS concluded

that the impacts are SMALL, and additional site-specific mitigation measures are not likely to be

sufficiently beneficial to be warranted. The following information discusses two specific

radiological programs conducted at CNS; the radiological environmental monitoring program

(REMP) and the radioactive effluent release program.

CNS conducts an annual REMP in which radiological impacts to the employees, the public, and

the environment in the environs around the CNS site are documented. The report contains a

discussion of the data relative to pre-plant operation baseline data. The objectives of the REMP

include the following:

measure and evaluate the levels of radiation and radioactive material in the

environs around the CNS site to assess the radiological impacts, if any, of plant

operation on the environment

supplement the results of the radiological effluent monitoring program by

verifying that the measurable concentrations of radioactive material and levels

of radiation are not higher than expected based on the measurement of

radioactive effluents and modeling for the applicable exposure pathways

demonstrate compliance with the requirements of applicable Federal regulatory

agencies

Two reports summarize radiological information about the CNS site; the annual radiological

environmental operating report and the annual radioactive effluent release report. The media

samples are intended to be representative of the radiation exposure pathways to the public from

all plant radioactive effluents. The REMP measures the aquatic, terrestrial, and atmospheric

environment, as well as the ambient gamma radiation, for radioactivity. Ambient gamma

radiation pathways include radiation from buildings and plant structures and airborne material

that may be released from the plant. In addition, the REMP also measures background radiation

(i.e., cosmic sources, global fallout, and naturally occurring radioactive material, including

radon). Thermoluminescent dosimeters (TLDs) are used to measure direct radiation. The

atmospheric environmental monitoring consists of sampling the air for particulates and

radioiodine. Terrestrial environmental monitoring consists of analyzing samples of milk and food

products. The aquatic environmental monitoring consists of analyzing samples of surface water,

drinking water, ground water, fish, and sediment from the Missouri River. There is also an onsite

ground water protection program designed to monitor the onsite plant environment for

indications of leaks from plant systems and pipes carrying radioactive liquid. The NRC staff

reviewed the CNS radioactive environmental operating reports for 2003 through 2009 to look for

any significant impacts to the environment or any unusual trends in the data (NPPD, 2004a),

(NPPD, 2005a), (NPPD, 2006a), (NPPD, 2007a), (NPPD, 2008d), (NPPD, 2009a), (NPPD,

2010). The staffs review of the REMP reports showed no unusual trends in the data and

showed no measurable impact from the operations at CNS on the environment.

Historical data on radioactive releases from CNS and the resultant dose calculations

demonstrate that the amount of radiation received to a hypothetical maximally exposed

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individual in the vicinity of CNS is a small fraction of the dose limits specified in 10 CFR Part 20,

the as low as reasonably achievable (ALARA) dose design objectives in Appendix I to

10 CFR Part 50, and the EPA's radiation standards in 40 CFR Part 190, "Environmental

Radiation Protection Standards for Nuclear Power Operations." Dose estimates for members of

the public are calculated based on liquid and gaseous effluent release data and atmospheric

and aquatic transport models. The CNS 2009 annual radioactive effluent release report

(NPPD, 2010) contains a detailed presentation of the radioactive discharges and the resultant

calculated doses. The following summarizes the calculated hypothetical maximum dose to an

individual located at the CNS site boundary from radioactive liquid and gaseous effluents

released during 2009:

* The whole-body dose to an offsite member of the general public from liquid

effluents was 2.45 x 10-2 millirems (mrem) (2.45 x 104 milliSieverts (mSv)) which

is below the 3 mrem (0.03 mSv) dose criteria in Appendix I to 10 CFR Part 50.

* The air dose at the site boundary from gamma radiation in gaseous effluents

was 1.99 x 10.3 millirads (mrad) (1.99 x 10-5 milligray (mGy)), which is below the

10 mrad (0.10 mGy) dose criteria in Appendix I to 10 CFR Part 50.

* The air dose at the site boundary from beta radiation in gaseous effluents was

3.74 x 10-3 mrad (3.74 x 10-5 mGy), which is below the 20 mrad (0.20 mGy)

dose criteria in Appendix I to 10 CFR Part 50.

The NRC staff has reviewed and assessed the CNS radioactive waste system performance in

controlling radioactive effluents and the resultant doses to members of the public in

conformance with the ALARA criteria. The NRC staff found that the 2009 radiological data for

CNS are consistent, with reasonable variation attributable to operating conditions and outages

and with the historical radiological effluent releases and resultant doses (NPPD, 2004b),

(NPPD, 2005b), (NPPD, 2006b), (NPPD, 2007b), (NPPD, 2008e), (NPPD, 2009a), (NPPD,

2010). These results demonstrate that CNS is operating in compliance with Federal radiation

protection standards contained in Appendix I to 10 CFR Part 50, 10 CFR Part 20, and

40 CFR Part 190. The applicant has no plans to conduct refurbishment activities during the term

of license renewal. Continued compliance with regulatory requirements is expected during the

license renewal term; therefore, the impacts from radioactive effluents are not expected to

change during the license renewal term.

4.8.2 Microbiological Organisms

The effects of thermophilic microbiological organisms on human health, listed in Table B-1 of

Appendix to Subpart A of 10 CFR Part 51, are categorized as a Category 2 issue and require

plant-specific evaluation during the license renewal process for the plants located on a small

river. The average annual flow of the Missouri River at the nearest point to a CNS measuring

station is approximately 1.2 x 1012 cubic feet per year (ft3/yr) (3.4 x 1010 cubic meters per year

(m3/yr)), which is less than 3.15 x 1012 ft3

/year (9 x 1010 m3

/year), the rate for which an

assessment of the impact of the proposed action on public health from thermophilic organisms

in the affected water is required by 10 CFR 51.53(c)(3)(ii)(G). Therefore, the site-specific effects

on public health must be addressed.

The Category 2 designation is based on the magnitude of the potential public health impacts

associated with thermal enhancement of the enteric pathogens such as Salmonella spp. and

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Shigella spp., the Pseudomonas aeruginosa bacterium, the pathogenic strain of the free-living

amoebae Naegleria spp., and Legionella spp. bacteria (NRC, 1996). Thermophilic

microorganisms generally occur at temperatures of 77°F to 176°F (25°C to 80°C) with an

optimal growth temperature range of 122°F-150°F (50°C-660C), minimum and maximum

temperature tolerances of 68°F (20°C) and 158 0 F (70 0C), respectively; however, thermal

preferences and tolerances vary across bacterial groups. Pathogenic thermophilic

microbiological organisms that are of concern during nuclear power reactor operation typically

have optimal growing temperatures of approximately 99 0F (370C) (Joklik and Smith, 1972).

Pseudomonas aeruginosa is an opportunistic pathogen that causes serious and sometimes fatal

infections in immunocompromised individuals. The organism produces toxins harmful to

humans and animals. It has an optimal growth temperature of 99 0F (370C) (Todar, 2007)

Legionella spp. consists of at least 46 species and 70 serogroups. It is responsible for

Legionnaires' disease, with the onset of pneumonia in the first 2 weeks of exposure. Risk

groups for Legionella spp. include elderly, cigarette smokers, persons with chronic lung or

immunocompromising diseases, and persons receiving immunosuppressive drugs.

The ambient temperatures of the Missouri River near CNS vary from freezing (approximately

32 0F (0°C)) in the winter to 87 0F-89°F (30.5°C-31.60C) in the summer; therefore, ambient river

conditions are not likely to support the proliferation of the pathogenic organisms of concern.

According to the data submitted by NPPD to the NDEQ for the period January 2003 to

September 2005, the mean monthly average temperature of the thermal discharge at

Outfall 001 was 75.7°F (24.3°C). The reported maximum daily temperature, which occurs

temporarily for the short time during periodic condenser backwash, was 109.2 0F (42.9°C). The

highest monthly average discharge temperature was 101.7°F (38.7°C) in August 2003 and

101.3°F (38.5°C) in July 2005, which is consistent with the historical data showing that monthly

average discharge temperatures at or above 95°F (35°C) occur only during July and August.

Ambient temperatures of the Missouri River stay below 77 0F (250C) from October to April;

therefore, ambient river conditions are not likely to support the proliferation of pathogenic

organisms of concern.

NPPD consulted the Nebraska Department of Public Health and Human Services (DHHS) and

the Missouri Department of Public Safety (DPS) to determine if there was any concern about the

potential occurrence of thermophilic microbiological organisms in the Missouri River at the CNS

location. The Nebraska DHHS and Missouri DPS stated that no occurrences of infections

caused by Naegleria fowleri from the Missouri River in the CNS vicinity were documented

(NPPD, 2008a).

Available data assembled into biannual reports by the Center for Disease Control (CDC) for the

years 1999 to 2006 (CDC, 2000), (CDC, 2002), (CDC, 2004), (CDC, 2006) indicate no

occurrence of waterborne disease outbreaks in the State of Nebraska resulting from exposure

to the thermophilic microbiological organisms Naegleria fowleri and Pseudomonas aeruginosa

from the operation of CNS.

The NRC staff reviewed all documents, applicable to this Category 2 issue, including NPPD's

ER, the NPDES permit, and CDC reports. The NRC staff concludes that thermophilic

microbiological organisms are not likely to present a public health hazard as a result of CNS

discharges to the Missouri River.

The NRC staff concludes that impacts on public health from thermophilic microbiological

organisms from continued operation of CNS in the license renewal period would be SMALL.

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4.8.3 Electromagnetic Fields - Acute Shock

Based on the GElS, the Commission found that electric shock resulting from direct access to

energized conductors or from induced charges in metallic structures has not been a problem at

most operating plants and generally is not expected to be a problem during the period of

extended operation; however, a site-specific review is required to determine the significance of

the electric shock potential along the portions of the transmission lines within the scope of the

SEIS.

The GElS states that it is not possible to determine the significance of the electric shock

potential without a review of the conformance of each nuclear plant transmission line with

National Electric Safety Code (NESC) criteria (IEEE, 2007). Evaluation of individual plant

transmission lines is necessary because the issue of electric shock safety was not addressed in

the licensing process for some plants. For other plants, land use in the vicinity of transmission

lines may have changed, or power distribution companies may have chosen to upgrade line

voltage. To comply with 10 CFR 51.53(c)(3)(ii)(H), the applicant must provide an assessment of

the potential shock hazard if the transmission lines that were constructed for the specific

purpose of connecting the plant to the transmission system do not meet the recommendations

of the NESC for preventing electric shock from induced currents.

All transmission lines associated with CNS were constructed in accordance with NESC and

industry guidance in effect at the time of their construction (AEC, 1973). The transmission

facilities are maintained to ensure continued compliance with current standards. The

transmission line assessment program, implemented at CNS, ensures continued monitoring and

documenting of current conditions of the transmissions lines, along with maintenance, and

compliance with current standards. Bimonthly aerial patrols and additional special patrols after

severe storms are performed in order to identify any ground clearance problems and the

integrity of the transmission line structures. Ground inspections are conducted by transmission

line technicians on an annual basis (NPPD, 2008a).

Since the lines were constructed, a new criterion has been added to the NESC for power lines

with voltages exceeding 98 kilovolts (kV). NPPD has reviewed the transmission line clearances

and configurations for compliance with this criterion (NPPD, 2008a) and determined that all

transmission lines within the scope of this review meet the NESC code. No induced shock

hazard to the public should occur, since the lines are operating within original design

specifications and meet current NESC clearance standards.

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

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

for electric shock resulting from the operation of CNS and its associated transmission lines. The

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

would be SMALL.

4.8.4 Electromagnetic Fields - Chronic Effects

In the GELS, the chronic effects of 60-hertz (Hz) electromagnetic fields (EMFs) from power lines

were not designated as Category 1 or 2, and will not be until a scientific consensus is reached

on the health implications of these fields. The Commission rules do not require the license

renewal application to include information on this issue.

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4.9 SOCIOECONOMICS

Category 1 issues in 10 CFR Part 51, Subpart A, Appendix B, Table B-1 that are applicable to

socioeconomic impacts during the renewal term, are listed in Table 4-6. As stated in the GELS,

the impacts associated with these Category 1 issues were determined to be SMALL, and

plant-specific mitigation measures would not be sufficiently beneficial to be warranted.

The NRC staff reviewed and evaluated the CNS ER, scoping comments, other available

information, and visited CNS in search of new and significant information that would change the

conclusions presented in the GElS. No new and significant information was identified during this

review and evaluation. Therefore, it is expected that there would be no impacts related to these

Category 1 issues during the renewal term beyond those discussed in the GElS.

Table 4-6. Category I Issues Applicable to Socioeconomics during the Renewal Term

Issues GElS Section Category

Public Services: public safety, social services, and tourism and 4.7.3.3; 4.7.3.4;

recreation 4.7.3.6

Public Services: education (license renewal) 4.7.3.1 1

Aesthetic Impacts (license renewal term) 4.7.6 1

Aesthetic impacts of transmission lines (license renewal term) 4.5.8 1

4.9.1 Generic Socioeconomic Issues

The following briefly describes the GElS conclusions, as stated in Table B-1 of 10 CFR Part 51,

Subpart A, Appendix B, for each of the socioeconomic Category 1 issues:

Public services: Public safety, social services, and tourism and recreation. Impacts to

public safety, social services, and tourism and recreation are expected to be of small

significance at all sites.

Public services: education (license renewal term). Only impacts of small significance are

expected.

Aesthetic impacts (license renewal term). No significant impacts are expected during the

license renewal term.

Aesthetic impacts of transmission lines (license renewal term). No significant impacts

during the license renewal term.

No new and significant information was identified for these issues during the review. Therefore,

it is expected that there would be no impacts during the renewal term beyond those discussed

in the GELS.

Table 4-6 lists the Category 1 socioeconomic issues, which require plant-specific analysis, and

an environmental justice impact analysis, that was not addressed in the GELS.

Table 4-7 lists the Category 2 socioeconomic issues, which require plant-specific analysis, and

an environmental justice impact analysis, which was not addressed in the GElS.

July 2010 4-19 NUREG-1437, Supplement 41
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Table 4-7. Category 2 Issues Applicable to Socioeconomics and Environmental Justice

During the Renewal Term

ISSUE-10 CFR Part 51, Subpart A, 10 CFR 51.53(c)(3)(ii)

Appendix B, Table B-I GElS Section 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 GElS and the associated revision to

10 CFR Part 51 were prepared. Therefore, environmental justice must be addressed in plant-specific reviews.

4.9.2 Housing Impacts

According to the 2000 Census, approximately 18,318 people lived within 20 mi of CNS, which

equates to a population density of 15 persons per square mile (mi2) (NPPD, 2008a). The NRC

staff defined in the GElS this density to be most sparse (less than 40 persons per mi 2 and no

community with 25,000 or more persons within 20 mi) and determined it to be Category 1.

Approximately 160,211 people live within 50 mi of CNS (NPPD, 2008a). This equates to a

population density of 20 persons per mi 2. Applying the GElS proximity measures, CNS is

classified as proximity Category 1 (no city with 100,000 or more persons and less than

50 persons per mi 2 within 50 mi). Therefore, according to the sparseness and proximity matrix

presented in the GELS, rankings of sparseness Category 1 and proximity Category 1 result in

the conclusion that CNS is located in a low population area.

Since Nemaha, Otoe, Richardson, and Atchison counties are not subject to growth control

measures that would limit housing development, any changes in employment at CNS would

have little noticeable effect on housing availability in these counties. Since NPPD has no plans

to add non-outage employees during the license renewal period, employment levels at CNS

would remain relatively constant with no additional demand for permanent housing during the

license renewal term. Based on this information, there would be no additional impact on housing

during the license renewal term.

4.9.3 Public Services: Public Utilities

In Section 4.7.4 of the GELS, the staff defined impacts on public utility services as SMALL if the

existing infrastructure could accommodate any plant-related demand without a noticeable effect

on the level of service. Impacts are defined as MODERATE if the demand for service or use of

the infrastructure is sizeable and would noticeably decrease the level of service or require

additional resources to maintain the level of service. Impacts are defined as LARGE when new

programs, upgraded or new facilities, or substantial additional staff is needed because of

plant-related demand. In the absence of new and significant information to the contrary, the only

impacts on public utilities that could be significant would be impacts on public water supplies.

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Analysis of impacts on the public water systems considered both plant demand and

plant-related population growth. Section 2.1.7 describes the permitted withdrawal rate and

actual use of water for reactor cooling at CNS.

Since NPPD has no plans to add non-outage employees during the license renewal period,

employment levels at CNS would remain relatively unchanged with no additional demand for

public water services. Public water systems in the region would be adequate to meet the

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

additional impact to public water services during the license renewal term.

4.9.4 Offsite Land Use - License Renewal Period

Offsite land use during the license renewal term is a Category 2 issue (10 CFR Part 51,

Subpart A, Appendix B, Table B-1). Table B-1 of 10 CFR Part 51, Subpart A, Appendix B notes

that "significant changes in land use may be associated with population and tax revenue

changes resulting from license renewal."

In Section 4.7.4 of the GELS, the NRC staff defines the magnitude of land-use changes as a

result of plant operation during the license renewal term as SMALL when there will be little new

development and minimal changes to an area's land-use pattern, as MODERATE when there

will be considerable new development and some changes to the land-use pattern, and LARGE

when there will be large-scale new development and major changes in the land-use pattern.

Tax revenue can affect land use because it enables local jurisdictions to provide the public

services (e.g., transportation and utilities) necessary to support development. Section 4.7.4.1 of

the GElS states that the assessment of tax-driven land-use impacts during the license renewal

term should consider: (1) the size of the plant's tax payments relative to the community's total

revenues, (2) the nature of the community's existing land-use pattern, and (3) the extent to

which the community already has public services in place to support and guide development. If

the plant's tax payments are projected to be small relative to the community's total revenue, tax

driven land-use changes during the plant's license renewal term would be SMALL, especially

where the community has pre-established patterns of development and'has provided public

services to support and guide development. Section 4.7.2.1 of the GElS states that if new tax

payments are less than 10 percent of the taxing jurisdiction's revenue, the significance level

would be SMALL. If tax payments are 10 to 20 percent of the community's total revenue, new

tax-driven land-use changes would be MODERATE. If tax payments are greater than 20 percent

of the community's total revenue, new tax-driven land-use changes would be LARGE. This

would be especially true where the community has no pre-established pattern of development or

has limited public services available to support and guide development.

4.9.4.1 Population-Related Impacts

Since NPPD has no plans to add non-outage employees during the license renewal period,

there would be no plant operations-driven population increase in the vicinity of CNS. Therefore,

there would be no additional population-related offsite land use impacts during the license

renewal term.

4.9.4.2 Tax Revenue-Related Impacts

As previously discussed in Chapter 2, NPPD makes annual payments in lieu of taxes (PILOT) to

the municipalities and 91 counties in Nebraska where NPPD sells power. Since NPPD started

making payments to local jurisdictions, population levels and land use conditions have not

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changed significantly, which might indicate that these tax revenues have had little or no affect

on land use activities within the county. PILOT payments are based upon the gross revenues

NPPD receives from electricity sales in the 91 counties, regardless of where the power is

generated. The magnitude of the PILOT payments relative to the county's total revenues is not

relevant in assessing tax revenue-related offsite land use impacts since NPPD is responsible for

producing and distributing electricity and PILOT payments even if the CNS does not produce

electricity or the operating license is not renewed.

Since NPPD has no plans to add non-outage employees during the license renewal period,

employment levels at CNS would remain relatively unchanged. Annual PILOT payments would

also remain relatively unchanged throughout the license renewal period. Based on this

information, there would be no additional tax-revenue-related offsite land use impacts during the

license renewal term.

4.9.5 Public Services: Transportation Impacts

Table B-1 of Appendix B to Subpart A of 10 CFR Part 51 states the following:

Transportation impacts (level of service) of highway traffic generated...during the

term of the renewed license are generally expected to be of SMALL significance.

However, the increase in traffic associated with additional workers and the local

road and traffic control conditions may lead to impacts of MODERATE or LARGE

significance at some sites.

All applicants are required by 10 CFR 51.53(c)(3)(ii)(J) to assess the impacts of highway traffic

generated by the proposed project on the level of service of local highways during the term of

the renewed license and during refurbishment activities.

Since NPPD has no plans to add non-outage employees during the license renewal period and

does not plan any refurbishment activities, there would be no noticeable change in traffic

volume and levels of service on roadways in the vicinity of CNS; therefore, there would be no

additional transportation impacts during the license renewal term.

4.9.6 Historic and Archaeological Resources

The National Historic Preservation Act (NHPA) requires Federal agencies to consider the effects

of their undertakings on historic properties. Historic properties are defined as resources that are

eligible for listing on the National Register of Historic Places (NRHP). The criteria for eligibility

are listed in 36 CFR 60.4 and include: (1) association with significant events in history;

(2) association with the lives of persons significant in the past; (3) embodies distinctive

characteristics of type, period, or construction; and (4) sites or places that have yielded or are

likely to yield important information (ACHP, 2009). The historic preservation review process

(Section 106 of the NHPA) is outlined in regulations issued by the Advisory Council on Historic

Preservation in 36 CFR Part 800.

The issuance of a renewed operating license for a nuclear power plant is a Federal action that

could affect historic properties on or near the nuclear plant site and transmission lines. In

accordance with the provisions of the NHPA, the NRC is required to make a reasonable effort to

identify historic properties included in or eligible for inclusion in the NRHP in the area of

potential effect (APE). The APE for license renewal is the nuclear power plant site, transmission

lines, and immediate environs. If historic properties are present, the NRC is required to contact

the State Historic Preservation Office (SHPO), assess the potential impact, and resolve any

NUREG-1437, Supplement 41 4-22 July 2010
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possible adverse effects of the undertaking (license renewal) on historic properties. The NRC is

also required to notify the SHPO if historic properties would not be affected by license renewal

or if no historic properties are present.

NPPD contacted the Missouri SHPO and the Nebraska State Historical Society (NSHS) in

January 2008, requesting information on historic and archaeological resources in the vicinity of

CNS and described the proposed action (license renewal) (NPPD, 2008a). The NSHS

responded in February 2008 that the proposed action (license renewal) would have no effect on

historic structures (NPPD, 2008a). The Missouri SHPO requested that an "historic architectural

and archaeological survey" be conducted at CNS (NPPD, 2008a). In response to the Missouri

SHPO's request, NPPD conducted a survey and submitted a Phase 1A Literature Review and

Archeological Sensitivity Assessment along with NPPD's Cultural Resources Protection Plan in

May 2008 (NPPD, 2008a). In June 2008, the Missouri SHPO concurred with the conclusions in

NPPD's archaeological assessment (NPPD, 2008a).

In accordance with 36 CFR 800.8(c), the NRC contacted the Missouri SHPO (NRC, 2008a), the

NSHS (NRC, 2008b), the Advisory Council on Historic Preservation (NRC, 2008c), and

Federally-recognized American Indian Tribes to initiate Section 106 consultation. These letters

are presented in Appendix D.

In April 2007 and March 2008, NPPD contracted with Enercon Services, Inc. to conduct an

"historic architectural and archaeological survey" of the CNS site. A report, "Phase 1A Literature

Review and Archeological Sensitivity Assessment of the Cooper Nuclear Station, Nemaha

County, Nebraska, Atchison County Missouri," prepared by Enercon Services for NPPD did not

conduct any subsurface testing. The survey determined that 55 ac of the site were heavily

disturbed by construction of the CNS facility and some of the lands have and continue to be

farmed. The study identified one prehistoric site (Whitten) adjacent to the CNS property, two

prehistoric lithic scatters, and three former house (farm) sites. All surface structures associated

with the earlier house sites have been demolished; however, remnants of these buildings

remain as historic archaeological sites and could be eligible for inclusion to the NRHP under

Criteria A. Additionally, Lewis and Clark were known to have camped in the vicinity of CNS. The

exact location of this campsite has never been determined.

As discussed in Section 2.2.10, a search of the NSHS site files identified no previously recorded

historic properties on the CNS property; however, the Enercon report indicates that portions of

the Whitten site could extend onto CNS property. A formal archaeological survey of the CNS

site has not been completed; however, a number of archaeological and historical research

studies have been conducted in both Nemaha and Atchison counties. These surveys identified

several historic and archaeological sites within a 6-mi radius of CNS. The resources found

during these surveys tend to occur on the same landforms that occur on the CNS property

suggesting that there is a potential for deeply buried undiscovered historic and archaeological

resources on the plant property.

The Whitten archeological site (25NH4) is a prehistoric mound (Plains Woodland) site

excavated in the late 1930s. It is unclear from the archaeological site description if the Whitten

site was located entirely on private property north of CNS, or if the site extended onto the CNS

property. Human remains, grave goods, and other artifacts were recovered from this site.

Artifacts recovered from the site suggest an affiliation with the Sterns Creek variant of the Plains

Woodland tradition (Gibbon and Ames, 1998). The NSHS site form noted that some of the

remains were sent to the U.S. National Museum in accordance with a Works Progress

Administration contract (NSHS, 1937). Historic records indicate that the entire bluff was

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surveyed from CNS property to the city of Nemaha. During Enercon's 2007 and 2008

walkovers, no additional burial mounds were identified; however, there remains a potential for

additional prehistoric sites (camp sites) to be in the area. During NRC's walkover survey, the

staff noted the presence of prehistoric and historic artifacts on CNS property.

The William Dawson House (Site # NH0O-69), located in the southwest corner of the site near

the bluff, was recorded in Nebraska historic archives but not included on the NRHP. The

Dawson House was torn down shortly after it was recorded. No visible remnants of the house

remain; however, subsurface portions of the house could remain.

During the environmental site visit, the NRC staff discovered that archaeological surveys were

not conducted prior to the construction of the firing range. At that time, NPPD did not have

corporate procedures (Cultural Resources Protection Plan) in place. In preparation for license

renewal, NPPD contracted with Enercon to survey the site and established a Cultural

Resources Protection Plan to acknowledge and improve the protection of archaeological

resources at CNS. In its plan, NPPD calls for surveys to be conducted by a qualified

archaeologist in areas deemed sensitive prior to work commencing.

In addition, during the construction of the independent spent fuel storage installation (ISFSI)

pad, soil was removed from the top of the bluff (with consent of the landowner). Archaeological

surveys were not conducted prior to this activity. NPPD has since taken corrective actions to

ensure that all aspects of its Cultural Resources Protection Plan are followed.

NPPD currently has no planned changes or ground disturbing activities associated with license

renewal at CNS; however, given the high potential for the discovery of additional historic and

archaeological resources at the CNS site, NPPD needs to ensure that these resources are

considered during future plant operations and maintenance activities. CNS is situated in an area

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

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

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

Based on a review of NSHS files, archaeological surveys, assessments, and other information,

the potential impacts of continued operations and maintenance on historic and archaeological

resources at CNS would be SMALL. NPPD could further reduce potential impacts to historic and

archaeological resources located at the CNS by training NPPD staff in the Section 106

consultation process and cultural awareness training to ensure that informed decisions are

made prior to any ground disturbing activities. In addition, NPPD could also forward its Cultural

Resources Protection Plan to the NSHS and the Missouri SHPO for review and comment. This

I will ensure that historic and archaeological resources are protected at the CNS site. Any

revisions to the Cultural Resources Protection Plan should be developed in consultation with the

NRC, NSHS, and Missouri SHPO. In addition, lands not surveyed should be investigated by a

qualified archaeologist prior to any ground disturbing activity.

4.9.7 Environmental Justice

Under Executive Order (E.O.) 12898 (59 Federal Register (FR) 7629) as amended by

60 FR 6381, January 30, 1995, Federal agencies are responsible for identifying and addressing

potential disproportionately high and adverse human health and environmental impacts on

minority and low-income populations. In 2004, the Commission issued a Policy Statement on

the Treatment of Environmental Justice Matters in NRC Regulatory and Licensing Actions

(69 FR 52040), which states, "The Commission is committed to the general goals set forth in

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E.O. 12898, and strives to meet those goals as part of its National Environmental Policy Act of

1969 (NEPA) review process."

The Council on Environmental Quality (CEQ) provides the following information in

Environmental Justice: Guidance under the National Environmental Policy Act (NEPA) (1997):

Disproportionately High and Adverse Human Health Effects. When

determining whether human health effects are disproportionately high and

adverse, agencies are to consider the following three factors to the extent

practicable: (a) Whether the health effects, which may be measured in risks and

rates, are significant (as employed by NEPA), or above generally accepted

norms. Adverse health effects may include bodily impairment, infirmity, illness, or

death; (b) Whether the risk or rate of hazard exposure by a minority population,

low-income population, or Indian tribe to an environmental hazard is significant

(as employed by NEPA) and appreciably exceeds or is likely to appreciably

exceed the risk or rate to the general population or other appropriate comparison

group; and (c) Whether health effects occur in a minority population, low-income

population, or Indian tribe affected by cumulative or multiple adverse exposures

from environmental hazards (CEQ, 1997).

Disproportionately High and Adverse Environmental Effects. When

determining whether environmental effects are disproportionately high and

adverse, agencies are to consider the following three factors to the extent

practicable: (a) Whether there is or will be an impact on the natural or physical

environment that significantly (as employed by NEPA) and adversely affects a

minority population, low-income population, or Indian tribe. Such effects may

include ecological, cultural, human health, economic, or social impacts on

minority communities, low-income communities, or Indian tribes when those

impacts are interrelated to impacts on the natural or physical environment;

(b) Whether environmental effects are significant (as employed by NEPA) and

are or may be having an adverse impact on minority populations, low-income

populations, or Indian tribes that appreciably exceeds or is likely to appreciably

exceed those on the general population or other appropriate comparison group;

and (c) Whether the environmental effects occur or would occur in a minority

population, low-income population, or Indian tribe affected by cumulative or

multiple adverse exposures from environmental hazards (CEQ, 1997).

The environmental justice analysis assesses the potential for disproportionately high and

adverse human health or environmental effects on minority and low-income populations that

could result from the operation of CNS during the renewal term. In assessing the impacts, the

following CEQ (1997) definitions of minority individuals and populations and low-income

population were used:

Minority. Individual(s) who are members of the following population groups:

American Indian or Alaskan Native; Asian or Pacific Islander; Black, not of

Hispanic origin; or Hispanic.

Minority populations. Minority populations should be identified where either:

(a) the minority population of the affected area exceeds 50 percent or (b) the

minority population percentage of the affected area is meaningfully greater than

the minority population percentage in the general population or other appropriate

unit of geographic analysis. In identifying minority communities, agencies may

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consider as a community either a group of individuals living in geographic

proximity to one another, or a geographically dispersed/transient set of

individuals (such as migrant workers or Native American), where either type of

group experiences common conditions of environmental exposure or effect. The

selection of the appropriate unit of geographic analysis may be a governing

body's jurisdiction, a neighborhood, census tract, or other similar unit that is to be

chosen so as to not artificially dilute or inflate the affected minority population. A

minority population also exists if there is more than one minority group present

and the minority percentage, as calculated by aggregating all minority persons,

meets one of the above-stated thresholds.

Low-income population. Low-income populations in an affected area are

identified with the annual statistical poverty thresholds from the U.S. Census

Bureau's (USCB) Current Population Reports, Series PB60, on Income and

Poverty.

4.9.7.1 Minority Population in 2000

The 50-mi radius around CNS includes 24 counties with nine in Nebraska, six in Kansas, five in

Iowa, and four in Missouri. The geographic area includes any census block with all or part of its

area within the 50-mi radius. According to 2000 census data, 4.3 percent of the population

(approximately 160,248 individuals) residing within a 50-mi (80 kilometer (km)) radius of CNS

identified themselves as minority individuals. The largest minority group was Hispanic or Latino

(2,295 persons or 1.4 percent), followed by American Indian (2,366 or about 1.5 percent)

(USCB, 2003). About 2.9 percent of the Nemaha County population identified themselves as

minorities, with Hispanic or Latino being the largest minority group (1 percent) followed by some

other race (0.7 percent) (USCB, 2009) (see Table 2.2.8.5-2).

Populations within each state were considered individually and as a four-State geographic area.

A combined or aggregate population of the four-State area was calculated based on these State

populations.

Approximately 370 (individual State method) to 380 (four-State combined method) blocks within

I 50 mi of CNS were determined to have high density minority population percentages that

exceeded the State average by 20 percentage points or more. The largest number of high

density minority blocks was Hispanic or Latino, with 160 (four-State combined) to 170 (individual

State) blocks that exceed the State average by 20 percent or more. The greatest concentrations

of high density minority population blocks are located nearly 50 mi south of CNS in Brown

County, KS, and approximately 30 mi south-southeast of CNS where the

Nebraska-Kansas-Missouri State borders come together. The closest high density minority population is located approximately 10 mi west of CNS, near Nemaha (NPPD, 2008a).

The Sac and Fox and Iowa Indian Reservations straddle the border of Nebraska (Richardson

County) and Kansas (Brown and Doniphan counties). The Kickapoo Indian Reservation is

located south of CNS in Brown County, KS.

Based on 2000 census data, Figure 4-1 (individual State method) and Figure 4-2 (four-State

combined method) show the locations of high density minority blocks within a 50-mi radius of

I CNS.

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Legend 0 5 10 20

r Cooper Nuclear Station State. e 50-Mile Rad. Conte Miles

Aggregate Minority Plus Hispanic Individual States

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

(Individual State) (Source: USCB, 2008)

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Legend 0 5 10 20

* Cooper Nuclear State o SMiles

50-Mile Radius . Counties

Aggregata Minority Plus HK panic Combined States

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

(Combined State) (Source: USCB, 2008)

4.9.7.2 Low-Income Population in 2000

According to 2000 census data, approximately 3,100 families and 16,000 individuals

(approximately 7.3 and 10.1 percent, respectively) residing within a 50-mi radius of CNS were

identified as living below the Federal poverty threshold in 1999 (USCB, 2003). The 1999

Federal poverty threshold was $17,029 for a family of four.

According to census data estimates, the median household income for Nebraska in 2007 was

$47,072, with 11.1 percent of the State population living below the Federal poverty threshold.

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Nemaha County had a lower median household income average ($41,024) and a higher

percentage (13.3 percent) of individuals living below the poverty level when compared to the

State average. Richardson County had the lowest median household income of the four

counties ($36,092) and a higher percentage (13.4 percent) of individuals living below the

poverty level when compared to the State. Otoe County had the highest median household

income ($45,018) and the lowest percentage (9.4 percent) of individuals living below the poverty

level among the four counties (USCB, 2008). Atchinson County, Missouri, had a lower median

household income average ($38,114) than the State and the highest percentage (14 percent) of

individuals living below the poverty level among the four counties. The median household

income for Missouri in 2007 was $45,012, with 13.3 percent of the State population living below

the Federal poverty threshold (USCB, 2009).

Census block groups were considered high density low-income block groups if the percentage

of households below the Federal poverty threshold exceeded the State average by 20 percent

or more. Based on 2000 census data, there were 192 block groups within the 50-mi radius of

CNS that exceeded the State average for low-income households by 20 percent or more. The

majority of census block groups with low-income populations were located in two counties, Page

County and Nodaway County in Missouri (NPPD, 2008a). Figure 4-3 (individual State method)

and Figure 4-4 (four-State combined method) show the location of high density low-income

census block groups within a 50-mi radius of CNS.

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Environmental Impacts of Operation

Legend 0 5 10 20

SCooper Nuclear Station States; ....... i Co nti•Miles •

50-Mile Rad,us Counfists

Pove•ry Individual State.

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

(Individual State) (Source: USCB, 2008)

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Legend 0 5 10 20

* Coooor Nuclear Station States 111;M

50-kde RdiusC-t-Miles

~IPovoqj Combined tae

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

(Combined State) (Source: USCB, 2008)

The NRC addresses environmental justice matters for license renewal through: (1) identification

of minority and low-income populations that may be affected by the proposed license renewal,

and (2) examining any potential human health or environmental effects on these populations to

determine if these effects may be disproportionately high and adverse.

The discussion and figures above indentify the location of minority and low-income populations

residing within a 50-mi (80-kin) radius of CNS. This area of impact is consistent with the impact

analysis for public and occupational health and safety, which also considers the radiological

effects on populations located within a 50-mi (80-kin) radius of the plant. As previously

July 2010 4-31 NUREG-1437, Supplement 41
Environmental Impacts of Operation

discussed for the other resource areas in Chapter 4, the analyses of impacts for all

environmental resource areas indicated that the impact from license renewal would be SMALL.

Socioeconomic conditions at the Sac and Fox and Iowa Reservation would not change as a

result of renewing the CNS operating license. Employment levels at CNS would remain

relatively unchanged, so direct and indirect employment opportunities caused by CNS would

remain unchanged. The Sac and Fox and Iowa Reservations also receive no income from taxes

paid by NPPD to the State of Nebraska. Therefore, there would be no additional socioeconomic

impact to minority and low-income populations during the license renewal term beyond what is

currently being experienced.

Potential impacts to minority and low-income populations would mostly consist of radiological

effects; however, radiation doses from continued operations associated with this license

renewal are expected to continue at current levels, and would remain within regulatory limits.

Chapter 5 discusses the environmental impacts from postulated accidents that might occur

during the license renewal term, which include both design basis and severe accidents. In both

cases, the Commission has generically determined that impacts associated with such accidents

are SMALL because nuclear plants are designed to successfully withstand design basis

accidents, and that any risk associated with severe accidents were also SMALL.

Therefore, based on this information and the analysis of human health and environmental

impacts presented in Chapters 4 and 5, there would be no disproportionately high and adverse

impacts to minority and low-income populations from the continued operation of CNS during the

license renewal term.

4.9.7.3 Analysis of Impacts

Consistent with the impact analysis for the public and occupational health and safety, the

affected populations are defined as minority and low-income populations who reside within a

50-mi radius of CNS. Based on the analysis of environmental health and safety impacts

presented in Chapter 4 of this SEIS for other resource areas, there would be no

disproportionately high and adverse impacts to minority and low-income populations from the

continued operation of CNS during the license renewal period.

The NRC also analyzed the risk of radiological exposure through the consumption patterns of

special pathway receptors, including subsistence consumption of fish, native vegetation, surface

waters, sediments, and local produce; absorption of contaminants in sediments through the

skin; and inhalation of plant materials. The special pathway receptors analysis is important to

the environmental justice analysis because consumption patterns may reflect the traditional or

cultural practices of minority and low-income populations in the area. This analysis is presented

below.

4.9.7.4 Subsistence Consumption of Fish and Wildlife

Section 4-4 of E.O. 12898 (1994) directs Federal agencies, whenever practical and appropriate,

to collect and analyze information on the consumption patterns of populations that rely

principally on fish and wildlife for subsistence and to communicate the risks of these

consumption patterns to the public. The NRC considered whether or not there were any means

for minority or low-income populations to be disproportionately affected by examining impacts to

American Indian, Hispanic, and other traditional lifestyle special pathway receptors. Special

pathways that took into account the levels of contaminants in native vegetation, crops, soils and

sediments, surface water, fish, and game animals in the vicinity of CNS were considered.

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NPPD has an ongoing comprehensive REMP at CNS that assesses the radiological impact of

site operations on the environment. Radiological environmental monitoring began at CNS in

1971 before the plant became operational. The REMP program monitors radiation levels in air,

terrestrial, and aquatic environments. All samples are collected by NPPD personnel and are

shipped to a laboratory for analysis.

To assess the radiological impact of the plant on the environment, the monitoring program at

CNS uses indicator-control sampling. Samples are collected at nearby indicator locations

downwind and downstream from the plant and at distant control locations upwind and upstream

from the plant. A plant effect would be indicated if the radiation level at an indicator location was

significantly larger than at the control location. The difference would also have to be greater

than could be accounted for by typical fluctuations in radiation levels arising from other

naturally-occurring sources.

Samples are collected from the aquatic and terrestrial pathways in the vicinity of CNS. The

aquatic pathways include fish, Missouri River surface water, ground water, and shoreline

sediment. The terrestrial pathways include airborne particulates, milk and food product garden

(leaf) vegetation, and direct radiation. During 2007, analyses performed on collected samples of

environmental media showed no significant or measurable radiological impact from CNS

operations (NPPD, 2008a)

Aquatic sampling at CNS consists of semi-annual upstream and downstream collections of fish

and shoreline sediments. All samples are analyzed for gamma-emitting isotopes. River water is

collected monthly at two locations, one upstream of the plant and one downstream. Quarterly

composites are analyzed for tritium. All results were below the required lower limit of detection

(NPPD, 2008a).

Sediment samples collected during June and October 2007 were analyzed by gamma

spectrometry. A number of naturally occurring radionuclides were detected in these samples.

Naturally occurring potassium-40 and thorium-228 were observed in all samples. All other

gamma emitters were below their detection limits (NPPD, 2008a).

Eight samples of fish were collected during the summer and fall of 2007. A middle-top feeding

fish (carp) and a bottom feeding fish (catfish) were collected in June and October. These

samples were analyzed by gamma ray spectroscopy. Only naturally occurring potassium-40

was detected (NPPD, 2008a).

According to the 2007 CNS REMP, 17 milk samples from the nearest producers were collected

and analyzed by gamma ray spectroscopy and for low-level iodine-131 by radiochemical

separation. Naturally occurring potassium-40 was measured in all samples. Naturally occurring

thorium-228 was measured in one sample. All other gamma emitters were below their detection

levels. Four milk samples were collected from other producers. Naturally occurring

potassium-40 was detected in all four samples. All other gamma emitters were below their

detection levels (NPPD, 2008a).

Ground water was collected from two stations quarterly and analyzed for tritium and for gamma

emitting radionuclides. One station is located 0.15 mi from the plant and another station 25.8 mi

from the plant. Naturally occurring potassium-40 was detected in 2 of 24 samples analyzed.

Naturally occurring thorium-228 was detected in 2 of 24 samples analyzed. All other gamma

emitters were below their detection levels.

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There were 26 broadleaf vegetation samples collected from June through September from three

locations during 2007. The samples were analyzed by gamma ray spectroscopy and for

low-level iodine-131 by radiochemical separation. Beryllium-7, which is produced continuously

in the upper atmosphere by cosmic radiation, was measured in 24 of 26 samples analyzed.

Naturally occurring potassium-40 was measured in all 26 samples analyzed. All other gamma

emitters were below their detection levels (NPPD, 2008a).

The results of the CNS 2007 REMP sampling demonstrate that the routine operation at CNS

has had no significant or measurable radiological impact on the environment. No elevated

radiation levels were detected in the offsite environment as a result of plant operations and the

storage of radioactive waste. The results of the REMP continue to demonstrate that the

operation of CNS did not result in a significant measurable dose to a member of the general

population or adversely impact the environment as a result of radiological effluents. The REMP

continues to demonstrate that the dose to a member of the public from the operation of CNS

remains significantly below the Federally required dose limits specified in 10 CFR Part 20,

10 CFR Part 50, and 40 CFR Part 190.

Based on recent monitoring results, concentrations of contaminants in native leafy vegetation,

sediments, surface water, and fish in areas surrounding CNS have been quite low (at or near

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

disproportionately high and adverse human health impacts would be expected in special

pathway receptor populations in the region as a result of subsistence consumption of fish and

wildlife.

4.10 EVALUATION OF NEW AND POTENTIALLY SIGNIFICANT INFORMATION

New and significant information is: (1) information that identifies a significant environmental

issue not covered in the GElS and codified in Table B-1 of 10 CFR Part 51, Subpart A,

Appendix B, or (2) information that was not considered in the analyses summarized in the GElS

and that leads to an impact finding that is different from the finding presented in the GElS and

codified in 10 CFR Part 51.

In preparing to submit its application to renew the CNS operating license, NPPD developed a

process to ensure that information not addressed in or available during the GElS evaluation

regarding the environmental impacts of license renewal for CNS would be properly reviewed

before submitting the ER, and to ensure that such new and potentially significant information

would be identified, reviewed, and assessed during the NRC review period. NPPD reviewed the

Category 1 issues that appear in Table B-1 of 10 CFR Part 51, Subpart A, Appendix B, to verify

that the conclusions of the GElS remained valid with respect to CNS. This review was

performed by personnel from CNS and its support organization that were familiar with NEPA

issues and the scientific disciplines involved in the preparation of a license renewal ER. The

NRC also has a process for identifying new and significant information. That process is

described in detail in NUREG-1 555, Supplement 1, Standard Review Plans for Environmental

Reviews for Nuclear Power Plants, Supplement 1: Operating License Renewal (NRC, 2000).

The search for new information includes: (1) review of an applicant's ER and the process for

discovering and evaluating the significance of new information; (2) review of records of public

comments; (3) review of environmental quality standards and regulations; (4) coordination with

Federal, State, and local environmental protection and resource agencies; and (5) review of the

technical literature. New information discovered by the NRC staff is evaluated for significance

using the criteria set forth in the GElS. For Category 1 issues where new and significant

information is identified, reconsideration of the conclusions for those issues is limited in scope to

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the assessment of the relevant new and significant information; the scope of the assessment

does not include other facets of the issue that are not affected by the new information.

The NRC staff has not identified any new and significant information on environmental issues

listed in Table B-1 of 10 CFR Part 51, Subpart A, Appendix B, related to the operation of CNS

during the period of license extension. The NRC staff also determined that information provided

during the public comment period did not identify any new issues that require site-specific

assessment. The NRC staff reviewed the discussion of environmental impacts in the GElS

(NRC, 1996) and conducted its own independent review (including the public scoping meetings

held in February 2009) to identify new and significant information.

4.11 CUMULATIVE IMPACTS

The NRC staff considered potential cumulative impacts in the environmental analysis of

continued operation of CNS. For the purposes of this analysis, past actions are those related to

the resources at the time of the power plant licensing and construction. Present actions are

those related to the resources at the time of current operation of the power plant, and future

actions are considered to be those that are reasonably foreseeable through the end of plant

operation including the period of extended operation. Therefore, the analysis considers potential

impacts through the end of the current license terms as well as the 20-year renewal license

term. The geographic area over which past, present, and future actions would occur is

dependent on the type of action considered and is described below for each impact area.

The impacts of the proposed action, as described in Sections 4.1-4.9, are combined with other

past, present, and reasonably foreseeable future actions regardless of what agency (Federal or

non-Federal) or person undertakes such other actions.

4.11.1 Cumulative Impacts on Water Resources

The NRC staff divided the description and discussion of water resources in previous sections

into ground water and surface water issues in order to follow the regulatory structure presented

in 10 CFR Part 51 (2009). Hydrologic conditions at CNS and elsewhere within the Missouri

River Valley, however, indicate a hydraulic connection between surface and ground water,

particularly between the Missouri River and the alluvial aquifer underlying the valley. This

connection reveals the possible impact of reduced river flow on ground water levels.

NPPD (2008a) reviewed well records and identified 1,400 registered wells within the Nemaha

River Basin, which includes the Missouri River below its confluence with the Platte River. Of the

wells identified, very few are close to CNS. The NGPC installed three wells about 1.5 mi

(2.4 km) south of CNS, and the city of Auburn, Nebraska, has a public water supply well about

1.9 mi (3 km) south. NPPD (2008a) also identified some local shallow farm wells within 2 mi

(3.2 km) of the plant property. All of the water supply wells in the area are completed either in

the Missouri River Valley Aquifer or Glacial Drift Aquifer, which are under unconfined conditions

and in hydraulic contact with the Missouri River.

Enercon conducted an operations study of the CNS potable wells which showed an equilibrium

radius of influence of between 100 to 1,250 ft (46 to 381 meters (m)) from each well. Enercon's

analysis of the drawdown data from the study indicated the radius of influence of CNS's wells

does not extend outside the CNS property boundary. Because all the CNS wells are in hydraulic

connection with the Missouri River, recharge from the river is likely induced by pumping

operations. The total maximum pumping rate at CNS of over 1,500 gpm (5,678 liters per minute)

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is less than 1 percent of the average flow in the river. Likewise, the influence of offsite pumping

should have no measurable effect on ground water levels onsite. Because the cumulative

effects of pumping ground water on river flow and vice versa are insignificant, the cumulative

impact on water resources in the CNS area is SMALL.

4.11.2 Cumulative Impacts on Electromagnetic Fields and Thermophilic Microbiological

Organisms

The continued operation of CNS has a low risk of causing outbreaks from thermophilic

microbiological organisms associated with thermal discharges. Available data compiled by the

CDC into biannual reports for the years 1999 to 2006 (CDC, 2000), (CDC, 2002), (CDC, 2004),

(CDC, 2006) indicates no occurrence of the waterborne disease outbreaks in the State of

Nebraska resulting from exposure to the thermophilic microbiological organisms Naegleria

fowleri and Pseudomonas aeruginosa due to the operation of CNS.

As part of its evaluation of cumulative impacts, the NRC staff also considered the effects of

thermal discharges from other facilities on the Missouri River, located within 1 mi upstream of

CNS, that are also producing thermal effluents. Such facilities could promote the growth of

thermophilic microbiological organisms. The NRC staff did not find any such facilities.

Potential cumulative effects of climate change on the Missouri River basin and local climate,

whether or not from natural cycles or anthropogenic activities, could result in a variety of

changes to the surface and ground water resources in the Missouri River basin. Nebraska is a

part of the Great Plains Region. As projected in the "Global Climate Change Impacts in the

United States" report by the USGCRP (2009), the temperatures in southeastern Nebraska,

where CNS is located, are expected to rise 6°F (-14'C) by 2080-2099 at minimum and

maximum over 10°F (5.6°C), causing more frequent extreme weather events. Increases in

average annual temperatures, higher probabilities of extreme heat events, and higher

occurrences of extreme rainfall (intense rainfall or drought) could increase Missouri River

temperatures and cause degradation of the water supply and its quality. Such conditions could

support the proliferation of pathogenic organisms of concern and affect the burden of

water-related diseases. The extent and the magnitude of the climate change on human health

could be significant (IPCC, 2009).

The NRC staff concludes that the thermophilic microbiological organisms are not likely to

present a public health hazard as a result of CNS discharges to the Missouri River. The NRC

staff concludes that the cumulative impacts on public health from thermophilic microbiological organisms from continued operation of CNS during the license renewal period would be SMALL.

The NRC staff determined that the CNS transmission lines are operating within original design

specifications and meet current NESC clearance standards; therefore, the CNS transmission

lines do not detectably affect the overall potential for electric shock from induced currents within

the analysis area. With respect to the chronic effects of electromagnetic fields, although the

GElS finding of "not applicable" is appropriate to CNS, the transmission lines associated with

CNS are not likely to detectably contribute to the regional exposure to extremely low frequency

electromagnetic fields. Therefore, the NRC staff has determined that the cumulative impacts of

continued operation of the CNS transmission lines would be SMALL.

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4.11.3 Cumulative Impacts on Aquatic Resources

This section addresses the direct and indirect effects of license renewal when added to the

aggregate effects of past, present, and reasonably foreseeable future actions (CEQ, 2005). The

direct effects on aquatic resources from an additional 20 years of CNS operation accrue

primarily from impingement, entrainment, and heat shock to natural populations and the

populations on which they depend through predator-prey, competitive, and other interactions.

The cumulative impact is the total effect on the aquatic resources of all actions taken, no matter

who has taken the actions (the second principle of cumulative effects analysis in CEQ, 1997).

The geographic boundary for assessing cumulative aquatic impacts is somewhat variable and

depends on the specific resource, but is generally the lower biological zone of the Missouri

River, which extends from Gavins Point Dam to the confluence with the Mississippi River

(Galat et al., 2005a), (Galat et al., 2005b).

The benchmark for assessing cumulative impacts on aquatic resources takes into account the

pre-operational environment as recommended by the EPA (1999) for its review of NEPA

documents:

Designating existing environmental conditions as a benchmark may focus the

environmental impact assessment too narrowly, overlooking cumulative impacts

of past and present actions or limiting assessment to the proposed action and

future actions. For example, if the current environmental condition were to serve

as the condition for assessing the impacts of relicensing a dam, the analysis

would only identify the marginal environmental changes between the continued

operation of the dam and the existing degraded state of the environment. In this

hypothetical case, the affected environment has been seriously degraded for

more than 50 years with accompanying declines in flows, reductions in fish

stocks, habitat loss, and disruption of hydrologic functions. If the assessment

took into account the full extent of continued impacts, the significance of the

continued operation would more accurately express the state of the environment

and thereby better predict the consequences of relicensing the dam.

Section 2.2.5 presents an overview of the condition of the Missouri River ecosystem and the

history and factors that led to its condition. At present, the Missouri River is a degraded

ecosystem that the National Research Council (NRCC) (2002) has said may be close to or

perhaps past the point of irreparable change. To determine and illustrate the environmental

changes that affect resources in cumulative impact analysis, CEQ (1997) recommends a

conceptual model. We present a simple conceptual model for the Missouri River ecosystem in

Figure 2.2.5-1 that shows how some environmental factors affect aquatic resources.

The NRCC (2002) identified the following man-induced changes in the Missouri River

ecosystem that jeopardize its fundamental natural processes, "the loss of natural flood pulses;

the loss of natural low flows; straightening of stream meanders and the elimination of cut-and-fill

alluviation; losses of natural riparian vegetation; reductions in water temperature variation;

introduction of nonnative species; and extensive bank stabilization and stream channelization."

These changes are due to activities like dam construction that alter flow and water temperature

patterns, amplitude and frequency of natural peak flows used by some species as

environmental cues for biological processes, and sediment transport and deposition. Land use

changes, channelization, and construction of levees and dikes have altered almost 3 million

acres of natural riverine and floodplain habitat. These changes, and more, influence primary

productivity and the energy sources for aquatic communities, alter or eliminate natural habitat

and habitat diversity required to support some species, and change invertebrate communities

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and food webs to fish. The NRCC (2002) found that, "Of the 67 native fish species living along

the mainstream, 51 are now listed as rare, uncommon, or decreasing across all or part of their

ranges" and that one of these fish, the pallid sturgeon, is on the Federal Endangered Species

List.

In addition to these historic impacts, this section focuses on other facilities that withdraw

I Missouri River water and introduced species. CNS directly affects Missouri River aquatic

communities primarily through impingement, entrainment, and heat shock. Other facilities that

withdraw water also impact aquatic communities through at least impingement and entrainment,

and for some, also heat shock. The impact of introduction and stocking of native and introduced

I fish species is also somewhat similar to the impact of CNS, because the effect of a power plant

that impinges and entrains aquatic organisms is somewhat similar to that of a large predator

introduced into an aquatic system.

The number of consumptive and non-consumptive intakes that withdraw water from the Missouri

River is relatively large (Table 4-8). The cumulative stress from this large number of intakes, of

which CNS is one, spread across the length of the river depends on many factors that the NRC

staff cannot quantify, but which may be significant when added to all the other stresses on

aquatic communities.

The States have stocked and released a number of native and introduced game fish into the

Missouri River, primarily for sport fishing. Game fish tend to be predators, which may, through

predation, affect aquatic communities in a manner somewhat similar to impingement and

entrainment. For example, Nelson-Stastny (2004) compiled a list of selected introduced and

native fish species stocked or released into the Missouri River in South Dakota in relation to

their potential as predators of pallid sturgeon (Table 4-9). That author notes that:

South Dakota made several stocking attempts with other fish species to try to

utilize the newly created reservoir habitat in the South Dakota portion of the

Missouri River. The fish species that were previously stocked, but for which

stocking was eventually discontinued, include lake whitefish (Coregonus

clupeaformis), sockeye salmon/kokanee (Oncorhyncus nerka), cutthroat trout

(Oncorhyncus clarki), lake trout (Salvelinus namaycush), Bonneville cisco

(Prosopium gemmiferu), muskellunge (Esox masquinongy), and tiger

muskellunge (Esox lucius x masquinongy). Of these, only lake whitefish and tiger

muskellunge are occasionally sampled either by anglers or in fish population

surveys and these fish are believed to be from original stocking events (i.e., large

adults).

This example is from just one of the States in the Missouri River basin. As with water intakes,

the cumulative stress from all these introductions spread across the length of the river depends

on many factors, which the NRC staff cannot quantify but which may be significant when added

to all the other stresses on aquatic communities.

While the level of impact due to direct and indirect impacts of CNS on aquatic communities is

SMALL, the cumulative impact when combined with all other sources has resulted in the

Missouri River aquatic ecosystem being unstable and has resulted in a LARGE level of impact.

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Table 4-8. Intakes. Number of consumptive and non-consumptive water intakes that withdraw

water from the Missouri River.

Number of Intakes By Location

Lower Itk Total

Reach Boundary Intakes

(RM) Power Municipal Industrial Irrigation Domestic Public

Fort Peck Lake 1,771.60 1 5 101 2 109

Fort Peck 1,547.10 5(1) 4 283(94) 162(14) 1 455(109)

Lake 1,389.90 1 10(5) 6(1) 44(10) 228 (63) 11 300 (79)

Sakakawea

Garrison 1,317.40 6 3 6 77 28 3 123

Lake Oahe 1,072.30 8 (3) 2 179 (12) 21 (6) 8 (2) 218 (23)

Oahe 1,072.20 0

Lake Shame 987.40 3(2) 91(71) 19(4) 2 115 (77)

Big Bend 987.30 0

Lake Francis 841.80 6 72 4 3 85

Case

Fort Randall 836.10 8(4) 8(4)

Lewis and 811.10 2 27(5) 6 2(2) 37(7)

Clark Lake

Gavins Point 734.20 1 33 7 1 42

Sioux City 648.00 2 2 1 42 (3) 2 49 (3)

Omaha 597.20 3 2 1 8 2 5 21

Nebraska City 497.40 2 22 1 25

St. Joseph 374.00 3 4 2 9

Kansas City 249.90 5 4 1 10

Boonville 129.90 3. 1 4

Hermann 0.00 3 3 6

Total 25 57 (11) 20(1) 891 (199) 579(87) 44(4) 1,616 (302)

Above Gavins 7 38(11) 18(1) 786 (196) 569(87) 32(4)

Point

Below Gavins 18 19 2 105(3) 10 12

Point

Numbers in parentheses refer to intakes located on reservation land.

Source: USACE, 2004a, page 3-112

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Table 4-9. Stastny 2004. Native and introduced fish species stocked in South Dakota into the

Missouri River system that are potential predators of pallid sturgeon. Species in this table were

actively managed via stocking or other means in 2004 or had their status, whether native or

nonnative, brought into question by others in litigation.

Stocking Years Stocked in Missouri River

Species Name Common Name Origin Status in South Dakota

Oncorhynchus mykiss rainbow trout I EFS 1951, 56, 57, 64, 68, 69, 19722003

Oncorhynchus Chinook salmon I EFS 1982-2000. 2003

tshawytscha

Salmo trutt brown trout I EFS 1964, 68, 79, 1981-2003

Morone chrysops white bass I EPD 1960-62

Coregonus artedi lake herring I EPD 1984, 88, 90-92

Polyodon spathula paddlefish N NSA* 1974, 76-78, 1985-2003

Osmerus mordax rainbow smelt I EPD**

Notropis hudsonius spottail shiner I EPD 1973-75, 78, 79

Micropterus dolomieu smallmouth bass I EPD 1972, 74, 80, 83-92, 94-98

Esox lucius northern pike PN, N NSA 1957, 58, 71, 82, 83, 85, 86, 88-97

Perca flavescens yellow perch PN, N NSA

Sander vitreum walleye N NSA 1952, 53, 57, 58, 83-98, 2002

Table adapted from Nelson-Stastny (2004, Table 1)

*Paddlefish stocking in the last decade has only been in the Lake Francis Case. An adult population exists in the

Lake Francis Case; however, natural reproduction has not been documented.

Rainbow smelt in the South Dakota portion of the Missouri River originated from fish stocked in Lake Sakakawea in

North Dakota.

Origin as a native (N), introduced (I), or probable native (PN).

Stocking status refers to one of the following:

Established sport fishery - stocking required to maintain (EFS)

Established population - stocking discontinued (EPD)

Native - if stocked, additive to natural reproduction (NSA)

4.11.4 Cumulative Impacts on Terrestrial Resources

This section addresses past, present, and future actions that could result in adverse cumulative

impacts to terrestrial resources, including wildlife populations, upland habitats, wetlands,

riparian zones, invasive species, protected species, and land use. For purposes of this analysis,

the geographic area considered in the evaluation includes the CNS site, including the land on

both the Nebraska and the Missouri sides of the Missouri River, the wetlands on and in the

vicinity of the CNS site, and the 145-mi long (233-km) transmission line corridor identified in

Section 2.1.5 of this report.

Prior to construction of the CNS facilities and before its conversion to cropland, the region

surrounding the CNS property in Nemaha County, Nebraska, and Atchison County, Missouri,

was historically part of a dynamic Missouri River floodplain system, located within the Missouri

alluvial plain ecoregion (USGS, 2001). Historically, the Missouri River meandered across the

width of this relatively flat, 6-mi (10-km) wide alluvial floodplain along the border of eastern

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Nebraska and western Missouri. The CNS facilities are located near the western edge of this

floodplain and adjacent to the western bank of the Missouri River. The vegetation within this

floodplain and its vicinity was historically dominated by tallgrass prairie and wooded wetlands

along the riparian corridors (NGPC, 2005). Before the completion in 1950 of the Federal levee

system along the Missouri River, most of the Missouri River floodplain was subjected to frequent

overbank flooding and much soil deposition occurred over the entire width of the floodplain

(NPPD, 2008a), (USGS, 2001). Wooded wetlands dominate the 239 ac of CNS property on the

Missouri side of the property, both today and prior to conversion of approximately 40 ac of the

property to agriculture (NPPD, 2008a). The Missouri CNS property is also part of the Missouri

alluvial plain ecoregion and much of the wooded wetland habitat historically flooded and

continues to experience overbank flooding from the Missouri River (USGS, 2001).

Historically, over 70 percent of the land encompassing the 145-mi long (233-km) transmission

line corridor was comprised primarily of prairie grasses of the tallgrass prairie ecoregion

(NPPD, 2008a), (NGPC, 2005). The remaining 30 percent of the land traversed by the

transmission line corridor was historically comprised of numerous narrow stream valleys with

woody vegetation and shallow intermittent streams with small pockets of wetlands

(NPPD, 2008a). The western half of the transmission line corridor traverses the Rainwater Basin

Plains and historically contained the largest concentrations of natural wetlands found in

Nebraska. Most of these wetlands have now been drained and converted to cropland and the

historic prairie grass regions in the counties surrounding the transmission line corridor have

likewise been converted to cropland (NGPC, 2005), (USGS, 2001). Most of the noted stream

valleys were too steep or too saturated to allow agriculture and still remain vegetated.

Currently, over 97 percent of the land in Nemaha County, Nebrasca, is used for agriculture. In

the adjacent Richardson County and Otoe County in Nebraska, and Atchison County in

Missouri, over 90 percent of the land on average is used for agriculture. Very little residential,

commercial, or industrial development has occurred in the counties surrounding the CNS site,

and cumulative impacts from such types of development are considered minor.

Current land use on the Nebraska CNS property outside of the actual power plant facilities

reflects the regional agricultural use. Approximately 900 ac (364 hectares (ha)) of the 1,120-ac

(453-ha) CNS site is used for agriculture (NPPD, 2008a). Much of the 55 ac (22 ha) of land

where the CNS facilities have been constructed was cropland prior to construction of the facility,

so disturbance to wildlife habitat had occurred prior to construction of CNS. Construction on

some of the CNS facility led to the loss of riparian habitat along the shoreline, as well as the loss

of some wetlands habitat, which may have impacted wildlife habitat and water quality. NPPD

was recently required by the USACE to restore approximately 1.5 ac (0.6 ha) of disturbed

wetlands habitat on a 55-ac (22-ha) parcel of ground as mitigation for NPPD filling in other

disturbed wetlands for construction of CNS parking facilities.

Surface water drainage patterns have changed on the Nebraska CNS property as a result of

construction of the Federal levee system and from construction of the CNS facility. A dike and

ditch system was created on the Nebraska side of the CNS site during initial construction of the

facilities to protect them from flooding events of the Missouri River (NPPD, 2008a). Over 120 ac

(49 ha) of the CNS site on the Nebraska side contain wooded, scrub-shrub, and emergent

wetlands, riparian habitat along the Missouri River, and several small intermittent streams

(NPPD, 2008a). Construction of the ditch, dike, and levee systems on the CNS site have in

some cases led to additional flooding on portions of the farm fields, forested areas, and these

wetland areas. The intermittent streams and some surface water drains south into the adjacent

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USACE Langdon Bend Wetlands Restoration Project, which may benefit wetlands restoration

on the USACE site (NDNR, 2009) (USACE, 2004b).

Approximately 40 ac (16 ha) of the 239-ac (97-ha) CNS property on the Missouri side are

cropland, and the remaining acres are primarily wooded wetlands. Two transmission line

corridors that are not in scope cut through this land and contain emergent vegetation. The

Federal levee is located along the eastern border of this land, and reduces the threat of flooding

of the farm fields beyond the CNS property while retaining more water on the CNS property.

This CNS property is still subject to occasional overbank flooding, as evidenced by water marks

located several feet up on the trunks of trees. Thus, some flooding events on this land may be

similar in degree of inundation to historic flooding events, helping to maintain this area as a

bottomland hardwood, forested wetland._A conservation deed restriction has been placed upon

the 239 ac of land located on the Missouri side of the river to provide for long-term protection of

this land from any development as well as agricultural production. A pair of bald eagles has

been actively nesting on this property for the past several years (NPPD, 2008a).

Several exotic invasive plant species are located along the riverbank or in the vicinity of the

CNS site, and include purple loosestrife (Lythrum salicaria), reed canary grass (Phalaris

arundinacea), and the common reed (Phragmites australis) (NRCS, 2007), (NDA, 2008). NPPD

does not manage invasive vegetative species on the CNS site; therefore, a potential exists for

these invasive species to increase in population on the CNS site and compete with native

vegetation for resources and degrade areas of terrestrial habitat. Invasive species may also be

introduced on the associated transmission line ROW, with potentially similar impacts.

The land traversed by the transmission line corridor and most of the land in the surrounding

counties has been converted primarily from prairie grasses to cropland. There is currently less

than 2 percent remaining of the historic prairie grass habitat in Nebraska (NGPC, 2005),

(USGS, 2001). Conversion from prairie grassland to cropland will affect wildlife species

composition and behavior, and may have a cumulative adverse impact on nutrient discharges

into the Missouri River and its tributaries. Farming occurs under the transmission lines and

immediately adjacent to the transmission line poles, so little land is lost from agricultural

production. Most of the narrow stream valleys now traversed by the transmission line corridor

remain as vegetated riparian corridors annually maintained by NPPD, primarily as scrub-shrub

wooded areas (NPPD, 2008a). ROW maintenance of these riparian corridors has likely had

some minor impacts in the past and is likely to have present and future impacts on these areas

from their conversion from primarily forested riparian communities to scrub-shrub riparian

communities; however, any future maintenance activities are estimated to be minor based on

NPPD's plan to conduct only necessary clearing to prevent obstruction of the lines.

NPPD has consulted with the USFWS to address the potential risk of bird collisions with NPPD

transmission line NPPD TL3502 which crosses the Platte River near the end of the CNS

transmission line corridor, approximately 4 mi (6 km) east of Grand Island, Nebraska. The

Federally-endangered whooping crane (Grus americana) and interior least tern (Stema

antillarum athalassos), and the Federally-threatened piping plover (Charadrius melodus) use the

Platte River and associated wetlands around Grand Island for different portions of their life cycle

(e.g., for migration, resting, feeding, and nesting) and risk collisions with the NPPD transmission

line. The USFWS has indicated that collisions with transmission lines are the main cause of

whooping crane mortality during their migrations (USFWS, 2009a); however, there are no data

to indicate that transmission line NPPD TL3502 has caused any injury or mortality to whooping

cranes, least terns, piping plovers, or to other species of Federally-protected migratory birds

where the transmission line crosses the Platte River. On May 8, 2009, the NPPD informed the

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USFWS that NPPD had agreed to mark that portion of the NPPD transmission line that crosses

the Platte River with bird flight diverters to increase the visibility of the transmission line and

reduce the risk of collisions (NPPD, 2009b). The USFWS replied to NPPD on June 8, 2009,

informing them that NPPD had satisfactorily addressed the concerns of the USFWS regarding

bird collisions (USFWS, 2009b). This voluntary mitigation measure by NPPD will help to reduce

current and future potential impacts to whooping cranes, interior lest terns, piping plovers, and

other migratory birds that use the Platte River and associated wetlands of the Rainwater Basin

Wetland Management District (USFWS, 2009c).

The Missouri River ecosystem has been dramatically transformed since the beginning of the

20th century. Historically, the Missouri River was free-flowing with regular overbank flooding

along its entire length, and the channel meandered across the entire floodplain. The

construction of seven dams upriver from CNS, bank stabilization, channelization of the river for

improved navigation by barge traffic, and a levee and dike system constructed along most of the

entire length of the floodplain have led to significant changes to the terrestrial habitat of the

ecosystem. There has also been a reduction of the amount and type of deciduous vegetation,

grasslands, and wetlands present within the floodplain. Within the Missouri River itself, there

has also been a reduction in the number of river islands (89 percent), a reduction in the surface

area of these islands (98 percent), and a reduction in the number of sandbars (97 percent)

along the river (NPPD, 2008a). With the implementation of Federal aquatic and terrestrial

habitat restoration projects along the entire Missouri River ecosystem and the adjacent USACE

Langdon Bend Wetlands Restoration Project, restoration of Missouri River terrestrial habitat is

beginning to improve ecological conditions from their current state (USACE, 2004b).

Agriculture continues to be the overwhelming dominant land use in the region and with a

declining human population in Nemaha County, additional impacts from new residential,

commercial, or industrial development are not anticipated to increase terrestrial impacts.

Continued runoff of nutrients from agricultural fields and bioaccumulation of pesticides or

herbicides poses a threat to terrestrial and riparian habitats as well as to wildlife species;

however, the Federal wetlands mitigation projects discussed above and in Section 2.2.6 will

help to reduce impacts to both the aquatic and terrestrial environment.

The NRC staff concludes that the minimal terrestrial impacts expected from the continued CNS

operations, including the operation and maintenance of the 145-mi (233-km) long transmission

line corridor, would not contribute to the overall decline in the condition of terrestrial resources;

however, while the level of impact due to direct and indirect impacts of CNS on terrestrial

communities is SMALL, the cumulative impact when combined with all other sources, even if

CNS was excluded, would be MODERATE.

4.11.5 Cumulative Air Quality Impacts

CNS is located in Nemaha County, Nebraska, which belongs to EPA Region 7. There are no

counties designated by the EPA as nonattainment or maintenance counties for any of the

criteria pollutants in the 50-mi (81-km) vicinity of CNS. Douglas County, Nebraska, located

approximately 72 mi (116 km) from CNS, is the closest maintenance county for lead.

As discussed in Section 2.2.2.1, "Air Quality Impacts," the Nebraska Division of Air Quality of

the NDEQ has primary responsibility for regulating air emission sources within the State of

Nebraska, and with the assistance from Lincoln-Lancaster County Health Department and

Douglas County Health Department, the NDEQ conducts ambient air monitoring in the State,

operating 28 sites throughout the State with 34 monitors. The EPA and National Atmospheric

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Deposition Program also monitor air quality in Nebraska, which participates in the EPA's

AIRNow Network which continuously monitors some of the criteria pollutants and informs the

public of the current environmental conditions.

In April 2009, the EPA published the official U.S. inventory of the greenhouse gas (GHG)

emissions that identifies and quantifies the primary anthropogenic sources and sinks of GHG.

The EPA GHG inventory is an essential tool for addressing climate change and participating

with the United Nations Framework Convention on Climate Change to compare the relative

global contribution of different emission sources and GHGs to climate change. The EPA

estimates that energy-related activities in the United States account for three-quarters of

human-generated GHG emissions, mostly in the form of carbon dioxide emissions from burning

fossil fuels. More than half of the energy-related emissions come from major stationary sources

like power plants, and approximately one-third comes from transportation. Industrial processes

(production of cement, steel, and aluminum), agriculture, forestry, other land use, and waste

management are also important sources of GHG emissions in the United States (EPA, 2009a).

Potential cumulative effects of climate change in southeastern Nebraska, where CNS is located,

and local climate, whether-or not from natural cycles or anthropogenic activities, could result in a

variety of changes to the air quality of the area. Nebraska is a part of the Great Plains Region.

As projected in the "Global Climate Change Impacts in the United States" report by USGCRP

(2009), the temperatures in southeastern Nebraska are expected to rise 6°F (°C) by

2080-2099 at minimum and maximum over 10°F (50

C), causing more frequent extreme weather

events. Increases in average annual temperatures, higher probabilities of extreme heat events,

higher occurrences of extreme rainfall (intense rainfall or drought), and changes in the wind

patterns could affect concentrations of the air pollutants and their long-range transport because

their formation partially depends on the temperature and humidity, and is a result of the

interactions between hourly changes in the physical and dynamic properties of the atmosphere,

atmospheric circulation features, wind, topography, and energy use (IPCC, 2009).

Nebraska is a participant of the Western Governors Association (WGA) that encourages the

participating regions to use their diverse resources for the production of affordable, sustainable,

and environmentally responsible energy. Nebraska is also a part of the WGA Western Regional

Air Partnership which established a multi-State and Tribal GHG registry and developed the

GHG emissions inventories.

As discussed in Section 2.1.3, "Nonradiological Waste Management," NPPD is committed to the

EPA's Reduce, Reuse, Recycle program at its major and minor facilities, with a growing Green

Team, that focuses on pollution prevention, waste minimization, education and training of the

personnel, and incorporates EPA recommendations on the national implementation of the

climate change energy conservation techniques (EPA, 2009b).

In the 2008 Integrated Resource Plan, NPPD outlined the environmental goals of the company

with emphasis on lowering GHG emissions and obtaining 10 percent of the energy supply from

renewable resources by 2020 (NPPD, 2008a).

CNS is exempt from the NDEQ operating permit requirements and holds a Low Emitter Status

from NDEQ, based on the CNS actual quantities of emissions that meet criteria and do not

exceed thresholds, defined in Chapter 5, Title 129 of the Nebraska Administrative Code, for the

emissions of particulate matter, 10 microns or less in diameter (PM1o); carbon monoxide (CO);

volatile organic compounds (VOCs); oxides of nitrogen (NO,); sulfur dioxide (SO2), sulfur

I trioxide (SO3), or any combination of the two (SOx); a single Hazardous Air Pollutant (HAP) or

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HAPs; and lead. As discussed in Section 2.2.2.1, "Air Quality Impacts," actual total emissions

from all sources at CNS for the period from 2004-2008 were 11.52 tons (10.45 metric tonnes

(MT)) per year, 10.73 tons (9.73 MT) per year, 13.21 tons (11.98 MT) per year, 11.43 tons

(10.37 MT) per year and 9.85 tons (8.94 MT) per year, respectively. Highest emissions for the

period from 2004-2008 were reported in 2006: 0.16 tons (0.15 MT) per year of PM10, 2.41 tons

(2.19 MT) per year of CO, 0.22 tons (0.20 MT) per year of VOC, 9.0 tons (8.16 MT) per year of

NO,, 1.41 tons (1.28 MT) per year of SO,, and 0.01 tons (0.009 MT) per year of a single HAP

(NPPD, 2009b).

NPPD stated in the ER (NPPD, 2008a), and the NRC staff confirmed, that no refurbishment is

planned at CNS during the license renewal period.

Based on all of the above, the staff concludes that combined with the emissions from other past,

present, and reasonably foreseeable future actions, cumulative hazardous and criteria air

pollutant emissions on air quality from CNS related actions would be SMALL.

4.11.6 Cumulative Human Health Impacts

The NRC and the EPA developed radiological dose limits for protection of the public and

workers to address the cumulative impact of acute and long-term exposure to radiation and

radioactive material. These dose limits are codified in 10 CFR Part 20 and 40 CFR Part 190.

This analysis includes the area within a 50-mi (80-kin) radius of the CNS site. The REMP

conducted by NPPD in the vicinity of the CNS site measures the cumulative impact of radiation

and radioactive materials from all sources.

As discussed in Section 4.8.1 of this report, the staff reviewed the radiological environmental

radiation monitoring results for the 5-year period from 2003-2007 as part of the cumulative

impacts assessment. Cumulative radiological impacts from all uranium fuel cycle facilities within

a 50-mi (80-km) radius of the CNS site are limited by the dose limits codified in 10 CFR Part 20

and 40 CFR Part 190. In Section 4.8 of this report, the NRC staff concluded that the impacts of

radiation exposure to the public from the operation of CNS during the renewal term would be

SMALL. The NRC and the EPA will regulate any future actions in the vicinity of the CNS site

that could contribute to cumulative radiological impacts; therefore, the NRC concludes that the

cumulative impacts from continued operations of CNS would be SMALL.

4.11.7 Cumulative Socioeconomic Impacts

As discussed in Section 4.4, continued operation of CNS during the license renewal term would

have no impact on socioeconomic conditions in the region beyond those already experienced.

Since NPPD has no plans to hire additional workers during the license renewal term, overall

expenditures and employment levels at CNS would remain relatively constant with no additional

demand for permanent housing and public services. In addition, since employment levels and

tax payments would not change, there would be no population or tax revenue-related land use

impacts. There would also be no disproportionately high and adverse health and environmental

impacts on minority and low-income populations in the region. Based on this and other

information presented in this chapter, there would be no cumulative socioeconomic impacts

from the continued operation of CNS during the license renewal term beyond what is currently

being experienced.

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Any ground disturbing activities during the license renewal term, however, could result in the

cumulative loss of historic and archaeological resources. Historic and archaeological resources

are non-renewable; therefore, the loss of archaeological resources is cumulative. The continued

operation of CNS during the license renewal term has the potential to impact unknown historic

and archaeological resources.

As discussed in Section 4.9.6, continued operation of CNS during the license renewal term

would have a SMALL impact on archaeological resources at the CNS site. NPPD has no plans

to alter the CNS site for license renewal. Any future land disturbing activities would be carried

out under corporate procedures. Should plans change, further consultation would be initiated by

the NRC with the SHPO to evaluate if existing procedures at NPPD remain adequate to protect

historic and archaeological resources. Because impacts to historic and archaeological

resources from the continued operation of CNS would be SMALL, the cumulative environmental

impacts to historic and archaeological resources would be SMALL.

4.11.8 Summary of Cumulative Impacts

The NRC staff considered the potential impacts resulting from the operation of CNS during the

period of extended operation and other past, present, and future actions in the vicinity of CNS.

The determination is that the potential cumulative impacts resulting from CNS operation

combined with other actions during the period of extended operation would be SMALL to

LARGE.

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

Resource Area Impact Discussion

I Water Resources SMALL The total maximum pumping rate at CNS of over 1,500 gpm

(5,678 liters per minute) is less than 1 percent of the average

flow in the river. Likewise, the influence of offsite pumping

should have no measurable effect on ground water levels

onsite. Because the cumulative effects of pumping ground

water on river flow and vice versa are insignificant, the

cumulative impact on water resources in the CNS area is

SMALL.

Aquatic Resources LARGE While the level of impact due to direct and indirect impacts of

CNS on aquatic communities is SMALL, the cumulative

impact when combined with all other sources has resulted in

the Missouri River aquatic ecosystem being unstable and

close to, if not past, the point of reparable change. This

condition meets the NRC's definition of a LARGE level of

impact.

I NUREG-1437, Supplement 41 4-46 July 2010
Environmental Impacts of Operation

Resource Area Impact Discussion

Terrestrial Resources MODERATE Agriculture continues to be the overwhelming dominant land

use in the region, and with a declining human population in

Nemaha County, additional impacts from new residential,

commercial, or industrial development are not anticipated to

increase terrestrial impacts. Continued runoff of nutrients from

agricultural fields and bioaccumulation of pesticides or herbicides poses a threat to terrestrial and riparian habitats, as well as to wildlife species. However, the Federal wetlands

mitigation projects discussed above and in Section 2.2.6 will

help to reduce impacts to terrestrial resources. The minimal

terrestrial impacts expected from the continued CNS

operations, including the operation and maintenance of the

transmission line corridor, would not contribute to the overall

decline in the condition of terrestrial resources. The

cumulative impacts on terrestrial, including non-CNS

activities, would be MODERATE.

Air Quality SMALL CNS holds a Low Emitter Status from NDEQ, based on the

CNS actual quantities of emissions that meet criteria and do

not exceed thresholds. The NRC staff concludes that the

minimal air quality impacts expected from the continued CNS

operation would not destabilize the air quality in the vicinity of

CNS; therefore, the NRC staff concludes that the cumulative

impacts on the air quality from the continued operation of

CNS during the license renewal period would be SMALL.

Socioeconomics SMALL In Section 4.8 of this report, the NRC staff concluded that the

impacts of radiation exposure to the public from the operation

of CNS during the renewal term would be SMALL. The NRC

and the EPA will regulate any future actions in the vicinity of

the CNS site that could contribute to cumulative radiological impacts; therefore, the NRC concludes that the cumulative

impacts from continued operations of CNS would be SMALL.

Human Health SMALL Cumulative radiological impacts from all uranium fuel cycle facilities within a 50-mi (80-km) radius of the CNS site are limited by the dose limits codified in 10 CFR Part 20 and

40 CFR Part 190. In Section 4.8 of this report, the staff

concluded that the impacts of radiation exposure to the public

from the operation of CNS during the renewal term would be

SMALL. The NRC and the State of Nebraska will regulate any

future actions in the vicinity of the CNS site that could

contribute to cumulative radiological impacts; therefore, the

NRC concludes that the cumulative impacts from continued

operations of CNS would be SMALL.

Archaeological Resources SMALL NPPD has no plans to alter the CNS site for license renewal.

Any future land disturbing activities would be carried out

under corporate procedures. Archaeological surveys would be

conducted in areas identified as archaeologically sensitive

prior to any ground disturbing activities. Should plans change,

further consultation would be initiated by NPPD with the NRC,

NSHS, and Missouri SHPO. Because impacts to historic and

archaeological resources from the continued operation of

CNS would be SMALL, the cumulative environmental impacts

to historic and archaeological resources would be SMALL.

I

July 2010 4-47 NUREG-1437, Supplement 41 1
Environmental Impacts of Operation

Resource Area Impact Discussion

Electromagnetic Fields and SMALL The NRC staff concludes that the thermophilic microbiological

Thermophilic Microbiological organisms are not likely to present a public health hazard as a

Organisms result of CNS discharges to the Missouri River. Therefore, the

cumulative impacts on public health from thermophilic

microbiological organisms from continued operation of CNS

during the license renewal period would be SMALL. The NRC

staff determined that the CNS transmission lines are

operating within original design specifications and meet

current NESC clearance standards; therefore, the CNS

transmission lines do not detectably affect the overall potential

for electric shock from induced currents within the analysis

area. With respect to the chronic effects of EMFs, although

the GElS finding of "not applicable" is appropriate to CNS, the

transmission lines associated with CNS are not likely to

detectably contribute to the regional exposure of extremely

low frequency-electromagnetic fields (ELF-EMFs); therefore,

the NRC staff has determined that the cumulative impacts of

the continued operation of the CNS transmission lines would

be SMALL.

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Effluent Release Report for 2006," Brownville, Nebraska, ADAMS Accession No.

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Station, Appendix E - Applicant's Environmental Report, Operating License Renewal Stage,"

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Accession No. ML091750299.

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Protection Supervisor, Nebraska Public Power District, to Donna K. Garden, Nebraska

Department of Environmental Quality, Subject: "Nebraska Public Power District, Cooper Nuclear

Station NPDES Permit #NE0001244, Annual 316(b) Compliance Report," February 29, 2008,

ADAMS Accession No. ML092450698.

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ML081300029.

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for License Renewal Application Environmental Report Cooper Nuclear Station, Docket No.

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#36750, March 27, 2009, ADAMS Accession No. ML091600712

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Environmental Monitoring Program Report for 2008. Brownville, Nebraska, ADAMS Accession

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Nebraska Department of Environmental Quality (NDEQ) 1977. Letter from D.T. Drain, Director,

to L.J. Cooper, Director, Nebraska Public Power District, Subject: "316(b) Demonstration

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Accession No. MLO92450636.

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36750-P," January 10, 2007, Wastewater Section, Lincoln, Nebraska, ADAMS Accession No.

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Threatened and Endangered Species: List of Species by County." Available URL:

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(accessed April 21, 2009).

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and A.B. Schlesinger (eds.), The Middle Missouri River: A Collection of Papers on the Biology

with Special Reference to Power Station Effects, The Missouri River Group, Norfolk, Nebraska,

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http://www.fws.qov/midwest/endangered/lists/missouri-cty.html (accessed April 17, 2009).

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Wildlife Biologist, Grand Island Field Office, to R. Bulavinetz, Aquatic Ecologist, Division of

License Renewal, U.S. Nuclear Regulatory Commission, Subject: "Cooper Nuclear Plant,"

March 16, 2009, ADAMS Accession No. ML092110590

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Environmental Manager, Nebraska Public Power District, Subject: "Cooper Nuclear Station,"

June 8, 2009, ADAMS Accession No. ML091830055.

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District." Available URL: http://www.fws.gov/Refucqes/profiles/index.cfm?id=64530 (accessed

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ADAMS Accession Nos. ML040690705 and ML040690738.

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Regulatory Commission, Washington, D.C., to M. Milwa, State Historic Preservation Officer,

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License Renewal Application Review (Log Number 004-AT-08)," ADAMS Accession No.

ML090210750.

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Regulatory Commission, Washington, D.C., to M. Smith, State Historic Preservation Officer,

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Renewal Application Review (HP Num. 0801-050-01)," ADAMS Accession No. ML090080197.

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Preservation, Washington, D.C., Subject: "Cooper Nuclear Station License Renewal Application

Review," ADAMS Accession No. ML090080683.

July 2010 4-53 NUREG-1437, Supplement 41

5.0 ENVIRONMENTAL IMPACTS OF POSTULATED ACCIDENTS

This chapter describes the environmental impacts from postulated accidents that might occur

during the period of extended operation. The term "accident" as defined in the Generic

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

(NRC, 1996), refers to any unintentional event outside the normal plant operational envelope

that results in a release or the potential for release of radioactive materials into the environment.

Two classes of postulated accidents are evaluated under the National Environmental Policy Act

(NEPA) in the license renewal review: design-basis accidents (DBAs) and severe accidents. In

the GElS, the U.S. Nuclear Regulatory Commission (NRC) staff categorized accidents as

"design basis" when the plant was designed specifically to accommodate these accidents, or as "severe" for those accidents involving multiple failures of equipment or function whose likelihood

is generally lower than DBAs but where consequences may be higher (NRC, 1996). These

issues are evaluated in Chapter 5 of the GELS, "Environmental Impacts of Postulated

Accidents."

Table 5-1. Issues Related to Postulated Accidents. Two issues related to postulated

accidents are evaluated under the National Environmental Policy Act (NEPA) in the license

renewal review: DBAs and severe accidents.

Issue GElS 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; 2

5.3.3.5; 5.4; 5.5.2

5.1 DESIGN-BASIS ACCIDENTS

As described in Section 50.34(b) in Title 10 of the Code of Federal Regulations

(10 CFR 50.34(b)), in order to receive NRC approval for an operating license, an applicant, for

an initial operating license, must submit a final safety analysis report (FSAR) as part of its

application. The FSAR presents the design criteria and design information f61r the proposed

reactor and comprehensive data on the proposed site. The FSAR also discusses various

hypothetical accident situations and the safety features that are provided to prevent and mitigate

accidents. The NRC staff reviews the application to determine whether or not the plant design

meets the NRC's regulations and requirements and includes, in part, the nuclear plant design

and its anticipated response to an accident.

The environmental impacts of postulated accidents were evaluated for the license renewal

period in Chapter 5 of the GELS. Section 5.5.1 states:

All plants have had a previous evaluation of the environmental impacts of

design-basis accidents. In addition, the licensee will be required to maintain

acceptable design and performance criteria throughout the renewal period.

Therefore, the calculated releases from design-basis accidents would not be

expected to change. Since the consequences of these events are evaluated for

the hypothetical maximally exposed individual at the time of licensing, changes in

the plant environment will not affect these evaluations. Therefore, the staff

concludes that the environmental impacts of design-basis accidents are of small

significance for all plants. Because the environmental impacts of design basis

July 2010 5-1 NUREG-1437, Supplement 41
Environmental Impacts of Postulated Accidents

accidents are of small significance and because additional measures to reduce

such impacts would be costly, the staff concludes that no mitigation measures

beyond those implemented during the current term license would be warranted.

This is a Category 1 issue.

No new and significant information related to DBAs was identified during the review of Nebraska

Public Power District's (NPPD's) environmental report (ER), site audit, scoping process, or

evaluation of other available information. Therefore, there are no impacts related to these issues

beyond those discussed in the GELS.

5.2 SEVERE ACCIDENTS

Severe nuclear accidents are those that are more severe than DBAs because they could result

in substantial damage to the reactor core, whether or not there are serious offsite

consequences. In the GElS, the staff assessed the impacts of severe accidents during the

license renewal period, using the results of existing analyses and information from various sites

to predict the environmental impacts of severe accidents for plants during the renewal period.

Severe accidents initiated by external phenomena such as tornadoes, floods, earthquakes,

fires, and sabotage have not traditionally been discussed in quantitative terms in the final

environmental impact statements and were not specifically considered for the Cooper Nuclear

Station (CNS) site in the GElS (NRC, 1996). The GELS, however, did evaluate existing impact

assessments performed by the NRC staff and by the industry at 44 nuclear plants in the United

States and segregated all sites into six general categories and then estimated that the risk

consequences calculated in existing analyses bound the risks for all other plants within each

category. The GElS further concluded that the risk from beyond design-basis earthquakes at

existing nuclear power plants is designated as SMALL. The Commission believes that NEPA

does not require the NRC to consider the environmental consequences of hypothetical terrorist

attacks on NRC-licensed facilities. However, the NRC staffs GElS for license renewal contains

a discretionary analysis of terrorist acts in connection with license renewal. The conclusion in

the GElS is that the core damage and radiological release from such acts would be no worse

than the damage and release to be expected from internally initiated events.

In the GELS, the NRC staff concludes that the risk from sabotage and beyond design-basis

earthquakes at existing nuclear power plants is designated as SMALL, and additionally, that the

risks from other external events are adequately addressed by a generic consideration of

internally initiated severe accidents (NRC, 1996).

Based on information in the GELS, the staff found that:

The generic analysis.. .applies to all plants and that the probability-weighted

consequences of atmospheric releases, fallout onto open bodies of water,

releases to ground water, and societal and economic impacts of severe

accidents are of small significance for all plants. However, not all plants have

performed a site-specific analysis of measures that could mitigate severe

accidents. Consequently, severe accidents are a Category 2 issue for plants that

have not performed a site-specific consideration of severe accident mitigation

and submitted that analysis for Commission review.

The staff identified no new and significant information related to postulated accidents during the

review of NPPD's ER, the site audit, the scoping process, or evaluation of other available

information. Therefore, there are no impacts related to postulated accidents beyond those

NUREG-1437, Supplement 41 5-2 July 2010
Environmental Impacts of Postulated Accidents

discussed in the GELS. In accordance with 10 CFR 51.53(c)(3)(ii)(L), however, the NRC staff

has reviewed severe accident mitigation alternatives (SAMAs) for CNS. Review results are

discussed in Section 5.3.

5.3 SEVERE ACCIDENT MITIGATION ALTERNATIVES

Regulations under Section 51.53(c)(3)(ii)(L) of 10 CFR requires an ER to contain an analysis of

alternatives to mitigate severe accidents if the staff has not previously evaluated SAMAs for the

applicant's plant in an environmental impact statement (EIS), related supplement, or in an

environmental assessment. The Commission's reconsideration of the issue of severe accident

mitigation for license renewal is based on the Commission's NEPA regulations that require a

consideration of mitigation alternatives in its EISs and supplements to EISs, as well as a

previous court decision that required a review of SAMAs at the operating license stage.

5.3.1 Introduction

This section presents a summary of the SAMA evaluation for CNS conducted by NPPD and the

staff's review of that evaluation. The NRC staff performed its review with contract assistance

from Pacific Northwest National Laboratory. Subsequent to the ER, NPPD discovered a problem

with the process they used to numerically average the site-specific meteorological data. NPPD

performed a sensitivity analysis of the population dose risk and offsite economic cost risk using

corrected meteorological data, and found that the population dose and offsite economic cost

values for each of the release categories would be slightly less than reported in the ER, and that

the conclusions of the SAMA remain valid (NPPD, 2009b). The NRC staff's review is available

in Appendix F; the SAMA evaluation is available in NPPD's ER and the supplement submitted in

December 2009.

The SAMA evaluation for CNS was conducted with a four-step approach. In the first step, NPPD

quantified the level of risk associated with potential reactor accidents using the plant specific

probabilistic risk assessment (PRA) and other risk models.

In the second step, NPPD examined the major risk contributors and identified possible ways

(SAMAs) of reducing that risk. Common ways of reducing risk are changes to components,

systems, procedures, and training. NPPD identified 244 potential SAMAs for CNS. NPPD

performed an initial screening to determine if any SAMAs could be eliminated because they are

not applicable to CNS due to design differences, because they have already been implemented

at CNS or because they are addressed by another SAMA candidate. One hundred sixty-four

SAMAs were eliminated based on this screening, leaving 33 for further evaluation.

In the third step, NPPD estimated the benefits and the costs associated with each of the

SAMAs. Estimates were made of how much each SAMA could reduce risk. Those estimates

were developed in terms of dollars in accordance with NRC guidance for performing regulatory

analyses (NRC, 1997). The cost of implementing the proposed SAMAs was also estimated.

Finally, in the fourth step, the costs and benefits of each of the remaining SAMAs were

compared to determine whether the SAMA was cost-beneficial, meaning the benefits of the

SAMA were greater than the cost (a positive cost benefit). NPPD concluded in its ER that

several of the SAMAs evaluated are potentially cost-beneficial (NPPD, 2008).

The potentially cost-beneficial SAMAs do not relate to adequately managing the effects of aging

during the period of extended operation (e.g., none of the potentially cost-beneficial SAMAs

July 2010 5-3 NUREG-1437, Supplement 41
Environmental Impacts of Postulated Accidents

would reduce the frequency or risk associated with aging-related failures). Therefore, they need

not be implemented as part of license renewal pursuant to 10 CFR Part 54. NPPD's SAMA

analysis and the NRC staffs review are discussed in more detail below.

5.3.2 Estimate of Risk

NPPD submitted an assessment of SAMAs for CNS as part of the ER. This assessment was

based on the most recent CNS probabilistic safety assessment (PSA) available at that time, a

plant-specific offsite consequence analysis performed using the MELCOR Accident

Consequence Code System 2 (MACCS2) computer program, and insights from the CNS

individual plant examination (IPE) (NPPD, 1993) and individual plant examination of external

events (IPEEE) (NPPD, 1996). As mentioned above, NPPD discovered an error in the method

used to average their wind data. NPPD performed a sensitivity analysis using the corrected

meteorological data. Their analysis found that the error was conservative relative to the average

population dose and economic cost, and that no SAMAS were inappropriately excluded from

consideration in the license renewal application (LRA) as a result of the error in wind direction.

NPPD submitted their analysis and changes to the LRA in a letter dated December 7, 2009

(NPPD, 2009b).

The NRC staff reviewed NPPD's re-analysis as submitted by NPPD and agrees that the error

was conservative relative to the average population dose and offsite economic cost and that no

SAMAs were inappropriately excluded from consideration in the LRA as a result of the error.

I The CNS core damage frequency (CDF) is approximately 9.3 x 10-6 per year for internal events

as determined from the quantification of the Level 1 PSA model. When determined from the

sum of the containment event tree sequences, or Level 2 PSA model, the release frequency is

approximately 1.2 x 10-5 per year. The latter value was used as the baseline CDF in the SAMA

evaluations. The CDF value is based on the risk assessment for internally-initiated events.

NPPD did not include the contributions from external events within the CNS risk estimates;

however, it did account for the potential risk reduction benefits associated with external events

by increasing the estimated benefits for internal events by a factor of 3. The breakdown of CDF

by initiating event is provided in Table 5-1.

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

Initiating Event CDF (per year) %Contribution to CDF

Transients 3.0 x 10- 32

Loss of DC power 2.1 x 10-6 22

Loss-of-coolant accidents (LOCAs) 1.4 x 10 6 15

Loss of feedwater 1.0 x 10- 11

Loss of offsite power 6.5 x 10.' 7

Loss of service water 6.0 x 10-7 7

Loss of AC buses 2.6 x 10"7 3

Internal flood 2.6 x 10"7 3

Interfacing-systems loss-of-coolant accidents (ISLOCAs) 5.1 x 10-8 <1

Total CDF (Internal Events) 9.3 x 10' 100

As shown in this table, events initiated by transients, loss of DC power, LOCA, and loss of

feedwater are the dominant contributors to the CDF.

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NPPD estimated the dose to the population within 50 miles (mi) (80 kilometers (km)) of the CNS

site to be approximately 0.021 person-sievert (person-Sv) (2.1 person-roentgen equivalent man

(person-rem)) per year. The breakdown of the total population dose by containment release

mode is summarized in Table 5-2. Containment failures within the early time frame (less than

3.7 hours following event initiation) dominate the population dose risk at CNS, with failures in

the intermediate time frame (3.7 to 24 hours following event initiation) contributing most of the

remaining population dose.

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

Population Dose

Containment Release Mode (Person-Rem(a) Per Year) % Contribution

Early containment failure 1.67 78

Intermediate containment failure 0.47 22

Late containment failure <0.1 <1

Intact containment Negligible Negligible

Total 2.14 100

(a) One person-rem = 0.01 person-Sv

The NRC staff has reviewed NPPD's data and evaluation methods and concludes that the

quality of the risk analyses is adequate to support an assessment of the risk reduction potential

for candidate SAMAs. Accordingly, the staff based its assessment of offsite risk on the CDFs

and offsite doses reported by NPPD in their ER (NPPD, 2008).

5.3.3 Potential Plant Improvements

Once the dominant contributors to plant risk were identified, NPPD searched for ways to reduce

that risk. In identifying and evaluating potential SAMAs, NPPD considered insights from the

plant-specific PSA, and SAMA analyses performed for other operating plants that have

submitted license renewal applications. NPPD identified 244 potential risk-reducing

improvements (SAMAs) to plant components, systems, procedures, and training.

NPPD removed all but 80 of the SAMAs from further consideration because they are not

applicable at CNS due to design differences, have already been implemented at CNS, or are

similar in nature and could be combined with another SAMA candidate. A detailed cost-benefit

analysis was performed for each of the remaining SAMAs.

The staff concludes that NPPD used a systematic and comprehensive process for identifying

potential plant improvements for CNS, and that the set of potential plant improvements identified

by NPPD is reasonably comprehensive and, therefore, acceptable.

5.3.4 Evaluation of Risk Reduction and Costs of Improvements

NPPD evaluated the risk-reduction potential of the remaining 80 SAMAs. The majority of the

SAMA evaluations were performed in a bounding fashion in that the SAMA was assumed to

completely eliminate the risk associated with the proposed enhancement.

NPPD estimated the costs of implementing the candidate SAMAs through the application of

engineering judgment and use of other licensee's estimates for similar improvements. The cost

estimates conservatively did not include the cost of replacement power during extended

July 2010 5-5 NUREG-1437, Supplement 41
Environmental Impacts of Postulated Accidents

outages required to implement the modifications, nor did they include maintenance and

surveillance costs of the installed equipment.

The staff reviewed NPPD's bases for calculating the risk reduction for the various plant

improvements and concludes that the rationale and assumptions for estimating risk reduction

are reasonable and generally conservative (i.e., the estimated risk reduction is higher than what

would actually be realized). Accordingly, the staff based its estimates of averted risk for the

various SAMAs on NPPD's risk reduction estimates.

The staff reviewed the bases for the applicant's cost estimates. For certain improvements, the

staff also compared the cost estimates to estimates developed elsewhere for similar

improvements, including estimates developed as part of other licensee's analyses of SAMAs for

operating reactors and advanced light-water reactors. The staff found the cost estimates to be

reasonable, and generally consistent with estimates provided in support of other plants'

analyses.

The staff concludes that the risk reduction and the cost estimates provided by NPPD are

sufficient and appropriate for use in the SAMA evaluation.

5.3.5 Cost-Benefit Comparison

The cost-benefit analysis performed by NPPD was based primarily on NUREG/BR-0184 (NRC,

1997) and was executed consistent with this guidance. NUREG/BR-0058 has recently been

revised to reflect the agency's revised policy on discount rates. Revision 4 of NUREG/BR-0058

states that two sets of estimates should be developed - one at 3 percent and the other at 7

percent (NRC, 2004). NPPD provided both sets of estimates (NPPD, 2008).

NPPD identified eight potentially cost-beneficial SAMAs in the baseline analysis contained in the

ER. The potentially cost-beneficial SAMAs are:

SAMA 25 - Develop procedures to allow bypass of the reactor core isolation

cooling (RCIC) turbine exhaust pressure trip, extending the time available for

RCIC operation.

SAMA 30 - Revise procedures to allow manual alignment of the fire water

system to the residual heat removal (RHR) heat exchangers, providing

improved ability to cool the RHR heat exchangers in a loss of service water

(SW).

SAMA 33 - Provide for the ability to establish an emergency connection of

existing or new water sources to feedwater and condensate systems, increasing

availability of feedwater.

SAMA 40 - Revise procedures to provide additional space cooling to the

emergency diesel generator (EDG) room via the use of portable equipment,

increasing availability of the EDG.

SAMA 45 - Provide an alternate means of supplying the instrument air header,

increasing availability of instrument air.

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SAMA 68 - Revise procedures to allow the ability to cross-connect the

circulating water pumps and the service water going to the turbine equipment

cooling (TEC) heat exchangers, which allow continued use of the power

conversion system after service water is lost.

SAMA 78 - Improve training on alternate injection via the fire water system,

increasing the availability of alternate injection.

* SAMA 79 - Revise procedures to allow use of the residual heat removal service

water (RHRSW) system without a service water booster pump, increasing

availability of the RHRSW system.

NPPD performed additional analyses to evaluate the impact of parameter choices and

uncertainties on the results of the SAMA assessment (NPPD, 2008). If the benefits are

increased by an additional factor of 3 to account for uncertainties, three additional SAMA

candidates were determined to be potentially cost-beneficial:

SAMA 14 - Provide a portable generator to supply DC power to individual

panels during a station blackout (SBO), increasing the time available for AC

power recovery.

SAMA 64 - Revise procedures to allow use of a fire pumper truck to pressurize

the fire water system, increasing availability of the fire water system.

SAMA 75 - Implement Generation Risk Assessment (trip and shutdown risk

modeling) into plant activities, decreasing the probability of trips/shutdown.

NPPD indicated that detailed engineering project cost-benefit analyses have been initiated for

the 11 potentially cost-beneficial SAMAs (NPPD, 2008), (NPPD, 2009a).

Based on the staffs review and the supplemental information provided by NPPD, the NRC staff

concludes that, with the exception of the potentially cost-beneficial SAMAs discussed above, the

costs of the SAMAs evaluated would be higher than the associated benefits.

5.3.6 Conclusions

The staff reviewed NPPD's analysis and concluded that the methods used and the

implementation of those methods were sound. The treatment of SAMA benefits and costs

support the general conclusion that the SAMA evaluations performed by NPPD are reasonable

and sufficient for the license renewal submittal.

Based on its review of the SAMA analysis, the staff concurs with NPPD's identification of areas

in which risk can be further reduced in a cost-beneficial manner through the implementation of

all, or a subset of potentially cost-beneficial SAMAs. Given the potential for cost-beneficial risk

reduction, the staff considers that further consideration of these SAMAs by NPPD is warranted.

However, none of the potentially cost-beneficial SAMAs relate to adequately managing the

effects of aging during the period of extended operation (i.e., none of the potentially

cost-beneficial SAMAs would reduce the frequency or risk associated with aging-related

failures). Therefore, they need not be implemented as part of the license renewal pursuant to

10 CFR Part 54.

July 2010 5-7 NUREG-1437, Supplement 41
Environmental Impacts of Postulated Accidents

5.4 REFERENCES

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

Production and Utilization Facilities."

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

Protection Regulations for Domestic Licensing and Related Regulatory Functions."

10 CFR Part 54. Code of Federal Regulations, Title 10, Energy, Part 54, "Requirements for

Renewal of Operating Licenses for Nuclear Power Plants."

Nebraska Public Power District (NPPD). 1993. "Generic Letter 88-20, Individual Plant

Examination for Severe Accident Vulnerabilities - 10 CFR 50.54(f), IPE Report Submittal,

Cooper Nuclear Station, Docket No. 50-298, DPR-46," March 1993, Agencywide Documents

Access and Management System (ADAMS) Accession Nos. ML073600192 (Volume 1) and

ML073600193 (Volume 2).

Nebraska Public Power District (NPPD). 1996. "Individual Plant Examination for External Events

Report - 10 CFR 50.54(f), Cooper Nuclear Station, NRC Docket No. 50-298, License No.

DPR-46," October 1996, ADAMS Accession No. ML073580487.

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

Station, Appendix E - Applicant's Environmental Report, Operating License Renewal Stage,"

Columbus, Nebraska, September 24, 2008, ADAMS Accession Nos. ML083030246 (main

report) and ML083030252 (attachments).

Nebraska Public Power District (NPPD). 2009a. Letter from Stewart B. Minahan, Nebraska

Public Power District, to the U.S. Nuclear Regulatory Commission Document Control Desk,

Subject: "Response to Request for Additional Information for License Renewal Application -

Severe Accident Mitigation Alternatives, Cooper Nuclear Station, Docket No. 50-298, DPR-46,"

July 1, 2009, ADAMS Accession No. ML091880319.

Nebraska Public Power District (NPPD). 2009b. Letter from Stewart B. Minahan, Nebraska

Public Power District, to the U.S. Nuclear Regulatory Commission Document Control Desk,

Subject: "SAMA Meteorological Anomaly Related to the Cooper Nuclear Station License

Renewal Application, Cooper Nuclear Station, Docket No. 50-298, DPR-46," December 7, 2009,

ADAMS Accession No. ML093490997.

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

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

ADAMS Accession Nos. ML040690705 and ML040690738.

U.S. Nuclear Regulatory Commission (NRC). 1997. "Regulatory Analysis Technical Evaluation

Handbook," NUREG/BR-0184, Washington, D.C.

U.S. Nuclear Regulatory Commission (NRC). 2004. "Regulatory Analysis Guidelines of the U.S.

Nuclear Regulatory Commission," NUREG/BR-0058, Revision 4, Washington, D.C. September

2004.

NUREG-1437, Supplement 41 5-8 July 2010
6.0 ENVIRONMENTAL IMPACTS OF THE URANIUM FUEL CYCLE,

SOLID WASTE MANAGEMENT AND GREENHOUSE GAS EMISSIONS

6.1 THE URANIUM FUEL CYCLE

This section addresses issues related to the uranium fuel cycle and solid waste management

during the period of extended operation. The uranium cycle includes uranium mining and

milling, the production of uranium hexafluoride, isotopic enrichment, fuel fabrication,

reprocessing of irradiated fuel, transportation of radioactive materials, and management of

low-level wastes and high-level wastes related to uranium fuel cycle activities. The Generic

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

(NRC, 1996), (NRC, 1999), details the potential generic impacts of the radiological and

nonradiological environmental impacts of the uranium fuel cycle, including transportation of

nuclear fuel and wastes. The GElS is based, in part, on the generic impacts provided in Table

S-3, "Table of Uranium Fuel Cycle Environmental Data," in Title 10 of the Code of Federal

Regulations (CFR), Section 51.51(a), and in Table S-4, "Environmental Impact of Transportation

of Fuel and Waste to and from One Light-Water-Cooled Nuclear Power Reactor," in

10 CFR 51.52(b). The GElS also addresses the impacts from radon-222 and technetium-99.

For these Category 1 issues, the GElS concludes that the impacts are designated as SMALL,

except for the collective offsite radiological impacts from the fuel cycle and from high-level waste

and spent fuel disposal, where no significance level was assigned to these two impacts. For the

collective offsite radiological impacts, the Commission concludes that these impacts are

acceptable in that these impacts would not be sufficiently large to require the National

Environmental Policy Act (NEPA) conclusion, for any plant, that the option of extended

operation under 10 CFR Part 54 should be eliminated. The staff of the U.S. Nuclear Regulatory

Commission (NRC) did not identify any new and significant information related to the uranium

fuel cycle during the review of Nebraska Public Power District's (NPPD) environmental report

(ER) (NPPD, 2008), the site audit, and the scoping process. Therefore, there are no impacts

related to these issues beyond those discussed in the GELS.

Nine generic issues are related to the fuel cycle and solid waste management. These are shown

in Table 6-1. There are no site-specific issues.

July 2010 6-1 NUREG-1437, Supplement 41
Environmental Impacts of the Uranium Fuel Cycle

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

Issues GElS Section Category

Offsite radiological impacts (individual effects from other than the

disposal of spent fuel and high-level waste)

Offsite radiological impacts (collective effects)

Offsite radiological impacts (spent fuel and high-level waste

disposal)

Nonradiological impacts of the uranium fuel cycle

Low-level waste storage and disposal

Mixed waste storage and disposal

Onsite spent fuel

Nonradiological waste

Transportation

6.1, 6.2.1, 6.2.2.1,

6.2.2.3, 6.2.3, 6.2.4,

6.6

6.1, 6.2.2.1, 6.2.3,

6.2.4,6.6

6.1, 6.2.2.1, 6.2.3,

6.2.4,6.6

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

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

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

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

6.1, 6.5, 6.5.1, 6.5.2,

6.5.3,6.6

6.1, 6.3.1, 6.3.2.3,

6.3.3, 6.3.4, 6.6,

Addendum 1

6.2 GREENHOUSE GAS EMISSIONS

This section provides a discussion of potential impacts from greenhouse gases (GHGs) emitted

from the nuclear fuel cycle. The GElS does not directly address these emissions, and its

discussion is limited to an inference that substantial carbon dioxide (C02) emissions may occur

if coal- or oil-fired alternatives to license renewal are implemented.

NUREG-1437, Supplement 41 6-2 July 2010
Environmental Impacts of the Uranium Fuel Cycle

6.2.1 Existing Studies

Since the development of the GELS, the relative volumes of GHGs emitted by nuclear and other

electricity generating methods have been widely studied. However, estimates and projections of

the carbon footprint of the nuclear power life cycle vary depending on the type of study

conducted. Additionally, considerable debate also exists among researchers regarding the

relative impacts of nuclear and other forms of electricity generation on GHG emissions. Existing

studies on GHG emissions from nuclear power plants generally take two different forms:

(1) qualitative discussions of the potential to use nuclear power to reduce GHG emissions

and mitigate global warming

(2) technical analyses and quantitative estimates of the actual amount of GHGs generated

by the nuclear fuel cycle or entire nuclear power plant life cycle and comparisons to the

operational or life cycle emissions from other energy generation alternatives

6.2.1.1 Qualitative Studies

The qualitative studies consist primarily of broad, large-scale public policy or investment

evaluations of whether an expansion of nuclear power is likely to be a technically, economically,

and/or politically feasible means of achieving global GHG reductions. Studies identified by the

NRC staff during the subsequent literature search include:

Evaluations to determine whether investments in nuclear power in developing

countries should be accepted as a flexibility mechanism to assist industrialized

nations in achieving their GHG reduction goals under the Kyoto Protocols

(Schneider, 2000), (IAEA, 2000), (NEA, 2002), (NIRS/WISE, 2005). Ultimately,

the parties to the Kyoto Protocol did not approve nuclear power as a component

under the Clean Development Mechanism (CDM) due to safety and waste

disposal concerns (NEA, 2002).

Analyses developed to assist governments, including the United States, in

making long-term investment and public policy decisions in nuclear power

(Keepin, 1988), (Hagen et al., 2001), (MIT, 2003).

Although the qualitative studies sometimes reference and critique the existing quantitative

estimates of GHGs produced by the nuclear fuel cycle or life cycle, their conclusions generally

rely heavily on discussions of other aspects of nuclear policy decisions and investment such as

safety, cost, waste generation, and political acceptability. Therefore, these studies are typically

not directly applicable to an evaluation of GHG emissions associated with the proposed license

renewal for a given nuclear power plant.

6.2.1.2 Quantitative

A large number of technical studies, including calculations and estimates of the amount of

GHGs emitted by nuclear and other power generation options, are available in the literature and

were useful to the NRC staffs efforts in addressing relative GHG emission levels. Examples of

these studies include - but are not limited to - Mortimer (1990), Andseta et al. (1998), Spadaro

et al. (2000), Storm van Leeuwen and Smith (2005), Fritsche (2006), Parliamentary Office of

Science and Technology (POST) (2006), AEA Technology (AEA, 2006), Weisser (2006),

Fthenakis and Kim (2007), and Dones (2007).

July 2010 6-3 NUREG-1437, Supplement 41
Environmental Impacts of the Uranium Fuel Cycle

Comparing these studies and others like them is difficult because the assumptions and

components of the life cycles the authors evaluate vary widely. Examples of areas in which

differing assumptions make comparing the studies difficult include:

* energy sources that may be used to mine uranium deposits in the future

* reprocessing or disposal of spent nuclear fuel

* current and potential future processes to enrich uranium and the energy sources

that will power them

* estimated grades and quantities of recoverable uranium resources

* estimated grades and quantities of recoverable fossil fuel resources

* estimated GHG emissions other than C0 2 , including the conversion to C02

equivalents per unit of electric energy produced

* performance of future fossil fuel power systems

* projected capacity factors for alternative means of generation

* current and potential future reactor technologies

In addition, studies may vary with respect to whether all or parts of a power plant's life cycle are

analyzed (i.e., a full life cycle analysis will typically address plant construction, operations,

resource extraction (for fuel and construction materials), and decommissioning, whereas, a

partial life cycle analysis will primarily focus on operational differences).

In the case of license renewal, a GHG analysis for that portion of the plant's life cycle (operation

for an additional 20 years) would not involve GHG emissions associated with construction

because construction activities have already been completed at the time of relicensing. In

addition, the proposed action of license renewal would also not involve additional GHG

emissions associated with facility decommissioning, because that decommissioning must occur

whether the facility is relicensed or not. However, in some of the aforementioned studies, the

specific contribution of GHG emissions from construction, decommissioning, or other portions of

a plant's life cycle cannot be clearly separated from one another. In such cases, an analysis of

GHG emissions would overestimate the GHG emissions attributed to a specific portion of a

plant's life cycle. Nonetheless, these studies provide some meaningful information with respect

to the relative magnitude of the emissions among nuclear power plants and other forms of

electric generation, as discussed in the following sections.

In Tables 6-2, 6-3, and 6-4, the NRC staff presents the results of the aforementioned

quantitative studies to provide a weight-of-evidence evaluation of the relative GHG emissions

that may result from the proposed license renewal as compared to the potential alternative use

of coal-fired, natural gas-fired, and renewable generation. Most studies from Mortimer (1990)

onward suggest that uranium ore grades and uranium enrichment processes are leading

determinants in the ultimate GHG emissions attributable to nuclear power generation. These

studies indicate that the relatively lower order of magnitude of GHG emissions from nuclear

power when compared to fossil-fueled alternatives (especially natural gas) could potentially

NUREG-1437, Supplement 41 6-4 July 2010
Environmental Impacts of the Uranium Fuel Cycle

disappear if available uranium ore grades drop sufficiently while enrichment processes

continued to rely on the same technologies.

6.2.1.3 Summary of Nuclear Greenhouse Gas Emissions Compared to Coal

Considering that coal fuels the largest share of electricity generation in the United States and

that its burning results in the largest emissions of GHGs for any of the likely alternatives to

nuclear power generation, including Cooper Nuclear Station (CNS), most of the available

quantitative studies focused on comparisons of the relative GHG emissions of nuclear to

coal-fired generation. The quantitative estimates of the GHG emissions associated with the

nuclear fuel cycle (and, in some cases, the nuclear life cycle), as compared to an equivalent

coal-fired plant, are presented in Table 6-2. The following chart does not include all existing

studies, but provides an illustrative range of estimates developed by various sources.

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

Source GHG Emission Results

Mortimer (1990) Nuclear-230,000 tons CO2

Coal-5,912,000 tons CO 2

Note: Future GHG emissions from nuclear to increase because of declining ore grade.

Andseta et al. (1998) Nuclear energy produces 1.4 percent of the GHG emissions compared to coal.

Note: Future reprocessing and use of nuclear-generated electrical power in the mining

and enrichment steps are likely to change the projections of earlier authors, such as

Mortimer (1990).

Spadaro et al. (2000) Nuclear-2.5 to 5.7 g Ceq/kWh

Coal-264 to 357 g Ceq/kWh

Storm van Leeuwen and Authors did not evaluate nuclear versus coal.

Smith (2005)

Fritsche (2006) (Values Nuclear-33 g Ceq/kWh

estimated from graph in Coal-950 gCoq/kWh

Figure 4)

POST (2006) (Nuclear Nuclear-5 g CeqlkWh

calculations from AEA, C 2006) Coal-- > 1000 g Ceq/kWh

Note: Decrease of uranium ore grade to 0.03 percent would raise nuclear to 6.8 g Ceq

/kWh. Future improved technology and carbon capture and storage could reduce

coal-fired GHG emissions by 90 percent.

Weisser (2006) Nuclear-2.8 to 24 g Ceq/kWh

(Compilation of results Coal-950 to 1250 g Ceq/kWh

from other studies)

Fthenakis and Kim Authors did not evaluate nuclear versus coal.

(2007)

Dones (2007) Author did not evaluate nuclear versus coal.

g Ceq/kWh = grams of CO 2 equivalents per kilowatt-hour

July 2010 6-5 NUREG-1437, Supplement 41
Environmental Impacts of the Uranium Fuel Cycle

6.2.1.4 Summary of Nuclear Greenhouse Gas Emissions Compared to Natural Gas

The quantitative estimates of the GHG emissions associated with the nuclear fuel cycle (and, in

some cases, the nuclear life cycle), as compared to an equivalent natural gas-fired plant, are

presented in Table 6-3. The following chart does not include all existing studies, but provides an

illustrative range of estimates developed by various sources.

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

Source GHG Emission Results

Mortimer (1990) Author did not evaluate nuclear versus natural gas.

Andseta et al. (1998) Authors did not evaluate nuclear versus natural gas.

Spadaro et al. (2000) Nuclear-2.5 to 5.7 g Ceq/kWh

Natural Gas-i120 to 188 g Ceq/kWh

Storm van Leeuwen Nuclear fuel cycle produces 20 to 33 percent of the GHG emissions compared to

and Smith (2005) natural gas (at high ore grades).

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-i150 g Ceq/kWh

POST (2006) (Nuclear Nuclear-5 g Ceq/kWh

calculations from AEA,

2006) Natural Gas-500 g CeqkWh

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 Natural Gas-440 to 780 g Ceq/kWh

from other studies)

Fthenakis and Kim Authors did not evaluate nuclear versus natural gas.

(2007)

Dones (2007) Author critiqued methods and assumptions of Storm van Leeuwen and Smith (2005),

and concluded that the nuclear fuel cycle produces 15 to 27 percent of the GHG

emissions of natural gas.

6.2.1.5 Summary of Nuclear Greenhouse Gas Emissions Compared to Renewable Energy

Sources

The quantitative estimates of the GHG emissions associated with the nuclear fuel cycle, as

compared to equivalent renewable energy sources, are presented in Table 6-4. Calculation of

GHG emissions associated with these sources is more difficult than the calculations for nuclear

energy and fossil fuels because of the large variation in efficiencies due to their different

sources and locations. For example, the efficiency of solar and wind energy is highly dependent

on the location in which the power generation facility is installed. Similarly, the range of GHG

emissions estimates for hydropower varies greatly depending on the type of dam or reservoir

involved (if used at all). Therefore, the GHG emissions estimates for these energy sources have

a greater range of variability than the estimates for nuclear and fossil fuel sources. As noted in

Section 6.2.1.2, the following chart does not include all existing studies, but provides an

illustrative range of estimates developed by various sources.

I NUREG-1437, Supplement 41 6-6 July 2010
Environmental Impacts of the Uranium Fuel Cycle

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

Source GHG Emission Results

Mortimer (1990) Nuclear-230,000 tons C02

Hydropower-78,000 tons C02

Wind power-54,000 tons C02

Tidal power-52,500 tons C02

Note: Future GHG emissions from nuclear to increase because of declining ore grade.

Andseta et al. (1998) Authors did not evaluate nuclear versus renewable energy sources.

Spadaro et al. (2000) Nuclear-2.5 to 5.7 g Ceq/kWh

Solar PV-27.3 to 76.4 g Ceq/kWh

Hydroelectric-i .1 to 64.6 g Ceq/kWh

Biomass-8.4 to 16.6 g Ceq/kWh

Wind-2.5 to 13.1 g C./kWh

Storm van Leeuwen Authors did not evaluate nuclear versus renewable energy sources.

and Smith (2005)

Fritsche (2006) (Values

estimated from graph in

Figure 4)

POST (2006) (Nuclear

calculations from AEA,

2006)

Nuclear-33 g Ceq/kWh

Solar PV-125 g Ceq/kWh

Hydroelectric-50 g Ceq/kWh

Wind-20 g C.q/kWh

Nuclear-5 g Ceq/kWh

Biomass-25 to 93 g C.q/kWh

Solar PV-35 to 58 g Ceq/kWh

Wave/Tidal-25 to 50 g Ceq/kWh

Hydroelectric-5 to 30 g Ceq/kWh

Wind-4.64 to 5.25 g Ceq/kWh

Note: Decrease of uranium ore grade to 0.03 percent would raise nuclear to

6.8 g Ceq/kWh.

Nuclear-2.8 to 24 g C.q/kWh

Solar PV-43 to 73 g CeqlkWh

Hydroelectric-1 to 34 g Ceq/kWh

Biomass-35 to 99 g Ceq/kWh

Wind-8 to 30 g Ceq/kWh

Nuclear-16 to 55 g Ceq/kWh

Solar PV-17 to 49 g Ceq/kWh

Author did not evaluate nuclear versus renewable energy sources.

Weisser (2006)

(Compilation of results

from other studies)

Fthenakis and Kim

(2007)

Dones (2007)

July 2010 6-7 NUREG-1437, Supplement 41 1
Environmental Impacts of the Uranium Fuel Cycle

6.2.2 Conclusions: Relative Greenhouse Gas Emissions

The sampling of data presented in Tables 6-2, 6-3, and 6-4 above demonstrates the challenges

of any attempt to determine the specific amount of GHG emissions attributable to nuclear

energy production sources, as different assumptions and calculation methodology will yield

differing results. The differences and complexities in these assumptions and analyses will

further increase when they are used to project future GHG emissions. Nevertheless, several

conclusions can be drawn from the information presented.

First, the various studies indicate a general consensus that nuclear power currently produces

fewer GHG emissions than fossil-fuel-based electrical generation (e.g., the GHG emissions from

a complete nuclear fuel cycle currently range from 2.5 to 55 g Ceq/kWh, as compared to the use

of coal plants (264 to 1250 g Ceq/kWh) and natural gas plants (120 to 780 g Ceq/kWh)). The

studies also provide estimates of GHG emissions from five renewable energy sources based on

current technology. These estimates included solar-photovoltaic (17 to 125 g Ceq/kWh),

hydroelectric (1 to 64.6 g Ceq/kWh), biomass (8.4 to 99 g Ceq/kWh), wind (2.5 to 30 g Ceq/kWh),

and tidal (25 to 50 g Ceq/kWh). The range of these estimates is wide, but the general conclusion

is that current GHG emissions from the nuclear fuel cycle are of the same order of magnitude as

from these renewable energy sources.

Second, the studies indicate no consensus on future relative GHG emissions from nuclear

power and other sources of electricity. There is substantial disagreement among the various

authors regarding the GHG emissions associated with declining uranium ore concentrations,

future uranium enrichment methods, and other factors, including changes in technology. Similar

disagreement exists regarding future GHG emissions associated with coal and natural gas for

electricity generation. Even the most conservative studies conclude that the nuclear fuel cycle

currently produces fewer GHG emissions than fossil-fuel-based sources, and is expected to

continue to do so in the near future. The primary difference between the authors is the projected

cross-over date (the time at which GHG emissions from the nuclear fuel cycle exceed those of

fossil-fuel-based sources) or whether cross-over will actually occur.

Considering the current estimates and future uncertainties, it appears that GHG emissions

associated with the proposed CNS relicensing action are likely to be lower than those

associated with fossil-fuel-based energy sources. The NRC staff bases this conclusion on the

following rationale:

(1) As shown in Tables 6-2 and 6-3, the current estimates of GHG emissions from the

nuclear fuel cycle are far below those for fossil-fuel-based energy sources.

(2) CNS license renewal~will involve continued GHG emissions due to uranium mining,

processing, and enrichment, but will not result in increased GHG emissions associated

with plant construction or decommissioning (as the plant will have to be decommissioned

at some point whether the license is renewed or not).

(3) Few studies predict that nuclear fuel cycle emissions will exceed those of fossil fuels

within a time frame that includes the CNS periods of extended operation. Several studies

suggest that future extraction and enrichment methods, the potential for higher grade

resource discovery, and technology improvements could extend this time frame.

I With respect to comparison of GHG emissions among the proposed CNS license renewal action

and renewable energy sources, it appears likely that there will be future technology

NUREG-1437, Supplement 41 6-8 July 2010
Environmental Impacts of the Uranium Fuel Cycle

improvements and changes in the type of energy used for mining, processing, and constructing

facilities of all types. Currently, the GHG emissions associated with the nuclear fuel cycle and

renewable energy sources are within the same order of magnitude. Because nuclear fuel

production is the most significant contributor to possible future increases in GHG emissions

from nuclear power, and because most renewable energy sources lack a fuel component, it is

likely that GHG emissions from renewable energy sources would be lower than those

associated with CNS at some point during the period of extended operation.

The NRC staff also provides an additional discussion about the contribution of GHG to

cumulative air quality impacts in Section 4.11.5 of this SEIS,

6.3 REFERENCES

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

Protection Regulations for Domestic Licensing and Related Regulatory Functions."

10 CFR Part 54. Code of Federal Regulations, Title 10, Energy, Part 54, "Requirements for

Renewal of Operating Licenses for Nuclear Power Plants."

AEA Technology (AEA). 2006. "Carbon Footprint of the Nuclear Fuel Cycle, Briefing Note,"

prepared for British Energy, March 2006.

Andseta, S., M.J. Thompson, J.P. Jarrell, and D.R. Pendergast (Andseta et al.). 1998. "CANDU

Reactors and Greenhouse Gas Emissions," Canadian Nuclear Association, 11 th Pacific Basin

Nuclear Conference, Banff, Alberta, Canada, May 1998.

Dones, R. 2007. "Critical Note on the Estimation by Storm Van Leeuwen J.W., and Smith P. of

the Energy Uses and Corresponding CO 2 Emissions for the Complete Nuclear Energy Chain,"

Paul Sherer Institute, April 2007.

Fritsche, U.R. 2006. "Comparison of Greenhouse-Gas Emissions and Abatement Cost of

Nuclear and Alternative Energy Options from a Life-Cycle Perspective," Oko-Institut, Darmstadt

Office, January 2006.

Fthenakis, V.M. and H.C. Kim. 2007. "Greenhouse-gas emissions from solar-electric and

nuclear power: A life cycle study," Energy Policy, Volume 35, Number 4.

International Atomic Energy Agency (IAEA). 2000. "Nuclear Power for Greenhouse Gas

Mitigation under the Kyoto Protocol: The Clean Development Mechanism (CDM)," November

2000.

Mortimer, N. 1990. "World Warms to Nuclear Power," SCRAM Safe Energy Journal, December

1989 and January 1990. Available URL:

http://www.no2nuclearpower.org uk/articles/mortimer se74.php (accessed February 29, 2007).

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

Station, Appendix E - Applicant's Environmental Report, Operating License Renewal Stage,"

Columbus, Nebraska, September 24, 2008, Agencywide Documents Access and Management

System (ADAMS) Accession Nos. ML083030246 (main report) and ML083030252

(attachments).

Organization for Economic Co-Operation and Development, Nuclear Energy Agency (NEA).

2002. "Nuclear Energy and the Kyoto Protocol."

Parliamentary Office of Science and Technology (POST). 2006. "Carbon Footprint of Electricity

Generation," Postnote, Number 268, October 2006.

July 2010 6-9 NUREG-1437, Supplement 41
Environmental Impacts of the Uranium Fuel Cycle

Schneider, M. 2000. "Climate Change and Nuclear Power," World Wildlife Fund for Nature, April

2000.

Spadaro, J.V., L. Langlois and B. Hamilton (Spadaro et al.). 2000. "Greenhouse Gas Emissions

of Electricity Generation Chains: Assessing the Difference," IAEA Bulletin 42/2/2000, Vienna,

Austria.

Storm van Leeuwen, J.W. and P. Smith 2005. "Nuclear Power-The Energy Balance," August

2005.

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

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

ADAMS Accession Nos. ML040690705 and ML040690738.

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

for License Renewal of Nuclear Plants, Main Report, "Section 6.3 - Transportation, Table 9.1,

Summary of Findings on NEPA Issues for License Renewal of Nuclear Power Plants, Final

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

ML040690720.

Weisser, D. 2006. "A Guide to Life-Cycle Greenhouse Gas (GHG) Emissions from Electric

Supply Technologies." Available URL:

http://www.iaea.orcq/OurWork/ST/NE/Pess/assets/GHG manuscript pre-print versionDanielWei

sser.jdf (accessed May 19, 2009)

NUREG-1437, Supplement 41 6-10 July 2010
7.0 ENVIRONMENTAL IMPACTS OF DECOMMISSIONING

Environmental impacts from the activities associated with the decommissioning of any reactor

before or at the end of an initial or renewed license are evaluated in the Generic Environmental

Impact Statement on Decommissioning of Nuclear Facilities: Supplement 1, '1Regarding the

Decommissioning of Nuclear Power Reactors," NUREG-0586, Supplement 1 (NRC, 2002). The

staff's evaluation of the environmental impacts of decommissioning presented in NUREG-0586,

Supplement 1, identifies a range of impacts for each environmental issue.

The incremental environmental impacts associated with decommissioning activities resulting

from continued plant operation during the renewal term are discussed in the Generic

Environmental Impact Statement for License Renewal of Nuclear Plants (GELS), NU REG-1437,

Volumes 1 and 2 (NRC, 1996), (NRC, 1999).

7.1 DECOMMISSIONING

Category 1 issues in Table B-1 of Title 10 of the Code of Federal Regulations (CFR) Part 51,

Subpart A, Appendix B that are applicable to Cooper Nuclear Station (CNS) decommissioning

following the renewal term are listed in Table 7-1.

Table 7-1. Category 1 Issues Applicable to the Decommissioning of Cooper Nuclear

Station Following the Renewal Term

Issue GElS Section

Radiation doses 7.3.1

Waste management 7.3.2

Air quality 7.3.3

Water quality 7.3.4

Ecological resources 7.3.5

Socioeconomic impacts 7.3.7

A brief description of the staffs review and the conclusions, as stated in Table B-i,

10 CFR Part 51, for each of the issues follows:

" Radiation doses. Based on information in the GElS, the Commission found that:

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 milliroentgen equivalent man (mrem) caused by buildup of long-lived

radionuclides during the license renewal term.

• Waste management. Based on information in the GELS, the Commission found that:

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.

July 2010 7-1 NUREG-1437, Supplement 41
Environmental Impacts of Decommissioning

0 Air quality. Based on information in the GElS, the Commission found that:

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. Based on information in the GELS, the Commission found that:

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.

0 Ecologqical resources. Based on information in the GELS, the Commission found that:

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. Based on information in the GElS, the Commission found that:

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.

The NRC staff has not identified any new and significant information during the review of the

Nebraska Public Power District (NPPD) environmental report (ER), the site audit, or the scoping

process; therefore, there are no impacts related to these issues beyond those discussed in the

GElS (NRC, 1996), (NRC, 1999). For the issues listed in Table 7-1 above, the GElS concluded

that the impacts are SMALL.

7.2 REFERENCES

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

Protection Regulations for Domestic Licensing and Related Regulatory Functions."

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

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

Agencywide Documents Access and Management System (ADAMS) Accession Nos.

ML040690705 and ML040690738.

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

for License Renewal of Nuclear Plants, Main Report, "Section 6.3 - Transportation, Table 9.1,

Summary of Findings on NEPA Issues for License Renewal of Nuclear Power Plants, Final

Report," NUREG-1437, Volume 1, Addendum 1, Washington, D.C.

U.S. Nuclear Regulatory Commission (NRC). 2002. Generic Environmental Impact Statement

on Decommissioning of Nuclear Facilities: Supplement 1, "Regarding the Decommissioning of

Nuclear Power Reactors," NUREG-0586, Supplement 1, Volumes 1 and 2, Washington, D.C.

I NUREG-1437, Supplement 41 7-2 July 2010
8.0 ENVIRONMENTAL IMPACTS OF ALTERNATIVES

The National Environmental Policy Act (NEPA) mandates that each environmental impact

statement (EIS) consider alternatives to any proposed major Federal action. U.S. Nuclear

Regulatory Commission (NRC) regulations (Title 10 of the Code of Federal Regulations (CFR)

Section 51.71(d)) implementing NEPA for license renewal require that a supplemental

environmental impact statement (SEIS) do the following:

Consider and weigh the environmental effects of the proposed action; the

environmental impacts of alternatives to the proposed action; and alternatives

available for reducing or avoiding adverse environmental effects and

consideration of the economic, technical, and other benefits and costs of the

proposed action.

In this case, the proposed Federal action is issuing a renewed license for Cooper Nuclear

Station (CNS), which will allow the plant to operate for 20 years beyond its current license

expiration date. In this chapter, the NRC staff examines potential environmental impacts of

alternatives to issuing a renewed operating license for CNS as well as alternatives that may

reduce or avoid adverse environmental impacts from license renewal, including when and

where these alternatives are applicable.

While the Generic Environmental Impact Statement for License Renewal of Nuclear Plants

(GELS), NUREG-1437 (NRC, 1996), (NRC, 1999), reached generic conclusions regarding many

environmental issues associated with license renewal, it did not determine which alternatives

are reasonable or reach conclusions about site-specific environmental impact levels. As such,

the NRC staff must evaluate environmental impacts of alternatives on a site-specific basis.

Alternatives to the proposed action of issuing a renewed CNS operating license must meet the

purpose and need for issuing a renewed license; they must "provide an option that allows for

power generation capability beyond the term of a current nuclear power plant operating license

to meet future system generating needs, as such needs may be determined by State, utility,

and, where authorized, Federal (other than NRC) decision makers" (NRC, 1996).

The NRC staff ultimately makes no decision as to which alternative (or the proposed action) to

implement, since that decision falls to utility, or State officials. Comparing the environmental

effects of these alternatives will assist the NRC in deciding whether or not the adverse

environmental impacts of license renewal are so great that preserving the option of license

renewal for energy planning decision makers would be unreasonable. If the NRC acts to issue a

renewed license, all of the alternatives, including the proposed action, will be available to

energy-planning decision makers. If the NRC decides not to renew the license (or takes no

action at all), then energy-planning decision makers may no longer elect to continue operating

CNS and will have to resort to another alternative-which may or may not be one of the

alternatives the NRC staff considers in this section-to meet their energy needs.

In evaluating alternatives to license renewal, the NRC staff first selects energy technologies or

options currently in commercial operation, as well as some technologies not currently in

commercial operation but likely to be commercially available by the time the current CNS

operating license expires.

July 2010 8-1 NUREG-1437, Supplement 41
Environmental Impacts of Alternatives

Second, the NRC staff screens the alternatives to

remove those that cannot meet future system needs.

Then, the staff screens the remaining options to

remove those whose costs or benefits do not justify

inclusion in the range of reasonable alternatives. Any

alternatives remaining, then, constitute alternatives to

the proposed action that the staff evaluates in-depth

throughout this section. At the end of the section, the

staff will briefly address each alternative removed

during screening.

The NRC staff initially considers 19 discrete

alternatives to the proposed action.

Once the staff identifies the in-depth alternatives, the

staff refers to generic environmental impact

evaluations in the GELS. The GElS provides

overviews of some energy technologies available at

the time of its publishing in 1996, though it does not

reach any conclusions regarding which alternatives

are most appropriate, nor does it precisely categorize

impacts for each site. Since 1996, many energy

technologies have evolved significantly in capability

and cost, while regulatory structures have changed

to either promote or impede development of

particular alternatives.

As a result, our analyses include updated information

from sources like the Energy Information

Administration (EIA), other organizations within the

Department of Energy (DOE), the Environmental

Protection Agency (EPA), industry sources and

publications, and information submitted by the

applicant (Nebraska Public Power District (NPPD)) in

the environmental report (ER).

I* i iIn,'Depthi. /

Alternatives:'

* Coal-fired

* Supercritical

* Natural gas-fired

Combined cycle

* Combination

Other Alternatives

Considered:

* Coal-fired integrated

gasification

combined-cycle

(!GCC)

0 New nuclear

* Wind power

* Conservation

• Purchased power

* Solar power

(photovoltaic and

concentrating)

* Wood-fired

combustion,

a Conventional

hydroelectric power

o* ';...,Wave and ocean

'energy.,

* Ge-othermal power

* Municipal solid waste

• Biofuels

* Methane

* Oil-fired power

For each in-depth analysis, the staff analyzes I Fuel cells. environmental impacts across seven impact I Delayed retirement

categories: (1) air quality, (2) ground water use and II

quality, (3) surface water use and quality, (4) ecology, (5) human health, (6) socioeconomics,

and (7) waste management. As in earlier chapters of this SEIS, the staff uses the NRC's

three-level standard of significance-SMALL, MODERATE, or LARGE-to indicate the intensity

of environmental effects for each alternative that is evaluated in depth. By placing the detailed

alternative analyses in this order, the NRC staff does not mean to imply that one alternative

would have the least impact, or that an energy-planning decision maker would be most likely to

implement one or another alternative.

Sections 8.1 through 8.3 contain analyses of environmental impacts of alternatives to license

renewal. These include a supercritical coal-fired plant in Section 8.1, a natural gas-fired

combined-cycle power plant in 8.2, and a combination of alternatives in 8.3, that includes some

natural gas-fired capacity, energy conservation, and a wind power component. In Section 8.4,

NUREG-1437, Supplement 41 8-2 July 2010
Environmental Impacts of Alternatives

the NRC staff explains why it dismissed many other alternatives from in-depth consideration.

Finally, in Section 8.5, the staff considers the Energy Outlook:

environmental effects that may occur if the Each year the EIA, part of the DOE, issues

NRC takes no action and does not issue a its updated Annual Energy Outlook (AEO).

renewed license for CNS. The AEO (2009) indicates that natural gas,

8.1 SUPERCRITICAL COAL-FIRED coal, and renewables are likely to fuel most

GENERATION new electrical capacity through 2030, with

some growth in nuclear capacity

Coal-fired generation accounts for a greater (EIA, 2009b), though all projections are

share of U.S. electrical power generation than subject to future developments in fuel price

any other fuel (EIA, 2009b). Furthermore, the or electricity demand.

EIA projects that coal-fired power plants will "Natural-gas-fired plants account for

account for the greatest share of capacity '53percent.of capacity additions in the

additions through 2030-more than natural r:eference6 asel, acmparedwith

gas, nuclear, or renewable generation options. 22percent forrenewables, 18 percent for

W hile coal-fired power plants are widely used coal-i red p , a 5..... ... percent for

and likely to remain widely used, the staff nuclear. Capacity expansion decisions

acknowledges that future additions to coal consider capital, operating, and

capacity may be affected by perceived or transmission costs. Typically, coal-fired,

actual efforts to limit greenhouse gas (GHG) nuclear, and renewable plants are

emissions. For now, the staff considers a capital-intensive, whereas operating (fuel)

coal-fired alternative to be a feasible, c

commercially available option for providing expenditures account for most of the costs

electrical generating capacity beyond CNS's associated with natural-gas-fired capacity"

current license expiration. (EIA, 2009d).

Supercritical technologies are increasingly common in new coal-fired plants. Supercritical

facilities operate at higher temperatures and pressures than most existing coal-fired plants. At

the critical point, there is no change of state when pressure is increased or if heat is added. For

states above the critical point, the steam is supercritical. Operating at higher temperatures and

pressures allows the supercritical coal-fired alternative to operate at a higher thermal efficiency

than subcritical coal-fired power plants. While supercritical facilities are more expensive to

construct, they consume less fuel for a given output, reducing environmental impacts. Based on

technology forecasts from EIA (EIA, 2009a), the NRC staff expects that a new, supercritical

coal-fired plant that begins operation in 2014 would operate at a heat rate of 9,069 British

thermal units per kilowatt-hours (Btu/kWh), or approximately 38 percent thermally efficient

(EIA, 2009a). 2

In a supercritical coal-fired power plant, burning coal heats pressurized water. As the

supercritical steam/water mixture moves through plant pipes to a turbine generator, the

pressure drops and the mixture flashes to steam. The heated steam expands across the turbine

stages, which then spin and turn the generator to produce electricity. After passing through the

turbine, any remaining steam is condensed back to water in the plant's condenser.

In most modern U.S. coal facilities, condenser cooling water circulates through cooling towers or

a cooling pond system (either of which are closed-cycle cooling systems). Older plants often

2I

2 Thermal efficiency is a measure of the efficiency of converting a fuel to energy and useful work. Thermal efficiency

of a nuclear plant is roughly 32 percent.

July 2010 8-3 NUREG-1437, Supplement 41
Environmental Impacts of Alternatives

withdraw cooling water directly from existing rivers or lakes and discharge heated water directly

to the same body of water (called open-cycle cooling). Though the NRC staff notes that a new

facility could hypothetically continue to use the existing CNS intake structure with a

once-through cooling system, as long as CNS could continue to receive sufficient water to

maintain cooling for those systems necessary for a shutdown plant and provided that no

modifications would be necessary to the intake structure and associated pumps. In order to

provide cooling water for the new facility, the NRC staff has chosen to evaluate a coal-fired

alternative using closed-cycle cooling because it will result in lower impacts-primarily to

aquatic ecology-over the life of the alternative. Construction impacts may, however, be slightly

greater, and operational impacts to aesthetics may also be slightly more noticeable, depending

on whether or not the replacement facility uses natural- or mechanical-draft cooling towers.

The plant would withdraw makeup water from and discharge blowdown (water containing

concentrated dissolved solids and biocides) back to the Missouri River. Cooling towers could be

either natural draft (tall towers powered only by the difference in density between heated, humid

air, and surrounding cooler and usually drier air) or mechanical draft (shorter towers powered by

mechanical fans). For this analysis, the NRC staff assumed that a new supercritical coal-fired

power plant would use mechanical draft towers for its closed-cycle cooling system.

In order to replace the 816 net megawatt-electric (MWe) that CNS currently supplies, the

coal-fired alternative would ideally produce roughly the same amount (NPPD, 2008). Onsite

electricity usage includes scrubbers, cooling towers, coal-handling equipment, lights,

communication, and other onsite needs. A supercritical coal-fired power plant equivalent in

capacity to CNS would require less cooling water than CNS because of the switch from

open-cycle to closed-cycle cooling and because the plant operates at a higher thermal

efficiency.

This 816 net MWe power plant would consume 3.14 million tons (2.84 million metric tonnes

(MT)) of coal annually assuming an average heat content of 8,570 British thermal units per

pound (Btu/Ib) (EIA, 2006). The EIA reported that most coal consumed in Nebraska originates in

Wyoming. Given current coal mining operations in Wyoming, the coal used in this alternative

would likely be mined in surface mines, then mechanically processed and washed, before being

transported-likely by rail-to the power plant site. Limestone for scrubbers would also likely

arrive by rail. This coal-fired alternative would then produce roughly 153,000 tons (138,800 MT)

of ash, and roughly 49,500 tons (45,000 MT) scrubber sludge. The coal ash and scrubber

sludge (about 38,300 tons (34,800 MT)) could be recycled.

Environmental impacts from the coal-fired alternative will be greatest during construction. Site

crews will clear the plant site of vegetation, prepare the site surface, and begin excavation

before other crews begin actual construction on the plant and any associated infrastructure,

including electricity transmission infrastructure connecting the plant to existing transmission

lines.

8.1.1 Air Quality

Air quality impacts from coal-fired generation can be substantial because it emits a significant

quantity of sulfur oxides (SOx), nitrogen oxides (NOx), particulates, carbon monoxide (CO), and

hazardous air pollutants (HAPs) such as mercury; however, many of these pollutants can be

effectively controlled by various technologies.

NUREG-1437, Supplement 41 8-4 July 2010
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CNS is located in Nemaha County, Nebraska. There are no areas designated by the EPA as

nonattainment or maintenance for any of the criteria pollutants in the 50-mile (mi) (81-kilometer

(km)) vicinity of CNS. (EPA has defined six "criteria pollutants" as indicators of air quality, and

has established for each of them a maximum concentration above which adverse effects on

human health may occur). A new coal-fired generating plant would qualify as a new

major-emitting industrial facility and would be subject to Prevention of Significant Deterioration

of Air Quality Review under requirements of the Clean Air Act (CAA) (42 U.S.C. § 7401 et seq.),

adopted by the Nebraska Department of Environmental Quality (NDEQ) in Title 129 of Nebraska

Air Quality Regulations (NAQR) (EPA, 2008). A new coal-fired generating plant would need to

comply with the new source performance standards for coal-fired plants set forth in 40 CFR 60

Subpart Da. The standards establish limits for particulate matter (PM) (40 CFR 60.42Da), sulfur

dioxide (SO 2) (40 CFR 60.43Da), and NO, (40 CFR 60.44Da). Regulations issued by NDEQ

adopt the EPA's CAA rules, with modifications, to limit power plant emissions of SO,, NO,, PM,

and HAPs, among other matters. The new coal-fired generating plant would qualify as a Class I

major source as identified in Chapter 2 of Title 129 of the Nebraska Administrative Code (NAC)

and would be required to obtain Class I major source permits from NDEQ, (the EPA may also

elect to review this aspect prior to issuance of the permits (NDEQ, 2003)).

Section 169A of the CAA (42 U.S.C. § 7491) calls for the EPA to establish rules to remedy any

existing visibility impairment and prevent any future impairment in mandatory Class I Federal

areas resulting from man-made air pollution. There are no mandatory Class I Federal areas in

the State of Nebraska and the closest mandatory Class I Federal area is Hercules-Glades

Wilderness Area, which is located 295 mi southeast from CNS in the State of Missouri.

However, the State of Nebraska is among nine States (Nebraska, Kansas, Oklahoma, Texas,

Minnesota, Iowa, Missouri, Arkansas, and Louisiana) that are members of the Central Regional

Air Planning Association (CENRAP), along with tribes, Federal agencies, and other interested

parties that identify regional haze and visibility issues and develop strategies to address them.

The visibility protection regulatory requirements, contained in 40 CFR Part 51, Subpart P,

include the review of the new sources that would be constructed in the attainment or

unclassified areas and may affect visibility in any Class I Federal area (40 CFR 51.307).

The emissions from the coal-fired alternative at the CNS site, projected by the NRC staff based

on published EIA data, EPA emission factors, and based on performance characteristics for this

alternative and likely emission controls, would be:

" Sulfur oxides (SO,) - 923 tons (838 MT) per year

" Nitrogen oxides (NOx) - 784 tons (711 MT) per year

• Total suspended particles (TSP) - 80 tons (72 MT) per year

* Particulate matter (PM) PM10 - 18 tons (17 MT) per year

* Particulate matter (PM) PM2.5 - 77 tons (69 MT) per year

" Carbon monoxide (CO) - 784 tons (711 MT) per year

8.1.1.1 Sulfur Oxides

The coal-fired alternative at the CNS site would likely use wet, limestone-based scrubbers to

remove SOx. The EPA indicates that this technology can remove more than 95 percent of SOx

from flue gases. The staff projects total SOx emissions would be 923 tons (838 MT) per year.

SO, emissions from a new coal-fired power plant would be subject to the part of the

requirements of the CAA (42 U.S.C. § 7651 et seq.). These regulations were enacted to reduce

emissions of SO2 and NO,, the two principal precursors of acid rain, by restricting emissions of

these pollutants from power plants. Title IV caps aggregate annual power plant SO2 emissions

and imposes controls on SO 2emissions through a system of marketable allowances. The EPA

July 2010 8-5 NUREG-1437, Supplement 41
Environmental Impacts of Alternatives

issues one allowance for each ton of S02 that a unit is allowed to emit. New units do not receive

allowances, but are required to have allowances to cover their S02 emissions. Owners of new

units must, therefore, purchase allowances from owners of other power plants or reduce SO 2

emissions at other power plants they own. Allowances can be banked for use in future years.

Thus, provided a new coal-fired power plant is able to purchase sufficient allowances to

operate, it would not add to net regional S02 emissions, although it might do so locally.

8.1.1.2 Nitrogen Oxides

A coal-fired alternative at the CNS site would most likely employ various available NOx-control

technologies, which can be grouped into two main categories: combustion modifications and

post-combustion processes. Combustion modifications include low-NO, burners, overfire air,

reburning, flue gas recirculation, and operational modifications. Post-combustion processes

include selective catalytic reduction (SCR), selective noncatalytic reduction, and hybrid

processes. Effective combination of the combustion modifications~and post-combustion

processes allows reducing NO) emissions by up to 95 percent (EPA, 1998). NPPD indicated in

its ER that it would use a combination of low-NO, burners, overfire air, and selective

noncatalytic reduction technologies in order to reduce NOx emissions from this alternative.

Assuming the use of such technologies at the CNS site, NO, emissions after scrubbing are

estimated to be in the range of 783.77 tons (711.04 MT) annually.

Section 407 of the CAA establishes technology-based emission limitations for NO, emissions. A

new coal-fired power plant would be subject to the new source performance standards for such

plants as indicated in 40 CFR 60.44Da(a)(1). This regulation limits the discharge of any gases

that contain NO, to 200 nanograms (ng) of NOx per joule (J) of gross energy output (equivalent

to 1.6 pounds per megawatt-hours (lb/MWh), based on a 30-day rolling average. Based on the

projected emissions and proposed emissions controls, the coal-fired alternative would meet this

regulation.

8.1.1.3 Particulates

The new coal-fired power plant would use fabric filters to remove particulates from flue gases.

NPPD indicates that fabric filters would remove 99.9 percent of PM (NPPD, 2008). The EPA

notes that filters are capable of removing in excess of 99 percent of PM, and that S02 scrubbers

further reduce PM emissions (EPA, 2008); therefore, the NRC staff believes the NPPD removal

factor is appropriate. Based on this, the new supercritical coal-fired plant would emit 79.68 tons

(72.29 MT) per year of TSP and approximately 18.33 tons (16.63 MT) per year of particulate

matter having an aerodynamic diameter less than, or equal to, 10 microns (PM10) annually. In

addition, coal burning would also result in approximately 76.50 tons per year (69.40 MT) of

particulate matter with an aerodynamic diameter of 2.5 microns or less (PM2.

5) and

coal-handling equipment would introduce fugitive dust emissions when fuel is being transferred

to onsite storage and then reclaimed from storage for use in the plant. During the construction of

a coal-fired plant, onsite activities would also generate fugitive dust. Vehicles and motorized

equipment would create exhaust emissions during the construction process. These impacts

would be intermittent and short-lived; however, to minimize dust generation, construction crews

could use applicable dust-control measures.

8.1.1.4 Carbon Monoxide

Based upon EPA emission factors (EPA, 1998), the NRC staff estimates that total CO

emissions would be approximately 783.77 tons (711.04 MT) per year.

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8.1.1.5 Carbon Dioxide

A coal-fired plant would also have unregulated carbon dioxide (C02) emissions during

operations, as well as during mining, processing, and transportation. The coal-fired plant would

emit between 5,516,000 tons (5,004,000 MT) and 5,715,000 tons (5,184,600 MT) of C02 per

year from coal combustion, depending on the type and quality of the coal burned.

8.1.1.6 Summary of Air Quality

While the GElS analysis mentions global warming from unregulated C02 emissions and acid

rain from SOx and NO, emissions as potential impacts, it does not quantify emissions from

coal-fired power plants; however, the GElS analysis does imply that air impacts would be

substantial (NRC, 1996). The above analysis shows that emissions of air pollutants, including

SO,, NO,, CO, and particulates, exceed those produced by the existing nuclear power plant, as

well as those of the other alternatives considered in this section. Operational emissions of C02

are also much greater under the coal-fired alternative than under other alternatives, as reviewed

by the staff in Section 6.2. Adverse human health effects such as cancer and emphysema have

also been associated with air emissions from coal combustion, and are discussed further in

Section 8.1.5.

The NRC analysis for a coal-fired alternative at an alternative site indicates that impacts from

the coal-fired alternative would have clearly noticeable effects, but given existing regulatory

regimens, permit requirements, and emissions controls, the coal-fired alternative would not

destabilize air quality. Therefore, the appropriate characterization of air impacts from a coal-fired

plant located at the CNS site is MODERATE.

8.1.2 Ground Water Use and Quality

If the onsite coal-fired alternative continued to use ground water for drinking water and service

water, the need for ground water at the plant would be minor. Total usage would likely be less

than CNS because fewer workers would be onsite, and the coal-fired unit would have fewer

auxiliary systems requiring service water. No effect on ground water quality would likely be

apparent.

Construction of a coal-fired plant could have a localized effect on ground water due to

temporary dewatering and runoff control measures. Because of the temporary nature of

construction and the likelihood of reduced ground water usage during operation, the impact of

the coal-fired alternative would be designated as SMALL.

8.1.3 Surface Water Use and Quality

Because the alternative would draw water from the Missouri River, most of the approximately

12,000 gallons per minute (gpm) needed for maximum withdrawal would be taken from the river

with an average consumptive loss of about 15 million gallons per day (mgd). Since the

consumptive loss is less than 0.1 percent of the average annual flow of the Missouri River, the

NRC staff concludes that the impact of surface water use would be designated as SMALL. A

new coal-fired plant would be required to obtain a National Pollutant Discharge and Elimination

System (NPDES) permit from the NDEQ for regulation of industrial discharges such as

wastewater and stormwater. Assuming the plant operates within the limits of this permit, the

impact from any cooling tower blowdown, site runoff, and other effluent discharges on surface

water quality would be designated as SMALL.

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8.1.4 Aquatic and Terrestrial Ecology

8.1.4.1 Aquatic Ecology

In Section 8.1, the NRC notes that it may be possible for a coal-fired alternative to rely on the

I existing CNS cooling water intake and open-cycle cooling, but in order to reduce potential

impacts to aquatic organisms, the NRC staff has determined that the coal-fired alternative would

use closed-cycle cooling. The number of fish and other aquatic organisms affected by

impingement, entrainment, and thermal impacts will be less than those associated with license

renewal because water consumption from, and heat rejected to, the Missouri River would be

I substantially lower than the current CNS as closed-cycle cooling requires less water and has

less aquatic effects than once-through cooling. Some temporary impacts to aquatic organisms

might occur as a result of construction or effluent discharges to the river. These activities would

be monitored by the NDEQ under the project's NPDES permit. Although the number of affected

organisms would be substantially less than for license renewal, the level of impact for continued

CNS operation is already small, and so NRC expects that the levels of impact for impingement,

entrainment, and thermal effects would also be designated as SMALL.

8.1.4.2 Terrestrial Ecology

Coal mining operations will also affect terrestrial ecology in offsite coal mining areas, although

some of the land is most likely already disturbed by mining operations. Onsite and offsite land

disturbances form the basis for impacts to terrestrial ecology.

Onsite impacts to terrestrial ecology will be minor because most of the site has been previously

disturbed and is currently used for agricultural activities, aside from the 234 acres (ac)

(95 hectares (ha)) of woodland on the Missouri side of the river. The impact could change if

additional railways or roads are constructed through less disturbed areas. It is likely that the

coal-fired alternative would continue to use the existing transmission system and right-of-ways

(ROWs). The construction of mechanical draft cooling towers for the closed-cycle cooling

system may also result in additional land disturbances. These construction activities may

fragment (in the case of roads or railways) or destroy habitats and could include a loss of onsite

farmland and possibly wetlands. Construction could also affect current drainage patterns of

water into and out of the wetlands on the CNS site. These land disturbances could affect food

supply and habitat of native wildlife and migratory waterfowl, and changes to the drainage

patterns of the wetlands could affect the wetlands vegetation. However, these impacts are not

likely to be significant. Cooling tower operation could produce some deposition of dissolved

solids on surrounding vegetation and soil from cooling tower drift, even though the GElS

indicates that the impact of cooling towers on agricultural crops is of small significance and most

of the land surrounding the CNS site is farmland.

Any onsite or offsite waste disposal by land filling will also affect terrestrial ecology at least

through the period when the disposal area is reclaimed. Deposition of acid rain resulting from

NOx or SOx emissions, and the deposition of other pollutants, can also affect terrestrial ecology.

Given the emission regulations discussed in Section 8.1.1, air deposition impacts may be

noticeable but are not likely to be destabilizing. Because of the potential habitat disturbances

and potential pollutant deposition, impacts to terrestrial resources from a coal-fired alternative

would be designated as MODERATE and would occur mostly during construction.

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8.1.5 Human Health

Coal-fired power plants introduce worker risks from coal and limestone mining, coal and

limestone transportation, plant operations, and disposal of coal combustion and scrubber

wastes. In addition, there are public risks from the inhalation of stack emissions (as addressed

in Section 8.1.1) and the secondary effects of eating foods grown in areas subject to deposition

from plant stacks.

Human health risks of coal-fired power plants are described, in general, in Table 8-2 of the

GElS (NRC, 1996). Cancer and emphysema as a result of the inhalation of toxins and

particulates are identified as potential health risks to occupational workers and members of the

public (NRC, 1996). The human health risks of coal-fired power plants, both to occupational

workers and to members of the public, are greater than those of the current CNS due to

exposures to chemicals such as mercury; SOx; NOx; radioactive elements, such as uranium and

thorium contained in coal and coal ash; and polycyclic aromatic hydrocarbon (PAH) compounds,

including benzo(a)pyrene.

Regulations restricting emissions-enforced by the EPA or State agencies-have acted to

significantly reduce potential health effects but do not entirely eliminate them. These agencies

also impose site-specific emission limits as needed to protect human health. Even if the

coal-fired alternative were located in a nonattainment area, emission controls and trading or

offset mechanisms could prevent further regional degradation; however, local effects could be

visible. Many of the byproducts of coal combustion responsible for health effects are largely

controlled, captured, or converted in modern power plants (as described in Section 8.1.1),

although some level of health effects may remain.

Aside from emission impacts, the coal-fired alternative introduces the risk of coal pile fires, and

for those plants that use coal combustion liquid and sludge waste impoundments, the release of

the waste due to a failure of the impoundment. Although there have been several instances of

this occurring in recent years, these types of events are still relatively rare.

Overall, despite the range of potential threats to human health, extensive health-based

regulations exist to mitigate the risks to workers and the public. As a result, the NRC staff

expects human health impacts to be characterized as SMALL.

8.1.6 Socioeconomics

8.1.6.1 Land Use

The GElS generically evaluates the impacts of nuclear power plant operations on land use both

on and off each power plant site. The analysis of land use impacts focuses on the amount of

land area that would be affected by the construction and operation of a new supercritical

coal-fired power plant on the CNS site.

Based on previous experience in operating coal-fired plants of similar size, the NRC staff

estimates that an 816-MWe plant would require approximately 170 ac (69 ha) of land. Additional

onsite land may be needed to support a rail spur and yard, as well as approximately 140 ac

(57 ha) of land area for waste disposal.

Offsite land use impacts would occur from coal mining, in addition to land use impacts from the

construction and operation of the new power plant. Scaling from GElS estimates, approximately

18,260 ac (7,390 ha) of land could be affected by mining coal and waste disposal to support the

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Environmental Impacts of Alternatives

coal-fired alternative during its operational life (NRC, 1996); however, most of the land in

existing coal mining areas has already experienced some level of disturbance. The elimination

of the need for uranium mining to supply fuel for the CNS would partially offset this offsite land

use impact. Scaling from GElS estimates, approximately 816 ac (330 ha) of land used for

uranium mining and processing would no longer be needed.

Based on this information, land use impacts could range from MODERATE to LARGE. Some

portion of this impact could be mitigated by constructing the rail spur in existing ROWs.

8.1.6.2 Socioeconomics

Socioeconomic impacts are defined in terms of changes to the demographic and economic

characteristics and social conditions of a region. For example, the number of jobs created by the

construction and operation of a new coal-fired power could affect regional employment, income,

and expenditures. Job creation is characterized by two types: (1) construction-related jobs,

which are transient, short in duration, and less likely to have a long-term socioeconomic impact;

and (2) operation-related jobs in support of power plant operations, which have the greater

potential for permanent, long-term socioeconomic impacts. Workforce requirements of power

plant construction and operation for the coal-fired alternative were determined in order to

measure their possible effects on current socioeconomic conditions.

Based on GElS estimates, NPPD projected a peak construction workforce of 979 to

2,040 workers would be required to construct the coal-fired alternative at CNS (NPPD, 2008).

During the construction period, the communities surrounding the plant site would experience

increased demand for rental housing and public services. The relative economic contributions of

these relocating workers to local business and tax revenues would vary over time.

After construction, local communities may be temporarily affected by the loss of construction

jobs and associated loss in demand for business services. In addition, the rental housing market

could experience increased vacancies and decreased prices. As noted in the GELS, the

socioeconomic impacts at a rural construction site could be larger than at an urban site,

because the workforce would need to relocate closer to the construction site. Although the CNS

site is a rural site, it is located near the city of Omaha, Nebraska (75 mi), meaning that these

effects may be somewhat lessened if workers commute to the site instead of relocating closer.

Construction impacts could range from MODERATE to LARGE.

I NPPD estimated an operational workforce of 163 to 204 workers for the 816-MWe CNS based

on GElS estimates (NPPD, 2008). The NPPD estimate appears reasonable and is consistent

I with trends calling for decreased workforces at power facilities. Even at a rural site like CNS,

impacts are unlikely to be large. Operations impacts would likely be in the range of SMALL to

MODERATE.

8.1.6.3 Transportation

During construction, approximately 2,000 workers would be commuting to the site. In addition to

commuting workers, trucks would transport construction materials and equipment to the

worksite increasing the amount of traffic on local roads. The increase in vehicular traffic would

peak during shift changes resulting in temporary levels of service impacts and delays at

intersections. Trains or barges could also be used to deliver large components to the CNS site, which could require the construction of a rail spur or a dock, as well as possible dredging in the

Missouri River, if barge delivery is chosen. Transportation impacts are likely to be in the range

of MODERATE to LARGE during construction.

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Transportation impacts would be greatly reduced after construction, but would not disappear

during plant operations. The maximum number of plant operating personnel commuting to CNS

would be approximately 200 workers. Frequent deliveries of coal and limestone by rail (if rail

delivery is used) would add to the overall transportation impact. Onsite coal storage would make

it possible to receive several trains per day. Limestone delivered by rail could also add

additional traffic (though considerably less traffic than that generated by coal deliveries).

The coal-fired alternative would likely create SMALL to MODERATE transportation impacts.

8.1.6.4 Aesthetics

The aesthetics impact analysis focuses on the degree of contrast between the coal-fired

alternative and the surrounding landscape and the visibility of the coal plant.

The coal-fired alternative would be up to 200 feet (ft) (61 meters (m)) tall with an exhaust stack

up to 500 ft (152 m) and may be visible offsite in daylight hours. The coal-fired plant, however,

would be shorter than the current CNS reactor building, which stands at 290 ft (88 m), with a

release point at 325 ft (99 m). The assumed mechanical draft towers would generate

condensate plumes, but these would be shorter than the plumes from the natural draft tower

alternative. Noise and light from plant operations, as well as lighting on plant structures, may be

detectable offsite.

Impacts could be moderated because the higher elevation ridges along the river valley may

make it difficult to see or hear the plant outside of the river valley. Overall, aesthetic impacts

associated with the coal-fired alternative would likely be designated as SMALL to MODERATE.

8.1.6.5 Historic and Archaeological Resources

Cultural resources are the indications of human occupation and use of the landscape as defined

and protected by a series of Federal laws, regulations, and guidelines. Prehistoric resources are

physical remains of human activities that predate written records; they generally consist of

artifacts that may alone or collectively yield information about the past. Historic resources

consist of physical remains that postdate the emergence of written records; in the United States,

they are architectural structures or districts, archaeological objects, and archaeological features

dating from 1492 and later. Ordinarily, sites less than 50 years old are not considered historic,

but exceptions can be made for such properties if they are of particular importance, such as

structures associated with the development of nuclear power or Cold War themes. American

Indian resources are sites, areas, and materials important to American Indians for religious or

heritage reasons. Such resources may include geographic features, plants, animals,

cemeteries, battlefields, trails, and environmental features. The cultural resource analysis

encompassed the power plant site and adjacent areas that could potentially be disturbed by the

construction and operation of alternative power plants.

The potential for historic and archaeological resources can vary greatly depending on the

location of the proposed site. To consider a project's effects on historic and archaeological

resources, any proposed areas will need to be surveyed to identify and record historic and

archaeological resources, identify cultural resources (e.g., traditional cultural properties), and

develop possible mitigation measures to address any adverse effects from ground disturbing

activities. Studies will be needed for all areas of potential disturbance at the proposed plant site

and along associated corridors where new construction will occur (e.g., roads, transmission

corridors, rail lines, or other ROWs). In most cases, project proponents should avoid areas with

the greatest sensitivity.

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CNS is situated in an area where historic and archaeological resources could be located several

feet beneath the ground surface. As noted in Section 4.9.6, NPPD conducted a Phase 1A

survey of the CNS site in 2007 and 2008. NPPD has also developed a Cultural Resources

Protection Plan which calls for surveys to be conducted by a qualified archaeologist in areas

deemed sensitive prior to work commencing. The plan also includes an inadvertent discovery

(stop work) provision to ensure that proper notification is taken to protect these resources

should they be discovered. Since NPPD conducted a survey and has established a protection

plan, the impact for a coal-fired alternative at the CNS site would be designated as SMALL.

8.1.6.6 Environmental Justice

The environmental justice impact analysis evaluates the potential for disproportionately high and

adverse human health and environmental effects on minority and low-income populations that

could result from the construction and operation of a new coal-fired power plant. Adverse health

effects are measured in terms of the risk and rate of fatal or nonfatal adverse impacts on human

health. Disproportionately high and adverse human health effects occur when the risk or rate of

exposure to an environmental hazard for a minority or low-income population is significant and

exceeds the risk or exposure rate for the general population or for another appropriate

comparison group. The minority and low-income populations are subsets of the general public

residing around the site, and all are exposed to the same hazards generated from various

power plant operations.

Minority and low-income populations could be affected by the construction and operation of a

new coal-fired power plant. For example, increased demand for rental housing during

construction could disproportionately affect low-income populations. Nevertheless, impacts on

minority and low-income populations from the construction and operation of a coal-fired power

plant alternative could range from SMALL to MODERATE.

8.1.7 Waste Management

Coal combustion generates several waste streams including ash (a dry solid) and sludge

(a semi-solid by-product of emission control system operation). The NRC staff estimates that an

816-MWe power plant would generate annually a total of 326,000 tons (296,000 MT) of dry solid

ash and scrubber sludge. Much of this waste would be recycled. Disposal of the remaining

waste from the 20-year operation of this alternative would require approximately 141 ac (57 ha).

Disposal of the remaining waste could noticeably affect land use and ground water quality, but

with a proper siting in accordance with the Title 132, Chapter 4 standards of the NAC,

implementation of the monitoring and management practices, it would not destabilize resources.

After closure of the waste site and revegetation, the land could be available for other uses.

The impacts from waste generated during operation of this coal-fired alternative would be

designated as MODERATE; the impacts would be clearly visible but would not destabilize

important resources.

Impacts from waste generated during the construction stage would be short-lived. The amount

of the construction waste is small compared to the amount of waste generated during the

operational stage, and most could be recycled. Overall, the impacts from waste generated

during the construction stage would be designated as SMALL.

The NRC staff, therefore, concludes that waste management impacts from construction and

operation of this alternative would be MODERATE.

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Table 8-1 provides a summary of the environmental impacts of the supercritical coal-fired

alternative compared to continued operation of CNS.

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

Compared to Continued Operation of Cooper Nuclear Station

Supercritical Coal-Fired Continued CNS Operation

Generation

Air quality MODERATE SMALL

Ground water SMALL SMALL

Surface water SMALL SMALL

Aquatic and terrestrial resources SMALL to MODERATE SMALL

Human health SMALL SMALL

Socioeconomics SMALL to LARGE SMALL

Waste management MODERATE SMALL

8.2 NATURAL GAS-FIRED COMBINED-CYCLE GENERATION

In this section, the environmental impacts of natural gas-fired combined-cycle generation are

evaluated at the CNS site.

Natural gas fueled 22 percent of electric generation in the United States in 2007 (the most

recent year for which data are available), accounting for the second greatest share of electrical

power after coal (EIA, 2009b). Like coal-fired power plants, natural gas-fired plants may be

affected by perceived or actual action to limit GHG emissions, although they produce markedly

fewer GHGs per unit of electrical output than coal-fired plants. Natural gas-fired power plants

are feasible, commercially available options for providing electrical generating capacity beyond

CNS's current license expiration.

Combined-cycle power plants differ significantly from coal-fired and existing nuclear power

plants. Combined-cycle power plants derive the majority of their electrical output from a

gas-turbine cycle, and then generate additional power-without burning any additional fuelthrough a second, steam-turbine cycle. The first, gas turbine stage (similar to a large jet engine)

burns natural gas which turns a drive shaft that powers an electric generator. The exhaust gas

from the gas turbine is still hot enough, however, to boil water to steam. Ducts carry the hot

exhaust to a heat recovery steam generator, which produces steam to drive a steam turbine and

produce additional electrical power. The combined-cycle approach is significantly more efficient

than any one cycle on its own; thermal efficiency can exceed 60 percent. Since the natural

gas-fired alternative derives much of its power from a gas turbine cycle, and because it wastes

less heat than either the coal-fired alternative or the existing CNS, it requires significantly less

cooling water and smaller cooling towers than the coal-fired alternative discussed in Section 8.1.

In order to replace the 816-MWe that CNS currently supplies, the NRC staff selected a gas-fired

alternative that uses two General Electric S107H combined-cycle generating units. While any

number of commercially available combined-cycle units could be installed in a variety of

combinations to replace the power currently produced by CNS, the S107H is a highly efficient

model that will help to minimize environmental impacts. Other manufacturers, like Siemens,

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offer similarly high efficiency models. This gas-fired alternative produces a net 400 MWe per

unit. Two units produce a total of 800 MWe, or nearly the same net output as the existing CNS.

The combined-cycle alternative operates at a heat rate of 5,690 Btu/kWh, or nearly 60 percent

thermal efficiency (GE, 2007). As noted above, this gas-fired alternative would require much

less cooling water than CNS, because it operates at a higher thermal efficiency and because it

requires much less water for steam cycle condenser cooling. Cooling towers for this alternative

would likely be mechanical draft-type towers approximately 65 ft (20 m) high.

In addition to cooling towers, other visible structures onsite include the turbine buildings and

heat recovery steam generators (HRSGs) (which may be enclosed in a single building), two

exhaust stacks, an electrical switchyard, and possibly, equipment associated with a natural gas

pipeline, like a compressor station. Based on GElS estimates, NPPD indicated that this

800-MWe plant would require approximately 90 ac (36 ha).

This 800-MWe power plant would consume 34 billion cubic feet (ft3) (964 million cubic meters

(M3)) of natural gas annually assuming an average heat content of 1,029 British thermal units

per cubic feet (Btu/ft3) (EIA, 2009c). Natural gas would be extracted from the ground through

wells, then treated to remove impurities (like hydrogen sulfide) and blended to meet pipeline gas

standards, before being piped through the interstate pipeline system to the power plant site.

This gas-fired alternative would produce relatively little waste, primarily in the form of spent

catalysts used for emissions controls.

Environmental impacts from the gas-fired alternative will be greatest during construction. Site

crews will clear vegetation from the site, prepare the site surface, and begin excavation before

other crews begin actual construction on the plant and any associated infrastructure, including a

pipeline spur to serve the plant and electricity transmission infrastructure connecting the plant to

existing transmission lines. Constructing the gas-fired alternative on NPPD property would allow

the gas-fired alternative to make use of CNS's existing transmission system.

8.2.1.1 Air Quality

Nemaha County, Nebraska is in EPA Region 7. All counties in the State of Nebraska are in

attainment for all criteria pollutants, except Douglas County, which is a maintenance county for

lead. A new gas-fired generating plant developed at the CNS site would qualify as a new

major-emitting industrial facility and require a New Source Review (NSR)/Prevention of

Significant Deterioration of Air Quality review under the CAA, adopted by NDEQ in Title 129 of

the NAC (EPA, 2008). The natural gas-fired plant would need to comply with the standards of

performance for electric utility steam generating units set forth in 40 CFR Part 60 Subpart Da.

Subpart P of 40 CFR Part 51 contains the visibility protection regulatory requirements, including

the review of the new sources that would be constructed in the attainment or unclassified areas

and may affect visibility in any Class I Federal area. If a gas-fired alternative was located close

to a mandatory Class I Federal area, additional air pollution control requirements would imply.

There are no mandatory Class I Federal areas in the State of Nebraska and the closest

mandatory Class I Federal area is Hercules-Glades Wilderness Area, which is located 295 mi

southeast from CNS in the State of Missouri.

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The staff projects the following emissions for a gas-fired alternative based on data published by

the EIA, EPA, and on performance characteristics for this alternative and its emissions controls:

* Sulfur oxides (SOx) - 60 tons (54 MT) per year

* Nitrogen oxides (NOx) - 192 tons (177 MT) per year

" Carbon monoxide (CO) - 40 tons (36 MT) per year

* Total suspended particles (TSP) - 34 tons (30 MT) per year

* Particulate matter (PM) PM10 - 34 tons (30 MT) per year

" Carbon dioxide (C0 2 ) - 2,050,000 tons (1,860,000 MT) per year

A new natural gas-fired plant would have to comply with Title IV of the CAA (42 U.S.C. § 7651)

reduction requirements for SO2 and NOx, which are main precursors of acid rain and the major

cause of reduced visibility. Title IV establishes maximum S02 and NO,, emission rates from the

existing plants and a system of the SO2 emission allowances that can be used, sold, or saved

for future use by the new plants.

8.2.1.2 Sulfur and Nitrogen Oxides

As stated above, the new natural gas-fired alternative would produce 60.02 tons (54.45 MT) per

year of SOx and 192.42 tons (176.56 MT) per year of NO, based on the use of the dry, low NOx

combustion technology and use of the SCR in order to significantly reduce NO, emissions.

The new plant would be subjected to the continuous monitoring requirements of SO,, NO,, and

CO 2 specified in 40 CFR Part 75. The natural gas-fired plant would emit approximately

2.1 million tons (approximately 1.9 million MT) per year of unregulated CO 2 emissions.

8.2.1.3 Particulates

The new natural gas-fired alternative would produce 33.54 tons (30.43 MT) per year of TSP, all

of which would be emitted as PM10.

8.2.1.4 Hazardous Air Pollutants

The EPA issued in December 2000 regulatory findings (EPA, 2000b) on emissions of HAPs

from electric utility steam-generating units, which identified that natural gas-fired plants emit

HAPs such as arsenic, formaldehyde, and nickel, and stated that:

Also in the utility RTC (Report to Congress), the EPA indicated that the impacts

due to HAP emissions from natural gas-fired electric utility steam generating

units were negligible based on the results of the study. The Administrator finds

that regulation of HAP emissions from natural gas-fired electric utility steam

generating units is not appropriate or necessary.

The new natural gas-fired alternative would produce 33.25 tons (30.16 MT) per

year of the TSP as PM10 emissions

8.2.1.5 Construction Impacts

Activities associated with the construction of the new natural gas-fired plant onsite or offsite

CNS would cause some additional, temporary air effects as a result of equipment emissions and

fugitive dust from operation of the earth-moving and material handling equipment. Emissions

from workers' vehicles and motorized construction equipment exhaust would be temporary. The

construction crews would employ dust-control practices in order to control and reduce fugitive

dust. The NRC staff concludes that the impact of vehicle exhaust emissions and fugitive dust

from operation of the earth-moving and material handling equipment would be SMALL.

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The overall air quality impacts of a new natural gas-fired plant located at the CNS site would be

designated as SMALL to MODERATE.

8.2.2 Ground Water Use and Quality

The use of ground water for a natural gas-fired combined-cycle plant would likely be limited to

supply wells for drinking water and possibly filtered service water. Total usage would likely be

much less than CNS because fewer workers would be onsite and because the gas-fired

alternative would have fewer auxiliary systems requiring service water.

No effects on ground water quality would be apparent except during the construction phase due

to temporary dewatering and runoff control measures. Because of the temporary nature of

construction and the likelihood of reduced ground water usage during operation, the impact of

the coal-fired alternative would be designated as SMALL.

8.2.3 Surface Water Use and Quality

Maximum withdrawals of surface water from the Missouri River would be much less for a

gas-fired plant than the 668,000 gpm (2 cubic meters per second (m3

/s)) maximum currently

used by CNS; however, by switching from the open-cycle cooling system currently used by CNS

to a closed-cycle cooling system used by the proposed alternative, consumptive water losses

will increase. Since the consumptive loss will remain less than 0.1 percent of the average

annual flow of the Missouri River, the NRC staff concludes that the impact of surface water use

would be designated as SMALL.

A new gas-fired plant would be required to obtain an NPDES permit from the NDEQ for

regulation of industrial wastewater, stormwater, and other discharges. Assuming the plant

operates within the limits of this permit, the impact from any possible runoff cooling tower

blowdown, stormwater discharge, and effluent discharges on surface water quality would be

designated as SMALL.

8.2.4 Aquatic and Terrestrial Ecology

8.2.4.1 Aquatic Ecology

Compared to the existing CNS plant, aquatic ecology actually benefits from the onsite gas-fired

alternative, as the combined-cycle plant with cooling towers rejects significantly less heat to the

environment, thus requiring less water. The number of fish and other aquatic organisms affected

by impingement, entrainment, and thermal impacts will be less than those associated with

license renewal because water consumption and heat rejected to the Missouri River are

substantially lower. Some temporary impacts to aquatic organisms might occur due to any

construction or effluent discharge to the river, but the NRC assumes that the appropriate

agencies would be monitoring and regulating such activities. Although the number of affected

organisms would be substantially less than for license renewal, the NRC level of impact for

license renewal is already small, and so the NRC expects that the levels of impact for

impingement, entrainment, and thermal effects would also be designated as SMALL.

8.2.4.2 Terrestrial Ecology

Constructing the natural gas alternative will require 90 ac (36 ha) of land. These land

disturbances form the basis for impacts to terrestrial ecology.

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Impacts to terrestrial ecology will be minor because the selected site has been previously

disturbed and is mostly used for agricultural activities. (Gas extraction and collection will also

affect terrestrial ecology in offsite gas fields, although much of this land is likely already

disturbed by gas extraction, and the incremental effects of this alternative on gas field terrestrial

ecology are difficult to gauge.)

Construction of the two natural gas units. and mechanical draft cooling towers could result in the

loss of farmland and possible changes to drainage patterns of water into and out of the wetlands

on the CNS site, which could affect food supply and habitat of native wildlife. Land disturbance

could also affect wetland vegetation, but these effects are not expected to be significant.

Operation of the cooling towers would produce a visible plume and cause some deposition of

dissolved solids on surrounding vegetation (including some wetlands) and soil from cooling

tower drift; however, the GElS indicates that the impact of cooling towers on agricultural crops is

of small significance, and most of the land surrounding the cooling towers is farmland.

Construction of the 40-mi gas pipeline could lead to a conversion of forested lands used by

terrestrial wildlife to a mowed ROW as well as the possible loss of cropland from agricultural

production, which could impact wildlife that use the croplands as a food source (NPPD, 2008).

Siting of the pipeline may occur partially in wetlands, which could impact wildlife that use

wetlands habitat. Pipeline construction may fragment surrounding habitat and may increase

edge habitat, which may have adverse impacts on forest interior dwelling species, including

migratory songbirds. Threatened and endangered species may also be affected by construction

of the gas pipeline. Impacts from construction of the pipeline are expected to be MODERATE.

Based on this information, impacts to terrestrial resources could range from SMALL to

MODERATE.

8.2.5 Human Health

Like the coal-fired alternative discussed above, a gas-fired plant would emit criteria air

pollutants, but generally in smaller quantities (except NO,, which requires additional controls to

reduce emissions). Human health effects of gas-fired generation are generally low, although in

Table 8-2 of the GElS (NRC, 1996), the NRC staff identified cancer and emphysema as

potential health risks from gas-fired plants. NO, emissions contribute to ozone formation, which

in turn contributes to human health risks. Emission controls on this gas-fired alternative maintain

NO, emissions well below air quality standards established for the purposes of protecting

human health, and emissions trading or offset requirements mean that overall NO) in the region

will not increase. Health risks to workers may also result from handling spent catalysts that may

contain heavy metals.

Overall, human health risks to occupational workers and to members of the public from

gas-fired power plant emissions sited at CNS would be less than the risks described for a

coal-fired alternative and, therefore, would likely be designated as SMALL.

8.2.6 Socioeconomics

8.2.6.1 Land Use

As discussed in Section 8.1.6, the GElS generically evaluates the impacts of nuclear power

plant operations on land use, both on and off each power plant site. The analysis of land use

impacts focuses on the amount of land area that would be affected by the construction and

operation of a two-unit natural gas-fired combined-cycle power plant at the CNS site.

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Based on GElS estimates, NPPD indicated that approximately 90 ac (36 ha) of land would be

needed to support a natural gas-fired alternative to replace CNS (NPPD, 2008). This amount of

land use would include other plant structures and associated infrastructure, and is unlikely to

exceed 90 ac (36 ha), excluding land for natural gas wells and collection stations. Land use

impacts from construction would be designated as SMALL.

In addition to onsite land requirements, land would be required offsite for natural gas wells and

collection stations. Scaling from GElS estimates, approximately 2,988 ac (1,209 ha) would be

required for wells, collection stations, and pipelines to bring the gas to the plant. Most of this

land requirement would occur on land where gas extraction already occurs. In addition, some

natural gas could come from outside the United States and be delivered as liquefied gas.

The elimination of uranium fuel for the CNS could partially offset offsite land requirements.

Scaling from GElS estimates, the NRC staff estimated that approximately 816 ac (330 ha)

would not be needed for mining and processing uranium during the operating life of the plant.

Overall land use impacts from a gas-fired power plant would be in the range of SMALL to

MODERATE.

8.2.6.2 Socioeconomics

Socioeconomic impacts are defined in terms of changes to the demographic and economic

characteristics and social conditions of a region. For example, the number of jobs created by the

construction and operation of a new natural gas-fired power plant could affect regional

employment, income, and expenditures. Two types of jobs are created by this alternative:

(1) construction-related jobs, which are transient, short in duration, and less likely to have a

long-term socioeconomic impact; and (2) operation-related jobs in support of power plant

operations, which have the greater potential for permanent, long-term socioeconomic impacts.

Workforce requirements of power plant construction and operations for the natural gas-fired

power plant alternative were determined in order to measure their possible effect on current

socioeconomic conditions.

The socioeconomic impacts from constructing and operating a gas-fired plant would have little

noticeable effect. Compared to the coal-fired alternative, the small size of the construction and

operations workforce would have little or no socioeconomic impact. As discussed in Section

8.1.6.2, the socioeconomic impact of operations of the coal-fired alternative would likely be in

the range of SMALL to MODERATE.

Based on GElS estimates, NPPD projected a maximum construction workforce of 979

(NPPD, 2008). During construction of a gas-fired plant, the communities surrounding the power

plant site would experience increased demand for rental housing and public services. The

relative economic effect of construction workers on local economy and tax base would vary over

time.

After construction, local communities may be temporarily affected by the loss of construction

jobs and associated loss in demand for business services, and the rental housing market could

experience increased vacancies and decreased prices. As noted in the GELS, the

socioeconomic impacts at a rural construction site could be larger than at an urban site,

because the workforce may have to move to be closer to the construction site. The impact of

construction on socioeconomic conditions could range from SMALL to MODERATE.

Based on GElS estimates, NPPD estimated a power plant operations workforce of

approximately 125 (NPPD, 2008). The NPPD estimate appears reasonable and is consistent

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with trends toward lowering labor costs by reducing the size of power plant operations

workforces. The small number of operations workers could have a noticeable effect on

socioeconomic conditions in the region, however, socioeconomic impacts associated with the

operation of a gas-fired power plant at the CNS site would be designated as SMALL.

8.2.6.3 Transportation

Transportation impacts associated with construction and operation of a two-unit, gas-fired power

plant would consist of commuting workers and truck deliveries of construction materials to the

CNS site. During construction, up to 1,000 workers would be commuting to the site. In addition

to commuting workers, trucks would transport construction materials and equipment to the

worksite increasing the amount of traffic on local roads. The increase in vehicular traffic would

peak during shift changes resulting in temporary levels of service impacts and delays at

intersections. Pipeline construction and modification to existing natural gas pipeline systems

could also have an impact.

During plant operations, transportation impacts would almost disappear. According to NPPD,

approximately 125 workers would be needed to operate the gas-fired power plant. Since fuel is

transported by pipeline, most transportation infrastructure would experience little increased use

from plant operations.

The transportation infrastructure would experience little to no increased use from plant

operations. Overall, the gas-fired alternative would have a SMALL impact on transportation

conditions in the region around the CNS.

8.2.6.4 Aesthetics

The aesthetics impact analysis focuses on the degree of contrast between the natural gas-fired

alternative and the surrounding landscape and the visibility of the gas-fired plant.

The two gas-fired units could be approximately 100 ft (30 m) tall, with two exhaust stacks up to

175 ft (53 m) tall. Some structures may require aircraft warning lights. Aesthetic impacts may be

mitigated as higher elevations and vegetation along the river valley could make it difficult to see

or hear the plant outside of the river valley. Power plant infrastructure would generally be

smaller and less noticeable than CNS, which has a reactor building height of 290 ft (88 m).

Mechanical draft cooling towers would generate condensate plumes and operational noise.

Noise during power plant operations would be limited to industrial processes and

communications. Pipelines delivering natural gas fuel could be audible offsite near

compressors.

In general, aesthetic changes would be limited to the immediate vicinity of the CNS. Impacts

would likely be designated as SMALL to MODERATE.

8.2.6.5 Historic and Archaeological Resources

The same considerations as discussed in Section 8.1.6.4 for impact of the coal-fired alternative

on historic and archaeological resources apply to the gas-fired alternative.

The impact for a gas-fired alternative at the CNS site would be SMALL.

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8.2.6.6 Environmental Justice

The environmental justice impact analysis evaluates the potential for disproportionately high and

adverse human health and environmental effects on minority and low-income populations that

could result from the construction and operation of a new natural gas-fired power plant. Adverse

health effects are measured in terms of the risk and rate of fatal or nonfatal adverse impacts on

human health. Disproportionately high and adverse human health effects occur when the risk or

rate of exposure to an environmental hazard for a minority or low-income population is

significant and exceeds the risk or exposure rate for the general population or for another

appropriate comparison group. The minority and low-income populations are subsets of the

general public residing around the site, and all are exposed to the same hazards generated

from various power plant operations.

Minority and low-income populations could be affected by the construction and operation of a

new natural gas-fired power plant. Some of these effects have been identified in resource areas

discussed in this section. For example, increased demand for rental housing during construction

could disproportionately affect low-income populations. Nevertheless, impacts on minority and

low-income populations from the construction and operation of a natural gas-fired power plant

alternative could range from SMALL to MODERATE.

8.2.7 Waste Management

During the construction stage of the natural gas-fired, combined-cycle generation alternative,

land clearing and other construction activities would generate waste that can be recycled,

disposed onsite or shipped to the offsite waste disposal facility. Because the alternative would

be constructed on the previously disturbed CNS site, the amounts of wastes produced during

land clearing would be reduced.

During the operational stage, spent SCR catalysts, which are used to control NO, emissions

from the natural gas-fired plants, would make up the majority of the waste generated by this

alternative.

The NRC staff concluded in the GElS (NRC, 1996) that a natural gas-fired plant would generate

minimal waste and the waste impacts would be SMALL for a natural gas-fired alternative

located at the CNS site or offsite.

Table 8-2 provides a summary of the environmental impacts of the natural gas-fired alternative

compared to continued operation of CNS.

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Table 8-2. Summary of Environmental Impacts of the Natural Gas-Fired, Combined-Cycle

Generation Alternative Compared to Continued Operation of Cooper Nucler Station

Natural Gas Combined-Cycle Continued CNS Operation

Generation

Air quality SMALL to MODERATE SMALL

Ground water SMALL SMALL

Surface water SMALL SMALL

Aquatic and terrestrial resources SMALL to MODERATE SMALL

Human health SMALL SMALL

Socioeconomics SMALL to MODERATE SMALL

Waste management SMALL SMALL

8.3 COMBINATION ALTERNATIVE

In this section, the environmental impacts of a combination of alternatives are evaluated. This

combination will include a portion of the combined-cycle gas-fired capacity identified in Section

8.2, an energy conservation capacity component, and a wind power component. This alternative

requires new construction of a single gas-fired unit installed at the CNS site and the construction

of roughly 250 wind turbines at an offsite location, or several different offsite locations.

In this alternative, a portion of CNS's output-250 MWe-would be replaced by conservation.

Inclusion of this conservation component of the alternative is based on Nebraska's energy

efficiency goals for the year 2012. Wind turbines constructed offsite will account for roughly

150 MWe of capacity and 400 MWe will come from one GE S107H combined-cycle power plant.

The only major construction anticipated would be at the current CNS site where the

combined-cycle gas-fired power plant would be constructed and the wind turbine construction at

an offsite location (including the ROW for new transmission lines). No major construction should

be necessary for the conservation portion.

The appearance of the gas-fired facility would be similar to that of the full gas-fired alternative

considered in Section 8.2, though only one unit would be constructed. The NRC staff estimates

that it would require about 50 percent of the space necessary for the alternative considered in

Section 8.2, and that all construction effects-as well as operational aesthetic, fuel-cycle, air

quality, socioeconomic, land use, environmental justice, and water consumption effects-would

scale accordingly.

8.3.1 Air Quality

Nemaha County, Nebraska, where CNS is located, is in EPA Region 7. All counties in the State

of Nebraska are in attainment for all criteria pollutants. Douglas County is a maintenance county

for lead. NDEQ is responsible for managing and monitoring air quality in the State of Nebraska.

This alternative is a combination of one 400-MWe natural gas-fired, combined-cycle generating

unit, constructed onsite, 250 MWe equivalent of conservation and demand-side management,

and 500 MWe of wind capacity constructed offsite, possibly at several different locations.

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A new gas-fired generating plant on the CNS site would qualify as a new major-emitting

industrial facility and requires an NSR under the CAA. Nebraska air quality regulations require

that a permit must be obtained before construction of the new major-emitting industrial facility,

which will be issued only if the new plant includes pollution control measures that reflect the

best available control technology (BACT). The natural gas-fired plant must comply with the

standards of performance for electric utility steam generating units set forth in 40 CFR Part 60

Subpart Da.

Subpart P of 40 CFR Part 51 contains the visibility protection regulatory requirements, including

the review of the new sources that would be constructed in the attainment or unclassified areas

and may affect visibility in any Class I Federal area (40 CFR 51.307). If a gas-fired unit were

located close to a mandatory Class I Federal area, additional air pollution control requirements

would imply. There are no mandatory Class I Federal areas in the State of Nebraska. The

closest is Hercules-Glades Wilderness Area, which is located 295 mi southeast of CNS in the

State of Missouri.

According to published EIA data, the EPA emission factors, performance characteristics for this

alternative, and implemented emission controls, emissions from the one natural gas-fired unit

with a capacity of 400 MWe built at the CNS site would be:

* Sulfur oxides (SO,) - 30 tons (27 MT) per year

* Nitrogen oxides (NOx) (with SCR) - 96 tons (87 MT) per year

* Carbon monoxide (CO) - 20 tons (18 MT) per year

* Total suspended particles (TSP) - 17 tons (15 MT) per year

0 Particulate matter (PM) PM10 - 17 tons (15 MT) per year

0 Carbon dioxide (CO 2) - 1,030,000 tons (964,000 MT) per year

The natural gas-fired component of this alternative would emit 17 tons (15 MT) per year of PM10.

In December 2000, the EPA issued regulatory findings (EPA, 2000b) on emissions of HAPs

from electric utility steam-generating units. The findings show that natural gas-fired plants emit

HAPs such as arsenic, formaldehyde, and nickel, and state that:

Also in the utility RTC (Report to Congress), the impacts due to HAP emissions

from natural gas-fired electric utility steam generating units were negligible based

on the results of the study. The Administrator finds that regulation of HAP

emissions from natural gas-fired electric utility steam generating units is not

appropriate or necessary.

The new natural gas-fired alternative would produce 16.77 tons (15.21 MT) per year of TSP, all

of which would be emitted as PM10 emissions.

The natural gas-fired plant would have to comply with CAA reduction requirements for SO2 and

NO, (42 U.S.C. § 7401 et seq.), which are the main precursors of acid rain and major causes of

reduced visibility. Title IV establishes maximum SO2 and NO, emission rates from the existing

plants and a system of the SO2 emission allowances that can be used, sold, or saved for future

use by the new plants.

As stated above, the new natural gas-fired unit would produce 30.01 tons (27.23 MT) per year

of SO, and 96.21 tons (87.28 MT) per year of NO, based on the use of the dry, low NO,

combustion technology and use of the SCR in order to significantly reduce NOx emissions.

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The natural gas-fired component of this alternative would be subjected to the continuous

monitoring requirements of SO2 , NO,, and CO 2 specified in 40 CFR Part 75. The natural

gas-fired plant would emit approximately 1 million tons (0.9 million MT) per year of unregulated

CO 2 emissions. In response to the Consolidated Appropriations Act of 2008, the EPA has

proposed a rule that requires mandatory reporting of GHG emissions from large sources

(applicable to the presented alternative) in the United States that would allow collection of

accurate and comprehensive emissions data to inform future policy decisions. The EPA

proposes that suppliers of fossil fuels or industrial GHGs, manufacturers of vehicles and

engines, and facilities that emit 25,000 MT or more per year of GHG emissions submit annual

reports to the EPA. The gases covered by the proposed rule are C02, methane (CH 4), nitrous

oxide (N20), hydroflourocarbons (HFC), perflourocarbons (PFC), sulfur hexafluoride (SF6), and

other fluorinated gases including nitrogen triflouride (NF3) and hydroflourinated ethers (HFE).

NPPD states in the "Statement on Addressing the Challenge of Global Climate Change" that it is

voluntarily engaged in lowering the GHG emissions (NPPD, 2008). In the 2008 Integrated

Resource Plan, NPPD outlines the environmental goals of the company with emphasis on

lowering GHG emissions and obtaining 10 percent of the energy supply from renewable

resources by 2020, wind being primarily the source of power (NPPD, 2008).

There would be no operating emissions from the wind or conservation components of the

combination alternative.

Activities associated with the construction of the new natural gas-fired plant onsite at CNS and

wind turbines offsite would cause some additional air effects as a result of equipment emissions

and fugitive dust from operation of the earth-moving and material handling equipment. Vehicles

of workers and construction motorized equipment exhaust emissions would be temporary. The

construction crews would employ dust-control practices in order to control and reduce fugitive

dust, which would be temporary in nature. The NRC staff concludes that the impact of vehicle

exhaust emissions and fugitive dust from operation of earth-moving and material handling

equipment would be designated as SMALL. Implementation of the conservation portion of this

alternative would have no noticeable effects on air quality, though some weatherization

programs may cause existing indoor air quality problems to become worse.

The overall air-quality impacts of the combination alternative consisting of a natural gas-fired

plant located at the CNS site, energy conservation, and an offsite wind component would be in

the range of SMALL to MODERATE.

8.3.2 Ground Water Use and Quality

If the onsite gas-fired plant continued to use ground water for drinking water and service water,

the total usage would likely be much less than CNS uses, because fewer workers are onsite

and because the gas-fired unit would have fewer auxiliary systems requiring service water. The

current average withdrawal rate is 250 gpm, and pumping tests indicate this rate would not

cause an effect on nearby supply wells. A reduction in this withdrawal rate means that impacts

of the combination alternative would remain SMALL.

8.3.3 Surface Water Use and Quality

Using a combined alternative with conservation as a major component will reduce the amount of

surface water consumed for cooling purposes from the already low consumption of the wholly

gas-fired alternative considered in Section 8.2. The maximum consumptive use would be

reduced to a fraction of the surface water withdrawn by the open-cycle cooling system currently

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in use by CNS. This represents less than 0.001 percent of the average annual flow rate in the

Missouri River. The impact of this withdrawal would be SMALL.

8.3.4 Aquatic and Terrestrial Ecology

8.3.4.1 Aquatic Ecology

In order to minimize impacts, NRC assumes that the cooling system for this gas-fired plant

would involve closed-cycle cooling. The wind and conservation components would have no

associated impingement, entrainment, and thermal impacts. The number of fish and other

aquatic resource organisms affected by impingement, entrainment, and other impacts will be

less than those associated with license renewal because water consumption and heat injected

to the Missouri River would be substantially lower. Some temporary impacts to aquatic

organisms might occur due to any construction that might occur or due to any effluent

discharges to the river, but these activities would be monitored by the NDEQ under the project's

NPDES permit. Although the number of affected organisms would be substantially less than for

license renewal, the NRC level of impact for license renewal is already designated as SMALL,

and so the NRC expects that the impact for impingement, entrainment, and thermal effects

would also be SMALL.

8.3.4.2 Terrestrial Ecology

A combination alternative of a single natural gas-fired unit, a system using wind energy, and

energy conservation would make use of existing disturbed land and possibly some farmland at

the CNS site for the natural gas unit and the mechanical draft cooling tower. This alternative

would also require land offsite for the gas pipeline and would require additional land offsite to

accommodate the number of turbines necessary in a wind farm to offset the power generated by

CNS.

This alternative would use a portion of the existing plant site land, switchyard, and transmission

line system for construction of the gas-fired unit. Approximately 45 ac (18 ha) of land would be

required on the CNS site to support a 400 MWe natural gas plant.

Impacts to terrestrial ecology from onsite construction of a single gas-fired unit with one

mechanical draft cooling tower would be less than the impacts described for the two-unit

gas-fired alternative. The impacts to farmland onsite would be approximately one-half of the

impacts of the two-unit natural gas plant alternative. The drainage patterns of the wetland areas

onsite may also be impacted, though again to a lesser degree than the two-unit gas alternative.

These onsite impacts are expected to be minor. Impacts to terrestrial ecology from offsite

construction of the 40-mi (64-km) long gas pipeline for a single gas-fired unit would be the same

as for the two gas-fired unit alternative previously discussed (NPPD, 2008).

Based upon data in the GEIS, the wind farm component of the combination alternative

producing 500 MWe of electricity would require approximately 32,000 ac (12,950 ha) spread

over several offsite locations, with approximately 125 ac (51 ha) in actual use. The remainder of

the land would remain in agriculture. Additional land may be needed for construction of

transmission line corridors to connect to existing transmission line corridors.

Impacts to terrestrial ecology from construction of the wind farm portion of the combination

alternative and any needed transmission lines could include loss of terrestrial habitat, an

increase in habitat fragmentation and a corresponding increase in edge habitat, and may impact

threatened and endangered species. The GElS notes that habitat fragmentation may lead to a

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decline in migrant bird populations. Bird mortality would increase from construction of the wind

farm, although proper site selection for the wind farm could help to reduce bird strikes. The

GElS noted that wind farms typically do not cause significant adverse impacts to bird

populations, although thousands of acres of wildlife habitat or agricultural land could be

impacted, and disruptions could occur to wildlife migratory routes (NRC, 1996).

Based on this information, impacts to terrestrial resources could range from MODERATE to

LARGE.

8.3.5 Human Health

The human health risks from a combination of alternatives include the effects already discussed

in Section 8.2.5 for the combined-cycle gas-fired plant. The GElS (NRC,1996) notes that the

environmental impacts of conservation and a demand-side management alternative are likely to

be centered on indoor air quality. This is due to increased weatherization of the home in the

form of extra insulation and reduced air turnover rates from the reduction in air leaks; however,

the actual impact from the conservation alternative is highly site-specific and not yet

well-established. For wind capacity, the GElS notes that, except for a potential small number of

occupational injuries, human health would not be affected by routine operations.

The human health risks from the combination of alternatives, although uncertain, are considered

to be SMALL to MODERATE given that the construction and operation of the facilities are

expected to comply with health-based Federal and State safety and emission standards.

8.3,6 Socioeconomics

8.3.6.1 Land Use

The GElS generically evaluates the impacts of nuclear power plant operations on land use both

on and off each power plant site. The analysis of land use impacts for a combination alternative

focuses on the amount of land area that would be affected by the construction and operation of

a single natural gas-fired unit power plant at the CNS site and at an offsite wind energy

generating facility, and demand-side energy conservation.

Based on GElS estimates, approximately 45 ac (18 ha) would be needed to support the single

natural gas-fired unit portion of the combination alternative. Land use impacts from construction

of the natural gas-fired power plant at CNS would be designated as SMALL.

In addition to onsite land requirements, land would be required offsite for natural gas wells and

collection stations. Scaling from GElS estimates, the natural gas-fired power plant at CNS could

require 1,469 ac (594 ha) for wells, collection stations, and pipelines to bring the gas to the

facility. Most of this land requirement would occur on land where gas extraction already occurs.

In addition, some natural gas could come from outside of the United States and be delivered as

liquefied gas.

The wind farm component of the combination alternative producing 500 MWe of electricity

would require approximately a 32,000-ac (12,950-ha) spread over several locations with

approximately 125 ac (51 ha) in actual use.

Land use impacts of an energy efficiency alternative would be designated as SMALL. Quickly

replacing and disposing old inefficient equipment could generate waste material and increase

the size of landfills; however, given the time for program development and implementation, the

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cost of replacements, and the average life of equipment, the replacement process would

probably be gradual. Older equipment would simply be replaced by more efficient equipment

(especially in the case of frequently replaced items, such as light bulbs). In addition, many items

(such as home appliances and industrial equipment) have recycling value and would probably

not be disposed of in landfills.

The elimination of uranium fuel for CNS could partially offset offsite land requirements. Scaling

from GElS estimates, approximately 816 ac (330 ha) would not be needed for mining and

processing uranium during the operating life of the plant. Overall land use impacts from the

combination alternative would range from SMALL to MODERATE.

8.3.6.2 Socioeconomics

As previously discussed, socioeconomic impacts are defined in terms of changes to the

demographic and economic characteristics and social conditions of a region. For example, the

number of jobs created by the construction and operation of a new single natural

gas-fired power plant at CNS and the wind farm could affect regional employment, income, and

expenditures. Job creation is characterized by two types: (1) construction-related jobs, which

are transient, short in duration, and less likely to have a long-term socioeconomic impact; and

(2) operation-related jobs in support of power generating operations, which have a greater

potential for permanent, long-term socioeconomic impacts. The NRC staff conducted

evaluations of construction and operations workforce requirements in order to measure their

effect on current socioeconomic conditions.

Based on GElS projections and a workforce of 1,200 for a 1,000-MWe plant, a single 400 MWe

unit at CNS requires a peak estimated construction workforce of 490. Additional estimated

construction workforce requirements for this combination alternative include 300 construction

workers for the wind farm. The number of additional workers would cause a short-term increase

in the demand for services and temporary (rental) housing in the region around the construction

site.

After construction and depending on the size of the community, some local communities may be

temporarily affected by the loss of the construction jobs and associated loss in demand for

business services. The rental housing market could also experience increased vacancies and

decreased prices. The impact of construction on socioeconomic conditions would be designated

as SMALL.

Following construction, a single-unit gas-fired power plant at CNS could provide up to 63 jobs,

based on NPPD estimates, or up to 64 jobs, based on GElS estimates. Additional estimated

operations workforce requirements for this combination alternative include 50 operations

workers for the wind farm. Given the small numbers of operations workers at these facilities,

socioeconomic impacts associated with the operation of the natural gas-fired power plant at

CNS and the wind farm would be designated as SMALL.

Socioeconomic effects of an energy efficiency program would be SMALL. As noted in the GElS,

the program would require additional workers. Lower-income families could benefit from

weatherization and insulation programs. This effectwould be greater than the effect for the

general population because low-income households experience home energy burdens more

than four times larger than the average household (OMB, 2007).

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8.3.6.3 Transportation

Transportation impacts would be SMALL because the number of employees commuting to the

CNS site, where the gas-fired portion is located, would be small. Any transportation effects from

the energy efficiency alternative would be widely distributed across the State, and would not be

noticeable.

Construction and operation of a natural gas-fired power plant and wind farm would increase the

number of vehicles on the roads in the vicinity of these facilities. During construction, cars and

trucks would deliver workers, materials, and equipment to the worksites. The increase in

vehicular traffic would peak during shift changes resulting in temporary levels of service impacts

and delays at intersections. Pipeline construction and modification to existing natural gas

pipeline systems could also have an impact. Highway delivery of large wind farm components

may also cause impacts to traffic.

During plant operations, transportation impacts would almost disappear. Given the small

numbers of operations workers at these facilities, levels of service impacts on local roads from

the operation of the natural gas-fired power plant at CNS and at the wind farm, would be

SMALL. Transportation impacts at the wind farm site would also depend on current road

capacities and average daily traffic volumes.

8.3.6.4 Aesthetics

The aesthetics impact analysis focuses on the degree of contrast between the surrounding

landscape and the visibility of the power plant.

A single natural gas-fired unit located at CNS would be approximately 100 ft (30 m) tall with an

exhaust stack of at least 175 ft (53 m) tall, which is less noticeable than the current CNS reactor

building at 290 ft (88 m). The impact would be moderated as higher elevations and vegetation

along the river valley could make it difficult to see or hear the power plant outside of the river

valley. Power plant infrastructure would generally be smaller and less noticeable than the CNS

containment and turbine buildings. Mechanical draft cooling towers (if used) would generate

condensate plumes and operational noise, which during power plant operations would be limited

to noise from industrial processes and communications. In addition to power plant structures,

construction of natural gas pipelines would have a short-term impact. Noise from the pipelines

could be audible offsite near compressors.

Impacts from energy efficiency programs would be SMALL. Some noise impacts could occur in

instances of energy efficiency upgrades to major building systems, although this impact would

be intermittent and short-lived.

In general, aesthetic changes would be limited to the immediate vicinity of the CNS site and the

wind farm facilities. The wind farm would have the greatest aesthetic effect. Compared to a

fossil-fueled power plant unit on 46-to 1,400 ac, the 250 wind turbines at over 300 ft (100 m) tall

and spread across multiple sites covering 32,000 ac (13,000 ha) may, in some locations,

dominate the view and be a major focus of viewer attention. The overall impact, however, would

depend on the sensitivity of the people living around the area of the site; therefore, overall

aesthetic impacts from the construction and operation of this combination alternative would be

SMALL to MODERATE.

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8.3.6.5 Historic and Archaeological Resources

Cultural resources are the indications of human occupation and use of the landscape as defined

and protected by a series of Federal laws, regulations, and guidelines. Prehistoric resources are

physical-remains of human activities that predate written records; they generally consist of

artifacts that may alone or collectively yield information about the past. Historic resources

consist of physical remains that postdate the emergence of written records; in the United States,

they are architectural structures or districts, archaeological objects, and archaeological features

dating from 1492 and later. Ordinarily, sites less than 50 years old are not considered historic,

but exceptions can be made for such properties if they are of particular importance, such as

structures associated with the development of nuclear power or Cold War themes. American

Indian resources are sites, areas, and materials important to American Indians for religious or

heritage reasons. Such resources may include geographic features, plants, animals, burial

grounds, battlefields, trails, and environmental features. The cultural resource analysis

encompassed the power plant site and adjacent areas that could potentially be disturbed by the

construction and operation of alternative power plants.

The potential for historic and archaeological resources can vary greatly depending on the

location of the proposed site. To consider a project's effects on historic and archaeological

resources, any proposed areas will need to be surveyed to identify and record historic and

archaeological resources, identify cultural resources (e.g., traditional cultural properties), and

develop possible mitigation measures to address any adverse effects from ground disturbing

activities. Studies will be needed for all areas of potential disturbance at the proposed plant site

and along associated corridors where new construction will occur (e.g., roads, transmission

corridors, rail lines, or other ROWs). In most cases, project proponents should avoid areas with

the greatest sensitivity.

The impact for a single-unit, natural gas-fired alternative at the CNS site would be SMALL. As

noted in Section 4.9.6, NPPD conducted a Phase 1A survey of the CNS site in 2007 and 2008.

NPPD has also developed a Cultural Resources Protection Plan which calls for surveys to be

conducted by a qualified archaeologist in areas deemed sensitive prior to work commencing.

The plan also includes an inadvertent discovery (stop work) provision to ensure that proper

notification is taken to protect these resources should they be discovered. Depending on the

resource richness of an alternative site or sites ultimately chosen for the wind farm alternative,

impacts could range from SMALL to MODERATE.

Impacts to historic and archaeological resources from implementing the energy efficiency

programs would be SMALL. A conservation alternative would not affect land use or historical or

cultural resources onsite or elsewhere in the State.

8,3.6.6 Environmental Justice

The environmental justice impact analysis evaluates the potential for disproportionately high and

adverse human health and environmental effects on minority and low-income populations that

could result from the construction and operation of a new natural gas-fired power plant and wind

farm. Adverse health effects are measured in terms of the risk and rate of fatal or nonfatal

adverse impacts on human health. Disproportionately high and adverse human health effects

occur when the risk or rate of exposure to an environmental hazard for a minority or low-income

population is significant and exceeds the risk or exposure rate for the general population or for

another appropriate comparison group. The minority and low-income populations are subsets of

the general public residing around the site, and all are exposed to the same hazards generated

from various power plant operations.

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Minority and low-income populations could be affected by the construction and operation of a

new natural gas-fired power plant and wind farm. Some of these effects have been identified in

resource areas discussed in this section. For example, increased demand for rental housing

during construction could disproportionately affect low-income populations.

Weatherization programs could target low-income residents as a cost-effective energy efficiency

option since low-income populations tend to spend a larger proportion of their incomes paying

utility bills (according to the Office of Management and Budget (OMB), low-income populations

experience energy burdens more than four times as large as those of average households

(OMB, 2007). Impacts to minority and low-income populations from energy efficiency programs

would be SMALL, depending on program design and enrollment.

Impacts on minority and low-income populations under the combination alternative could range

from SMALL to MODERATE, due to the small number of workers needed to construct and

operate the natural gas-fired power plant and wind farm.

8.3.7 Waste Management

During the construction stage of this combination of alternative, land clearing and other

construction activities would generate wastes that can be recycled, disposed onsite, or shipped

to the offsite waste disposal facility. During the operational stage, spent SCR catalysts, which

are used to control NO, emissions from the natural gas-fired plants, would make up the majority

of the waste generated by this alternative.

There will be an increase in wastes generated during installation or implementation of

conservation measures, such as appropriate disposal of old appliances, installation of control

devices, and building modifications. New and existing recycling programs would help to

minimize the amount of generated waste.

The NRC staff concludes that overall waste impacts from the combination of the natural

gas-fired unit constructed onsite, wind capacity, and conservation are SMALL.

Table 8-3 provides a summary of the environmental impacts of the combined alternative

compared to continued operation of CNS.

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

to Continued Operation of Cooper Nuclear Station

Combination Alternative Continued CNS Operation

Air quality SMALL to MODERATE SMALL

Ground water SMALL SMALL

Surface water SMALL SMALL

Aquatic and terrestrial resources SMALL to LARGE SMALL

Human health SMALL to MODERATE SMALL

Socioeconomics SMALL to MODERATE SMALL

Waste management SMALL SMALL

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8.4 ALTERNATIVES CONSIDERED BUT DISMISSED

In this section, the NRC staff presents the alternatives it initially considered for analysis as

alternatives to license renewal of CNS, but later dismissed due to technical, resource

availability, or commercial limitations that currently exist and that the NRC staff believes are

likely to continue to exist when the existing CNS license expires. Under each of the following

technology headings, the NRC staff indicates why it dismissed each alternative from further

consideration. Offsite coal and gas-fired alternatives were not considered because the NRC

staff determined that a possibly undisturbed offsite location would generally generate larger

impacts than either alternative constructed at the previously disturbed CNS site.

8.4.1 Offsite Coal- and Gas-Fired Capacity

While it is possible that coal- and gas-fired alternatives like those considered in Sections 8.1

and 8.2, respectively, could be constructed at sites other than CNS, the NRC staff determined

that they would result in greater impacts than alternatives constructed at the CNS site. Greater

impacts would occur from construction of support infrastructure, like transmission lines, roads,

and railway spurs that are already present on the CNS site. Furthermore, the community around

CNS is already familiar with the appearance of a power facility and it is an established part of

the region's aesthetic character. Workers skilled in power plant operations would also be

available in this area. The availability of these factors is only likely to be available on other

recently-industrial sites. In cases where recently-industrial sites exist, other remediation may

also be necessary in order to make the site ready for redevelopment. In short, an existing power

plant site would present the best location for a new power facility.

8.4.2 Coal-Fired Integrated Gasification Combined-Cycle

While utilities across the United States have considered or are considering plans for integrated

gasification combined-cycle (IGCC) coal-fired power plants, few IGCC facilities have yet been

constructed. All facilities constructed in the United States to date have been smaller than CNS.

The technology, however, is commercially available and relies on a gasifier stage and a

combined-cycle stage. Existing combined-cycle facilities (like the ones considered in Section

8.2) could be used as a part of an IGCC alternative.

The EIA indicates that IGCC and other advanced coal plants may become increasingly common

in coming years, though uncertainties about construction time periods and commercial viability

in the near future lead the NRC staff to believe that IGCC is an unlikely alternative to CNS

license renewal (EIA, 2009a). For plants whose licenses expire at later dates, IGCC (with or

without carbon capture and storage) may prove to be a viable alternative.

8.4.3 New Nuclear

In its ER, NPPD indicated that it is unlikely that a nuclear alternative could be sited, constructed,

and operational by the time CNS's operating license expires in 2014 (NPPD, 2008). Sources in

the nuclear industry have recently indicated.that reactor projects currently under development

are probably 8 or 9 years from completion (Nucleonics Week, 2008), or possibly online in the

2016-2017 time frame. A plant currently under development would also require additional time

to develop an application. Given the relatively short time remaining on the current CNS

operating license, the NRC staff has not evaluated new nuclear generation as an alternative to

license renewal.

NUREG-1437, Supplement 41 8-30 July 2010
Environmental Impacts of Alternatives

8.4.4 Energy Conservation and Energy Efficiency

Though often used interchangeably, energy conservation and energy efficiency are different

concepts. Energy efficiency means deriving a similar level of services by using less energy,

while energy conservation indicates a reduction in energy consumption. Both fall into a larger

category known as demand-side management. Demand-side management measures address

energy end uses-unlike energy supply alternatives discussed in previous sections.

Demand-side management can include measures that: (1) shift energy consumption to different

times of the day to reduce peak loads; (2) interrupt certain large customers during periods of

high demand; (3) interrupt certain appliances during high demand periods; (4) replace older,

less efficient appliances, lighting, or control systems; and (5) encourage customers to switch

from gas to electricity for water heating and other similar measures that utilities use to boost

sales.

Unlike other alternatives to license renewal, the GElS notes that conservation is not a discrete

power generating source; it represents an option that States and utilities may use to reduce their

need for power generation capability (NRC, 1996).

While NPPD does state that demand-side management is encouraged by the utility, and that in

2007 there was over a 500 MWe demand reduction (NPPD, 2008), it is unlikely that increased

energy efficiency in the State of Nebraska will have grown enough to offset the loss of CNS by

the license expiration in 2014. Because of this, the NRC staff has not evaluated energy

conservation and efficiency as a discrete alternative to license renewal. It has, however, been

considered as a component of the combination alternative.

8.4.5 Purchased Power

In its ER, NPPD indicated that purchased electrical power is, in theory, a potential alternative to

CNS license renewal; however, for the 2014 to 2034 time frame of CNS's renewal, there are no

guaranteed available power sources to replace the 816 MWe that CNS provides. NPPD

indicates that most of its purchased power supply is imported from Canada, which is expected

to decrease over the next two decades. Within the State of Nebraska, two newly licensed

coal-fired plants starting production in 2009 and 2012 combined will barely meet the amount of

electricity currently provided by CNS. Because of the lack of assured availability of purchased

electrical power, the NRC staff has not evaluated purchased power as an alternative to license

renewal.

8.4.6 Solar Power

Solar technologies use the sun's energy to produce electricity. Currently, the CNS site receives

approximately 3.8 to 4.2 kilowatt-hours (kWh) per square meter per day, as does most of the

eastern portion of Nebraska (NREL, 2008), for solar collectors oriented at an angle equal to the

installation's latitude. Since flat-plate photovoltaics tend to be roughly 25 percent efficient, a

solar-powered alternative will require at least 11,620 ac (4,700 ha) of collectors to provide an

amount of electricity equivalent to that generated by CNS. Space between parcels and

associated infrastructure increase this land requirement. This amount of land, while large, is

consistent with the land required for coal and natural gas fuel cycles. In the GELS, the NRC staff

noted that, by its nature, solar power is intermittent (i.e., it does not work at night and cannot

serve baseload when the sun is not shining), and the efficiency of collectors varies greatly with

weather conditions. A solar-powered alternative will require energy storage or backup power

supply to provide electric power at night. Given the challenges in meeting baseload

July 2010 8-31 NUREG-1437, Supplement 41
Environmental Impacts of Alternatives

requirements, the NRC staff did not evaluate solar power as an alternative to license renewal of

CNS.

8.4.7 Biomass Waste

In 1999, DOE researchers estimated that Nebraska has biomass fuel resources consisting of

forest, mill, agricultural, and urban residues, as well as energy crop potential. Excluding

potential energy crops, DOE researchers projected that Nebraska had 16,634,800 tons

(15,091,000 MT) of plant-based biomass available at 50 dollars per ton delivered

(Walsh et al., 2000) (costs are in 1995 dollars). The Bioenergy Feedstock Development

Program at Oak Ridge National Laboratory estimates that each air-dry pound of wood residue

produces approximately 6,400 British thermal units (Btu) of heat (ORNL, 2007). Assuming 33

percent conversion efficiency, using all biomass available in Nebraska at 50 dollars per ton-the

maximum price the researchers considered-would generate roughly 20.6 terawatt hours of

electricity.

Walsh et al. (2000) note that these estimates of biomass capacity contain substantial

uncertainty, and that potential availability does not mean biomass will actually be available at

the prices indicated or that resources will be usably free of contamination. Some of these plant

wastes already have reuse value, and would likely be more costly to deliver because of

competition. Others, such as forest residues, may prove unsafe and unsustainable to harvest on

a regular basis (the vast majority of biomass capacity in Nebraska, however, comes from

agricultural residues, with very little potential from forest residues). It is likely that the available

resource potential is much less than the estimate totals in Walsh et al., and the total resource is

not likely to be sufficient to substitute for the capacity provided by CNS. As a result, the NRC

staff has not considered a biomass-fired alternative to CNS license renewal.

8.4.8 Hydroelectric Power

According to researchers at the Idaho National Energy and Environmental Laboratory (INEEL),

Nebraska has an estimated 345 MWe of technically available, undeveloped hydroelectric

resources at 45 sites throughout the State (INEEL, 1997). Most of these sites have a potential

capacity of less than 1 MWe, although the largest site in Nebraska is capable of providing

22 MWe. Given that the available hydroelectric potential in the State of Nebraska constitutes

less than one-half of the generating capacity of CNS, the NRC staff did not evaluate hydropower

as an alternative to license renewal.

8.4.9 Wave and Ocean Energy

Wave and ocean energy has generated considerable interest in recent years. Ocean waves,

currents, and tides are often predictable and reliable. Ocean currents flow consistently, while

tides can be predicted months and years in advance with well-known behavior in most coastal

areas. Most of these technologies are in relatively early stages of development, and while some

results have been promising, they are not likely to be able to replace the capacity of CNS by the

time its license expires. While testing of new technologies to produce electricity from the ocean

continues, and because the CNS site is located far from any ocean, the NRC did not consider

wave and ocean energy as an alternative to CNS license renewal.

NUREG-1437, Supplement 41 8-32 July 2010
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8.4.10 Geothermal Power

Although geothermal energy has an average capacity factor of 90 percent and can be used for

baseload power where available, geothermal electric generation is limited by the geographical

availability of geothermal resources (NRC, 1996). Nebraska has some geothermal potential in a

heating and thermal capacity, but it does not have geothermal electricity potential for

development (DOE, 2007). The NRC staff concluded that geothermal energy is not a

reasonable alternative to license renewal at CNS.

8.4.11 Municipal Solid-Waste

Municipal solid-waste combustors use three types of technologies: mass burn, modular, and

refuse-derived fuel. Mass burning is used most frequently in the United States and involves little

sorting, shredding, or separation. Consequently, toxic or hazardous components present in the

waste stream are combusted, and toxic constituents are exhausted to the air or become part of

the resulting solid wastes. Currently, approximately 89 waste-to-energy plants operate in the

United States. These plants generate approximately 2,700 MWe, or an average of 30 MWe per

plant (Integrated Waste Services Association, 2007). More than 27 average-sized plants will be

necessary to provide the same level of output as the other alternatives to CNS license renewal.

Estimates in the GElS suggest that the overall level of construction impact from a

waste-fired plant will be approximately the same as that for a coal-fired power plant.

Additionally, waste-fired plants have the same or greater operational impacts than coal-fired

technologies (including impacts on the aquatic environment, air, and waste disposal). The initial

capital costs for municipal solid-waste plants are greater than for comparable

steam-turbine technology at coal-fired facilities or at wood-waste facilities because of the need

for specialized waste separation and handling equipment (NRC, 1996).

The decision to burn municipal waste to generate energy is driven by the need for an alternative

to landfills rather than energy considerations. The use of landfills as a waste disposal option is

likely to increase as energy prices increase; however, it is possible that municipal waste

combustion facilities may become attractive again.

Regulatory structures that once supported municipal solid-waste incineration no longer exist.

The Tax Reform Act of 1986 made capital-intensive projects, such as municipal-waste

combustion facilities, more expensive relative to less expensive waste disposal alternatives,

such as landfills. Also, the 1994 Supreme Court decision C&A Carbone, Inc. v. Town of

Clarkstown, New York, struck down local flow control ordinances that required waste to be

delivered to specific municipal waste combustion facilities rather than landfills that may have

had lower fees. In addition, environmental regulations have increased the cost to construct and

maintain municipal waste combustion facilities.

Given the small average installed size of municipal solid-waste plants and the unfavorable

regulatory environment, the NRC staff does not consider municipal solid-waste combustion to

be a feasible alternative to CNS license renewal.

8.4.12 Biofuels

In addition to wood and municipal solid-waste fuels, there are other concepts for

biomass-fired electric generators, including conversion to liquid biofuels and biomass

gasification. In the GElS, the NRC staff indicates that none of these technologies progressed to

July 2010 8-33 NUREG-1437, Supplement 41
Environmental Impacts of Alternatives

the point of being competitive on a large scale or of being reliable enough to replace a baseload

plant such as CNS. After reevaluating current technologies, the NRC staff finds other

biomass-fired alternatives as still unable to reliably replace the CNS capacity. For this reason,

the NRC staff does not consider other biomass-derived fuels to be feasible alternatives to CNS

license renewal.

8.4.13 Oil-Fired Power

The EIA projects that oil-fired plants will account for very few of new generation capacity

constructed in the United States during the 2008 to 2030 time period. Furthermore, EIA does

not project that oil-fired power will account for any significant additions to capacity (EIA, 2009b).

The variable costs of oil-fired generation are found to be greater than those of nuclear or

coal-fired operations, and oil-fired generation has greater environmental impacts than natural

gas-fired generation. In addition, future increases in oil prices are expected to make oil-fired

generation increasingly more expensive (EIA, 2009b). The high cost of oil has prompted a

steady decline in its use for electricity generation. Thus, the NRC staff does not consider

oil-fired generation as an alternative to CNS license renewal.

8.4.14 Fuel Cells

Fuel cells oxidize fuels without combustion and its environmental side effects. Power is

produced electrochemically by passing a hydrogen-rich fuel over an anode and passing air

(or oxygen) over a cathode and then separating the two by an electrolyte. The only byproducts

(depending on fuel characteristics) are heat, water, and CO2. Hydrogen fuel can come from a

variety of hydrocarbon resources by subjecting them to steam under pressure. Natural gas is

typically used as the source of hydrogen.

At the present time, fuel cells are not economically or technologically competitive with other

alternatives for large-scale electricity generation. The EIA projects that fuel cells may cost

$5,374 per installed kilowatt (total overnight costs3) (EIA, 2009b), or 3.5 times the construction

cost of new coal-fired capacity, and 7.5 times the cost of new, advanced gas-fired,

combined-cycle capacity. In addition, fuel cell units are likely to be small (the EIA reference

plant is 10 MWe). While it may be possible to use a distributed array of fuel cells to provide an

alternative to CNS, it would be extremely costly to do so. Accordingly, the NRC staff does not

consider fuel cells to be an alternative to CNS license renewal.

8.4.15 Delayed Retirement

NPPD has no plans to retire generating capacity in Nebraska prior to 2014 (NPPD, 2008). As a

result, delayed retirement is not a feasible alternative to license renewal. Other generation

capacity may be retired prior to the expiration of the CNS license, but this capacity is likely to be

older, less efficient, and without modern emissions controls.

8.5 NO-ACTION ALTERNATIVE

This section examines environmental effects that occur if NRC takes no action. No action in this

case means that NRC does not issue a renewed operating license for CNS and the license

3 Overnight cost is the cost of a construction project if no interest was incurred during construction.

NUREG-1437, Supplement 41 8-34 July 2010
Environmental Impacts of Alternatives

expires at the end of the current license term, in 2014. If NRC takes no action, the plant will

shutdown at or before the end of the current license. After shutdown, plant operators will initiate

decommissioning according to 10 CFR 50.82.

The NRC staff notes that no action is the only alternative that is considered in-depth that does

not satisfy the purpose and need for this SEIS, because it does not provide power generation

capacity nor would it meet the needs currently met by CNS or the alternatives evaluated in

Sections 8.1 through 8.3. Assuming that a need currently exists for the power generated by

CNS, the no-action alternative would require the appropriate energy planning decision makers

to rely on an alternative to replace the capacity of CNS or reduce the need for power.

This section addresses only those impacts that arise directly as a result of plant shutdown. The

environmental impacts from decommissioning and related activities have already been

addressed in several other documents, including the Final Generic Environmental Impact

Statement on Decommissioning of Nuclear Facilities, NUREG-0586, Supplement 1

(NRC, 2002); the license renewal GElS (Chapter 7, NRC, 1996); and Chapter 7 of this SEIS.

These analyses either directly address or bound the environmental impacts of decommissioning

whenever NPPD ceases operating CNS.

The NRC staff notes that, even with a renewed operating license, CNS will eventually shut

down, and the environmental effects addressed in this section will occur at that time. Since

these effects have not otherwise been addressed in this SEIS, the impacts will be addressed in

this section. As with decommissioning effects, shutdown effects are expected to be similar

whether or not they occur at the end of the current license or at the end of a renewed license.

8.5.1 Air Quality

When the plant stops operating, there will be a reduction in emissions from activities related to

plant operation, such as use of diesel generators and employee vehicles. In Chapter 4, the NRC

staff determined that these emissions would have a SMALL impact on air quality during the

renewal term; therefore, if emissions decrease, the impact to air quality would also decrease

and would be a SMALL impact.

8.5.2 Ground Water Use and Quality

The use of ground water would diminish as plant personnel are removed from the site and

operations cease. Some consumption of ground water may continue as a small staff remains

onsite to maintain facilities prior to decommissioning. Overall impacts would be smaller than

during operations, but would remain SMALL.

8.5.3 Surface Water Use and Quality

The rate of consumptive use of surface water would decrease as the plant is shut down and the

reactor cooling system continues to remove the heat of decay. Wastewater discharges would

also be reduced considerably. Shutdown would reduce the already SMALL impact on surface

water resources and quality.

July 2010 8-35 NUREG-1437, Supplement 41
Environmental Impacts of Alternatives

8.5.4 Aquatic and Terrestrial Resources

8.5.4.1 Aquatic Ecology

If the plant were to cease operating, impacts to aquatic ecology would decrease, as the plant

would withdraw and discharge less water than it does during operations. Shutdown would

reduce the already SMALL impacts to aquatic ecology.

8.5.4.2 Terrestrial Ecology

Terrestrial ecology impacts would be SMALL. No additional land disturbances on or offsite

would occur.

8.5.5 Human Health

Human health risks would be smaller following plant shutdown. The plant, which is currently

operating within regulatory limits, would emit less gaseous and liquid radioactive material to the

environment. In addition, following shutdown, the variety of potential accidents at the plant

(radiological or industrial) would be reduced to a limited set associated with shutdown events

and fuel handling and storage. In Chapter 4 of this SEIS, the NRC staff concluded that the

impacts of continued plant operation on human health would be SMALL. In Chapter 5, the NRC

staff concluded that the impacts of accidents during operation were SMALL. Therefore, as

radioactive emissions to the environment decrease, and as likelihood and variety of accidents

decrease following shutdown, the NRC staff concludes that the risk to human health following

plant shutdown would be SMALL.

8.5.6 Socioeconomics

8.5.6.1 Land Use

Plant shutdown would not affect onsite land use. Plant structures and other facilities would

remain in place until decommissioning. Most transmission lines connected to CNS would remain

in service after the plant stops operating. Maintenance of most existing transmission lines would

continue as before. Impacts on land use from plant shutdown would be SMALL.

8.5.6.2 Socioeconomics

Plant shutdown would have an impact on socioeconomic conditions in the region around CNS.

Plant shutdown would eliminate approximately 750 jobs and would reduce tax revenue in the

region. The loss of these contributions, which may not entirely cease until after

decommissioning, would have a SMALL to MODERATE impact. See Appendix J to

NUREG-0586, Supplement 1 (NRC, 2002), for an additional discussion of the potential

socioeconomic impacts of plant decommissioning.

8.5.6.3 Transportation

Traffic volumes on the roads in the vicinity of CNS would be reduced after plant shutdown. Most

of the reduction in traffic volume would be associated with the loss of jobs at the plant.

Deliveries to the plant would be reduced until decommissioning. Transportation impacts would

be SMALL as a result of plant shutdown. Transportation impacts would increase if a new energy

facility were constructed at the CNS site or in the immediate vicinity. These impacts are

addressed in Sections 8.1 to 8.3. Such impacts may be SMALL to MODERATE, but of short

duration.

NUREG-1437, Supplement 41 8-36 July 2010
Environmental Impacts of Alternatives

8.5.6.4 Aesthetics

Plant structures and other facilities would remain in place until decommissioning. Noise caused

by plant operation would cease. Aesthetic impacts of plant closure would be SMALL.

8.5.6.5 Historic and Archaeological Resources

Impacts from the no-action alternative on historic and archaeological resources would be

SMALL, since CNS would be decommissioned. A separate environmental review would be

conducted for decommissioning. That assessment would address the protection of historic and

archaeological resources.

8.5.6.6 Environmental Justice

Termination of power plant operations would not disproportionately affect minority and

low-income populations outside the immediate vicinity of CNS. Minority and low-income

populations are generally concentrated in urban areas. Thus, impacts from plant shutdown

would be SMALL. See Appendix J of NUREG-0586, Supplement 1 (NRC, 2002), for additional

discussion of these impacts.

8.5.7 Waste Management

If the no-action alternative were implemented, the generation of high-level waste would stop and

generation of low-level and mixed waste would decrease. Impacts from implementation of the

no-action alternative are expected to be SMALL.

Table 8-4 provides a summary of the environmental impacts of the no-action alternative

compared to continued operation of CNS.

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

Operation of Cooper Nuclear Station

No Action Continued CNS Operation

Air quality SMALL SMALL

Ground water SMALL SMALL

Surface water SMALL SMALL

Aquatic and terrestrial resources SMALL SMALL

Human health SMALL SMALL

Socioeconomics SMALL to MODERATE SMALL

Waste management SMALL SMALL

8.6 ALTERNATIVES SUMMARY

In this chapter, the NRC staff considers the following alternatives to CNS license renewal:

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

alternative. No action by NRC and its effects were also considered. The impacts for all

alternatives to CNS license renewal are summarized in Table 8-6 on the following page.

July 2010 8-37 NUREG-1437, Supplement 41
Environmental Impacts of Alternatives

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

Impact Area

00 0 D

. 0o

0 0 " E o

a 0

a C U CDCl) 0 0

Alternative <

License renewal SMALL SMALL SMALL SMALL SMALL SMALL Small

Supercritical coal-fired alternative at MODERATE SMALL SMALL SMALL to SMALL SMALL to MODERATE

CNS site MODERATE LARGE

SMALL to SMALL to SMALL to Gas-fired alternative at the CNS site MODERATE SMALL SMALL MODERATE SMALL MODERATE SMALL

SMALL to SMALL SMALL SMALL to SMALL to SMALL to Combination of alternatives MODERATE LARGE MODERATE MODERATE SMALL

SMALL to

No-action alternative SMALL SMALL SMALL SMALL SMALL MODERATE SMALL

NUREG-1437, Supplement 41 8-38 July 2010
Environmental Impacts of Alternatives

The environmental impacts of the proposed action (issuing a renewed CNS operating license)

would be SMALL for all impact categories, except for the Category 1 issue of collective offsite

radiological impacts from the fuel cycle, high-level waste, and spent fuel disposal. The NRC

staff did not add a single significant level to these impacts, but the Commission determined

them to be Category 1 issues nonetheless.

The coal-fired alternative is not an environmentally favorable alternative due to impacts on air

quality from NO), SO,, PM, PAHs, CO, C0 2 , and mercury (and their corresponding human

health impacts); and due to construction impacts to aquatic, terrestrial, and potential historic and

archaeological resources.

The gas-fired alternative would have slightly lower air emissions, lower waste management, and

lower socioeconomic impacts than the coal-fired alternative. The combination alternative would

have lower air emissions and waste management impacts than both the gas-fired and coal-fired

alternatives; however, the combination alternative would have relatively high construction

impacts to aquatic, terrestrial, and potential historic and archaeological resources due mainly to

the wind turbine component.

In conclusion, the environmentally preferred alternative in this case is the license renewal of

CNS. All other alternatives capable of meeting the needs currently served by CNS entail

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

alternative necessitates the implementation of one or a combination of alternatives, all of which

have greater impacts than the proposed action, the NRC staff concludes that the no-action

alternative will have environmental impacts greater than or equal to the proposed license

renewal action.

8.7 REFERENCES

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

Protection Regulations for Domestic Licensing and Related Regulatory Functions."

Department of Energy (DOE). 2007. "GeoPowering the West: Nebraska State Profile." Available

URL: http://wwwl.eere.energy.gov/qeothermal/qpw/profile nebraska.html (accessed July 2009).

Energy Information Administration (EIA). 2006. "Cost and Quality of Fuel for Electric Plants,

2004 and 2005," DOE/EIA-0191(2005), Washington, D.C., Agencywide Documents Access and

Management System (ADAMS) No. ML082880730. Available URL:

http://www.eia.doe.qov/cneaf/electricitv/cq/cqa2005.pdf (accessed July 2009).

Energy Information Administration (EIA). 2009a. "Annual Energy Outlook 2009 With Projections

to 2030," DOE/EIA-0383(2009), Washington, D.C. Available URL:

http://www.eia.doe.gov/oiaf/archive/aeo09/pdf/0383(2009).pdf (accessed July 2009).

Energy Information Administration (EIA). 2009a. "Summary Statistics for the United States."

Table ES1 from Electric Power Annual with Data for 2007. Available URL:

(accessed June 2009).

Energy Information Administration (EIA). 2009c. "Table A4. Approximate Heat Content of

Natural Gas, 1949-2008 (Btu per Cubic Foot)." Available URL:

http://www.eia.doe.gov/emeu/aer/txt/ptb1304.html (accessed July 2009).

Energy Information Administration (EIA). 2009d. "Annual Energy Outlook 2009, Electricity

Demand." Available URL: http://www.eia.doe.gov/oiaf/archive/aeoO9/electricity.html (accessed

December 2009).

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Environmental Protection Agency (EPA). 1998. Compilation of Air Pollutant Emission Factors,

Volume 1: Stationary Point and Area Sources: AP 42, Fifth Edition. "Section 1.1: Bituminous

and Subbituminous Coal Combustion: Final Section Supplement E," Washington, D.C.

Environmental Protection Agency (EPA). 2000a. "Notice of Regulatory Determination on Wastes

from the Combustion of Fossil Fuels," Federal Register, Vol. 65, pp. 32214-32237, Washington,

D.C.

Environmental Protection Agency (EPA). 2000b. "Regulatory Finding on the Emissions of

Hazardous Air Pollutants from Electric Utility Steam Generating Units," Federal Register,

Vol. 65, No. 245, pp. 79825-79831, Washington, D.C., December 20, 2000.

I Environmental Protection Agency (EPA). 2008. "New Source Review (NSR)," ADAMS

No.ML083450073. Available URL: http://www.epa.qov/nsr/ (accessed June 2009)

I General Electric (GE). 2007. "Gas Turbine and Combined Cycle Products," May 2007. Available

URL:

httrt:I/www.gepower.com/prod serv/products/gas turbines cc/en/downloads/gasturbine cc pro

ducts.pd (accessed June 2009).

Idaho National Engineering and Environmental Laboratory (INEEL). 1997. "U.S. Hydropower

Resource Assessment for Nebraska," DOE/ID-1 0430(NE). Available URL:

http://hvdropower.inl.qov/resourceassessment/pdfs/states/ne.pdf (accessed July 2009).

Nebraska Department of Environmental Quality (NDEQ). 2003. "Environmental Guidance

Document: Air Quality Permit Process," October 2003. Available URL:

http:/lwww.dea.state.ne.us/Publica.nsf/c4afc76e4eO77e11862568770059b73f/c754133adl 2af7

2a06256dc1 006371 fO/$FILE/03-148.pdf (accessed August 2009).

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

Station, Appendix E - Applicant's Environmental Report, Operating License Renewal Stage,"

Columbus, Nebraska, September 24, 2008, ADAMS Accession Nos. ML083030246 (main

report) and ML083030252 (attachments).

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

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

ADAMS Accession Nos. ML040690705 and ML040690738.

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

for License Renewal of Nuclear Plants, Main Report, "Section 6.3 - Transportation, Table 9.1,

Summary of Findings on NEPA Issues for License Renewal of Nuclear Power Plants, Final

Report," NUREG-1437, Volume 1, Addendum 1, Washington, D.C.

U.S. Nuclear Regulatory Commission (NRC). 2002. Generic Environmental Impact Statement

on Decommissioning of Nuclear Facilities: Supplement 1, "Regarding the Decommissioning of

Nuclear Power Reactors," NUREG-0586, Supplement 1, Volumes 1 and 2, Washington, D.C.

U.S. Office of Management and Budget (OMB). 2007. "Detailed Information on the Low Income

Home Energy Assistance Program Assessment," ADAMS Accession No. ML082880730.

Available URL: http://www.whitehouse.qov/omb/expectmore/detail/10001059.2003.html

(accessed June 2009).

Walsh, M.E., R.L. Perlack, A. Turhollow, D. de la Torre Ugarte, D.A. Becker, R.L. Graham, S.A.

Slinsky, and D.E. Ray (Walsh et. al.). 2000. "Biomass Feedstock Availability in the United

States: 1999 State Level Analysis," ADAMS Accession No. ML083050223. Available URL:

http://bioenergy.ornl.qov/resourcedata/index.html (accessed July 2009).

NUREG-1437, Supplement 41 8-40 July 2010
9.0 CONCLUSION

This final supplemental environmental impact statement (SEIS) contains the environmental

review of the Nebraska Public Power District (NPPD) application for a renewed operating

license for Cooper Nuclear Station (CNS), as required by the Code of Federal Regulations

(CFR), Part 51 of Title 10 (10 CFR Part 51) and the U.S. Nuclear Regulatory Commission's

(NRC) regulations that implement the National Environmental Policy Act (NEPA). This chapter

presents conclusions and recommendations from the site-specific environmental review of CNS

and summarizes site-specific environmental issues of license renewal that were identified during

the review. The environmental impacts of license renewal are summarized in Section 9.1; a

comparison of the environmental impacts of license renewal and energy alternatives is

presented in Section 9.2; unavoidable impacts of license renewal, energy alternatives, and

resource commitments are discussed in Section 9.3; and conclusions and NRC staff

recommendations are presented in Section 9.4.

9.1 ENVIRONMENTAL IMPACTS OF LICENSE RENEWAL

The staff's review of site-specific environmental issues in this SEIS leads to the conclusion that

issuing a renewed license would have SMALL impacts for the eight Category 2 issues

applicable to license renewal at CNS, as well as environmental justice and chronic effects of

electromagnetic fields (EMF).

Mitigation measures were considered for each Category 2 issue, as applicable. For ground

water, no measures to mitigate the environmental impacts of plant operation were found to be

warranted because of the limited radius of influence of CNS wells. NPPD has implemented

some impingement and entrainment mitigation measures, such as dual flow screens with

modified Ristroph fish buckets and plans to install a fish handling system, which the staff

concludes will minimize impacts on aquatic resources. The NRC staff identified a variety of

measures that could mitigate potential acute EMF impacts resulting from continued operation of

the CNS transmission lines, including erecting barriers along the length of the transmission line

to prevent unauthorized access to the ground beneath the conductors and installing road signs

at road crossings. These mitigation measures could reduce human health impacts by

minimizing public exposures to electric shock hazard.

The staff identified a variety of measures that could mitigate the potential impacts of

thermophilic microbiological organisms resulting from continued operation of CNS. These

mitigation measures include periodically monitoring for thermophilic microbiological organisms

in the water and sediments near the discharge, as well as prohibiting recreational use near the

discharge plume. These mitigation measures could reduce human health impacts by minimizing

public exposures to thermophilic microbiological organisms. The NRC staff did not identify any

cost-benefit studies applicable to the mitigation measures mentioned above.

The NRC staff also considered cumulative impacts of past, present, and reasonably foreseeable

future actions, regardless of what agency (Federal or non-Federal) or person undertakes them.

The staff concluded that cumulative impacts of CNS's license renewal would be SMALL for

potentially affected resources.

July 2010 9-1 NUREG-1437, Supplement 41
Conclusion

9.2 COMPARISON OF ENVIRONMENTAL IMPACTS OF LICENSE RENEWAL AND

ALTERNATIVES

In the conclusion to Chapter 8, the NRC staff determined that impacts from license renewal are

generally less than the impacts of alternatives to license renewal, with the exception of energy

conservation and energy efficiency. In comparing possible environmental impacts from

supercritical coal-fired generation, natural gas combined-cycle generation, energy conservation

and energy efficiency, and a combination alternative that includes natural gas, conservation and

efficiency, upgrades to existing hydroelectric dams, and environmental impacts from license

renewal, it was found that the energy conservation and energy efficiency alternative would result

in the lowest environmental impact. Based on the NRC staffs analysis, it was found that the

impacts of license renewal are reasonable in light of the impacts from alternatives to the license

renewal of CNS.

9.3 RESOURCE COMMITMENTS

9.1.1 Unavoidable Adverse Environmental Impacts

Unavoidable adverse environmental impacts are impacts that would occur after implementation

of all feasible mitigation measures. Implementing any of the energy alternatives considered in

this SEIS, including the proposed action, would result in some unavoidable adverse

environmental impacts.

Minor unavoidable adverse impacts on air quality would occur due to emission and release of

various chemical and radiological constituents from power plant operations. Nonradiological

emissions resulting from power plant operations are expected to comply with Environmental

Protection Agency (EPA) emissions standards, though the alternative of operating a

fossil-fueled power plant in some areas may worsen existing attainment issues. Chemical and

radiological emissions would not exceed the National Emission Standards for Hazardous Air

Pollutants.

During nuclear power plant operations, workers and members of the public would face

unavoidable exposure to radiation and hazardous and toxic chemicals. Workers would be

exposed to radiation and chemicals associated with routine plant operations and the handling of

nuclear fuel and waste material. Workers would have higher levels of exposure than members

of the public, but doses would be administratively controlled and would not exceed standards or

administrative control limits. In comparison, the alternatives involving the construction and

operation of a non-nuclear power generating facility would also result in unavoidable exposure

to hazardous and toxic chemicals to workers and the general public.

The generation of spent nuclear fuel and waste material, including low-level radioactive waste,

hazardous waste, and nonhazardous waste would also be unavoidable. In comparison,

hazardous and nonhazardous wastes would also be generated at non-nuclear power generating

facilities. Wastes generated during plant operations would be collected, stored, and shipped for

suitable treatment, recycling, or disposal in accordance with applicable Federal and State

regulations. Due to the costs of handling these materials, power plant operators would be

expected to conduct all activities and optimize all operations in a way that generates the

smallest amount of waste possible.

NUREG-1437, Supplement 41 9-2 July 2010
Conclusion

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

Maintenance and Enhancement of Long-Term Productivity

The operation of power generating facilities would result in short-term uses of the environment

as described in Chapters 4, 5, 6, 7, and 8. "Short-term" is the period of time that continued

power generating activities take place.

Power plant operations require short-term use of the environment and commitment of

resources, and also commit certain resources (e.g., land and energy) indefinitely or

permanently. Certain short-term resource commitments are substantially greater under most

energy alternatives, including license renewal, than under the No-Action alternative because of

the continued generation of electrical power and the continued use of generating sites and

associated infrastructure. During operations, all energy alternatives require similar relationships

between local short-term uses of the environment and the maintenance and enhancement of

long-term productivity.

Air emissions from power plant operations introduce small amounts of radiological and

nonradiological constituents to the region around the plant site. Over time, these emissions

would result in increased concentrations and exposure, but are not expected to impact air

quality or radiation exposure to the extent that public health and long-term productivity of the

environment would be impaired.

Continued employment, expenditures, and tax revenues generated during power plant

operations directly benefit local, regional, and State economies over the short term. Local

governments investing project-generated tax revenues into infrastructure and other required

services could enhance economic productivity over the long term.

The management and disposal of spent nuclear fuel, low-level radioactive waste, hazardous

waste, and nonhazardous waste requires an increase in energy and consumes space at

treatment, storage, or disposal facilities. Regardless of the location, the use of land to meet

waste disposal needs would reduce the long-term productivity of the land.

Power plant facilities are committed to electricity production over the short term. After

decommissioning these facilities and restoring the area, the land could be available for other

future productive uses.

9.1.3 Irreversible and Irretrievable Commitments of Resources

This section describes the irreversible and irretrievable commitment of resources that have

been identified in this SEIS. Resources are irreversible when primary or secondary impacts limit

the future options for a resource. An irretrievable commitment refers to the use or consumption

of resources that are neither renewable nor recoverable for future use. Irreversible and

irretrievable commitment of resources for electrical power generation include the commitment of

land, water, energy, raw materials, and other natural and man-made resources required for

power plant operations. In general, the commitment of capital, energy, labor, and material

resources are also irreversible.

The implementation of any of the energy alternatives considered in this SEIS would entail the

irreversible and irretrievable commitment of energy, water, chemicals, and in some cases, fossil

fuels. These resources would be committed during the license renewal term and over the entire

life cycle of the power plant and would be unrecoverable.

July 2010 9-3 NUREG-1437, Supplement 41
Conclusion

Energy expended would be in the form of fuel for equipment, vehicles, and power plant

operations and electricity for equipment and facility operations. Electricity and fuel would be

purchased from offsite commercial sources. Water would be obtained from existing water supply

systems. These resources are readily available, and the amounts required are not expected to

deplete available supplies or exceed available system capacities.

The irreversible and irretrievable commitment of material resources includes materials that

cannot be recovered or recycled, materials that are rendered radioactive and cannot be

decontaminated, and materials consumed or reduced to unrecoverable forms of waste. None of

the resources used by these power generating facilities, however, are in short supply, and for

the most part are readily available.

Various materials and chemicals derived from chemical vendors, including acids and caustics,

are required to support the operation's activities. Their consumption is not expected to affect

local, regional, or national supplies.

The treatment, storage, and disposal of spent nuclear fuel, low-level radioactive waste,

hazardous waste, and nonhazardous waste require the irretrievable commitment of energy and

fuel and will result in the irreversible commitment of space in disposal facilities.

9.4 RECOMMENDATIONS

Based on: (1) the analysis and findings in the GElS; (2) information provided in the

environmental report submitted by NPPD; (3) consultation with Federal, State, and local

agencies; (4) a review of pertinent documents and reports; and (5) consideration of public

comments received, the recommendation of the NRC staff is for the Commission to determine

that the above considered adverse environmental impacts of license renewal are not so great

that preserving the option of license renewal for energy planning decision makers (i.e., State

regulatory agencies and NPPD) would be unreasonable.

NUREG-1437, Supplement 41 9-4 July 2010
10.0 LIST OF PREPARERS

This supplemental environmental impact statement (SEIS) was prepared by members of the

Office of Nuclear Reactor Regulation, with assistance from other U.S. Nuclear Regulatory

Commission (NRC) organizations and with contract support from Pacific Northwest National

Laboratory.

Table 10-1 provides a list of NRC staff that participated in the development of the SEIS. Pacific

Northwest National Laboratory provided contract support for the severe accident mitigation

alternatives (SAMAs) analysis, presented in Chapter 5 and Appendix F.

Table 10-1. List of Preparers

Name

Bo Pham

Dave Pelton

Andrew Imboden

Emmanuel Sayoc

Tam Tran

Bennett Brady

Dennis Beissel

Dennis Logan

Affiliation

Nuclear Regulatory Commission

Nuclear Reactor Regulation

Nuclear Reactor Regulation

Nuclear Reactor Regulation

Nuclear Reactor Regulation

Nuclear Reactor Regulation

Nuclear Reactor Regulation

Nuclear Reactor Regulation

Nuclear Reactor Regulation

Function or Expertise

Stephen Klementowicz

Jennifer Davis

Richard Bulavinetz

Ekaterina Lenning

Robert Palla

Jeffrey Rikhoff

Andrew Stuyvenburg

Allison Travers

Nuclear Reactor Regulation

Nuclear Reactor Regulation

Nuclear Reactor Regulation

Nuclear Reactor Regulation

Nuclear Reactor Regulation

Nuclear Reactor Regulation

Nuclear Reactor Regulation

Nuclear Reactor Regulation

Branch Chief

Branch Chief

Branch Chief

Project Manager

Project Manager

Project Manager

Hydrology

Aquatic Ecology; Terrestrial

Ecology

Radiation Protection; Human

Health

Historic and Archaeological

Resources

Terrestrial Ecology

Air Quality

Severe Accident Mitigation

Alternatives

Socioeconomics; Land Use;

Environmental Justice;

Historic and Archaeological

Resources

Alternatives

Alternatives

July 2010 10-1 NUREG-1437, Supplement 41
List of Preparers

Name Affiliation Function or Expertise

Nuclear Regulatory Commission

SAMA Contractor(a)

Steve Short Pacific Northwest National Laboratory Severe Accident Mitigation

Alternatives

Bruce Schmitt Pacific Northwest National Laboratory Severe Accident Mitigation

Alternatives

Jon Young Pacific Northwest National Laboratory Severe Accident Mitigation

Alternatives

(a) Pacific Northwest National Laboratory is operated by Batelle for the U.S. Department of Energy

NUREG-1437, Supplement 41 10-2 July 2010
11.0 INDEX

accidents ................................................................................................... xix, 5-1, 5-2, 5-3, B-7

aesthetic ....................................................... xviii

alternatives ............................... iii, xix, xx, xxi, 1-6, 5-2, 8-6, 8-25, 9-1, 9-2, 9-3, 10-1, 12-1, B-7

archaeological resources ................................................................................. xix, 1-6, B-7, D-1

Barnwell .................................................................................................................................. 2-7

biota ................................................................................................................................... B-2

burnup ................................................................................................................................. B-10

chronic effects ............................................................................. 1-4, 4-14, 4-36, 4-48, 9-1, B-6

closed-cycle cooling ............................................................ B-4

cultural resources .................................................................................................................. C -1

decom m issioning ................................................................................................ 9-3, B-10, B-11

design-basis accidents ........................................................................................... xxiv, 5-1, 5-2

discharges .............................................................................................................. 9-1, B-2, B-7

dose .......................................................................................... 2-7, 4-16, 4-17, B-6, B-8, B-9

education ............................................................................................................. 4-19, 4-21, B-7

electrom agnetic fields ........................................................... 1-4, 4-12, 4-38, 4-50, 9-1, B-5, B-7

entrainm ent .................................................................................................................... B-2, B-3

environm ental justice .......................................................................... 1-4, 4-21, 4-27, 9-1, B-12

EPA ....................................... ..... xxxi, 2-7, 4-16, B-10, C-1

GElS ................ xx, xxi, xxii, xxiii, xxiv, xxvii, xxxi, 1-3, 1-4, 1-6, 1-10, 4-1, 4-3,4-5, 4-12, 4-15,

4-20, 4-21, 4-36, 4-50, 5-1, 5-2, 5-3, 6-1, 6-2, 7-2, 9-4, A-i, B-9

ground water .................................................................................. 4-2, 4-16, 9-1, B-4, B-5, C-1

hazardous waste .............................................................................................. 2-8, 9-2, 9-3, 9-4

high level waste ............................................................................................................ B-9, B-10

im pingem ent ........................................................................................................... B-2, B-3, B-4

low level waste ........................................ .............. xxxii

m itigation ........................................ xxiii, 1-4, 1-6, 4-3, 4-5, 4-12, 4-15, 5-3, 9-1, 9-2, 10-1, 12-1

m ixed waste ............................................................................................................... xxxii, B-11

NEPA ............................................. xx, xxi, xxxiii, 1-1, 1-12, 4-36, 5-1, 7-3, 9-1, B-9, B-10, D-1

no-action alternative .......................................................................................................... v, xxvi

nonattainm ent ........................................................................................................................ B-6

NPDES ................................................................................................................ xxxiv, B-2, C-1

pressurized water reactor ..................................................................................................... xxxv

radon-222 ....................................................................................................................... 6-1, B-9

reactor ................................................................. xx, xxi, xxx, xxxii, xxxv, 5-1, 5-2, 5-3, B-4, B-9

refurbishm ent ......................................................................... 4-17, B-1, B-2, B-4, B-6, B-7, B-8

replacem ent power ............................................................................................................ v

scoping. xx, xxi, xxiii, xxvii, 1-3, 1-6, 4-3, 4-5, 4-12, 4-15, 4-37, 5-2, 5-3, 6-1, 7-2, 9-4, A-i, E-3

severe accidents (SAMA) ................................................................... xxxvi, 5-3, 5-4, 10-1, 12-1

solid waste .............................................................................................. 2-7, 2-8, 6-1, B-12, C-1

spent fuel ............................................................................. xxxii, 1-4, 6-1, 6-2, B-9, B-10, B-11

storm water ............................................................................................................................ 4-16

surface water ................................................................................. xxiv, 4-3, 4-16, B-i, B-4, C-1

Sthreatened and endangered species ........................................... 1-7, 4-14, B-2, B-6, C-1, D-1

transm ission lines ....................................................... 4-1, 4-20, 4-21, 4-38, 4-50, 9-1, B-6, B-8

tritium ...................................................................................... . . .. ........... .... 4-16

July 2010 11-1 NUREG-1437, Supplement 41
Index

uranium ......................................................................................................... 6-1, 6-2, B-9, B-1i1

wastewater ............................................................................................................................ B-2

Yucca ................................................................................................................ B-9, B-10, B-11

NUREG-1437, Supplement 41 11-2 July 2010
12.0 LIST OF AGENCIES, ORGANIZATIONS, AND PERSONS TO

WHOM COPIES OF THE SUPPLEMENTAL ENVIRONMENTAL IMPACT

STATEMENT ARE SENT

Name and Title Company and Address

Mr. Ronald D. Asche Nebraska Public Power District

President and Chief Executive Officer 1414 15th Street

Columbus, NE 68601

Mr. Gene Mace Nebraska Public Power District

Nuclear Asset Manager P.O. Box 98

Brownville, NE 68321

Mr. John C. McClure Nebraska Public Power District

Vice President and General Counsel P.O. Box 499

Columbus, NE 68602-0499

Mr. David Van Der Kamp Nebraska Public Power District

Licensing Manager P.O. Box 98

Brownville, NE 68321

Mr. Michael J. Linder Nebraska Department of Environmental Quality

Director P.O. Box 98922

Lincoln, NE 68509-8922

Chairman Nemaha County Board of Commissioners

Nemaha County Courthouse

1824 N Street

Auburn, NE 68305

Ms. Julia Schmitt Nebraska Health & Human Services R & L

Manager, Radiation Control Program Public Health Assurance

301 Centennial Mall, South

P.O. Box 95007

Lincoln, NE 68509-5007

Mr. H. Floyd Gilzow Missouri Department of Natural Resources

Deputy Director for Policy P.O. Box 176

Jefferson City, MO 65102-0176

Senior Resident Inspector U.S. Nuclear Regulatory Commission

P.O. Box 218

Brownville, NE 68321

Regional Administrator, Region IV U.S. Nuclear Regulatory Commission

612 E. Lamar Blvd., Suite 400

Arlington, TX 76011-4125

Director Missouri State Emergency Management Agency

P.O. Box 116

Jefferson City, MO 65102-0116

July 2010 12-1 NUREG-1437, Supplement 41
List of Agencies, Organizations, and Persons

Name and Title Company and Address

Chief, Radiation and Asbestos Control Section Kansas Department of Health and Environment

Bureau of Air and Radiation

1000 SW Jackson, Suite 310

Topeka, KS 66612-1366

Ms. Melanie Rasmussen Bureau of Radiological Health

Radiation Control Program Director Iowa Department of Public Health

Lucas State Office Building, 5th Floor

321 East 12th Street

Des Moines, IA 50319

Mr. Keith G. Henke Office of Emergency Coordination

Planner, Division of Community and Public Health 930 Wildwood P.O. Box 570

Jefferson City, MO 65102

Mr. Art Zaremba Nebraska Public Power District

Director of Nuclear Safety Assurance P.O. Box 98

Brownville, NE 68321

Mr. John F. McCann Entergy Nuclear Operations, Inc.

Director 440 Hamilton Avenue

Licensing, Entergy Nuclear Northeast White Plains, NY 10601-1813

Steward Minahan Cooper Nuclear Station

Vice President 72676 - 648A Avenue

Nuclear and Chief Nuclear Officer Brownville, NE 68321

Mike Boyce Cooper Nuclear Station

Cooper Strategic Initiatives Manager 72676 - 648A Avenue

Brownville, NE 68321

Dave Bremer Cooper Nuclear Station

License Renewal Project Manager 72676 - 648A Avenue

Brownville, NE 68321

Bill Victor Cooper Nuclear Station

License Renewal Project Licensing Lead 72676 - 648A Avenue

Brownville, NE 68321

Jim Loynes Cooper Nuclear Station

License Renewal Project Engineer 72676 - 648A Avenue

Brownville, NE 68321

Garry Young Entergy Nuclear

License Renewal Manager 1448 S.R. 333, N-GSB-45

Russellville, AK 72802

Alan Cox Entergy Nuclear

License Renewal Technical Manager 1448 S.R. 333, N-GSB-45

Russellville, AK 72802

Jerry Perry Entergy Nuclear

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

Russellville, AK 72802

NUREG-1437, Supplement 41 12-2 July 2010
List of Agencies, Organizations, and Persons

Name and Title

Yolanda Peck

Kendall Neiman

Annie Thomas

John Chaney

Darrell Kruse

Daryl J. Obermeyer

Sherry Black

Director

Marty Hayes

Chairman

Bob Engles

Mayor of Auburn, NE

Company and Address

500 S. Main Street

Rock Port, MO 64482

1008 Central Ave.

Auburn, NE 68305

830 Central Ave.

Auburn, NE 68305

1522 I Street

Auburn, NE 68305

1101 17th Street

Auburn, NE 68305

2415 McConnell Ave.

Auburn, NE 68305

64381 727A Road

Brownville, NE 68321

Auburn Memorial Library

1810 Courthouse Ave.

Auburn, NE 68305

Board of Brownville, NE

P.O. Box 67

223 Main Street

Brownville, NE 68321

1101 J Street

Auburn, NE 68305

500 S. Main Street

Rock Port, MO 64482

U.S. Fish and Wildlife Service

Ecological Services

Nebraska Field Office

203 West Second Street

Grand Island, NE 68801

U.S. Environmental Protection Agency Region 7

901 N. 5th Street

Kansas City, KS 66101

U.S. Environmental Protection Agency Region 7

901 N. 5th Street

Kansas City, KS 66101

Nebraska Department of Health & Human Services

301 Centennial Mall South

Lincoln, NE 68509

Missouri Department of Natural Resources

P.O. Box 176

Jefferson City, MO 65102

Jo Stevens

Mayor of Rock Port, MO

John Cochnar

John Askew

Regional Administrator

Regional Administrator

Joann Scheafer

Director

Doyle Childers

Director

Mark Miles

State Historic Preservation Officer

July 2010 12-3 NUREG-1437, Supplement 41 1
List of Agencies, Organizations, and Persons

Name and Title Company and Address

Michael J. Smith Department of Natural Resources

State Historic Preservation Officer P.O. Box 176

Jefferson City, MO 65102

Robert Puschendorf Nebraska State Historical Society

P.O. Box 82554

Lincoln, NE 68501

Carla Mason ADC Digital Communications

820 Central Ave

Auburn, NE 68305

Matthew Leaf KTNC/KLZA Radio

1602 Stone St.

Falls City, NE 68355

Daryl J. Oberneyer ADC Digital Communications

64381 727A Road

Brownville, NE 68321

I NUREG-1437, Supplement 41 12-4 July 2010
APPENDIX A.

COMMENTS RECEIVED ON THE COOPER NUCLEAR STATION,

ENVIRONMENTAL REVIEW

A. COMMENTS RECEIVED ON THE COOPER NUCLEAR STATION

ENVIRONMENTAL REVIEW

A.1. Comments Received During Scoping

The scoping process began on January 26, 2009, with the publication of the U.S. Nuclear

Regulatory Commission's (NRC's) Notice of Intent to conduct scoping in the Federal Register

(NRC, 2009a). The scoping process included two public meetings held in Brownville and

Auburn, Nebraska, on February 25, 2009. Approximately 120 people attended the meetings.

After the NRC's prepared statements pertaining to the license renewal process, the meetings

were open for public comments. Attendees provided oral statements that were recorded and

transcribed by a certified court reporter. Transcripts of the entire meeting, as well as written

statements submitted at the public meetings, were issued as an attachment to the Cooper

Public Meeting Summary Report dated April 14, 2009 (NRC, 2009b). In addition to the

comments received during the public meetings, comments were received through the mail and

e-mail.

Each commenter was given a unique identifier so every comment could be traced back to its

author. Table A-1 identifies the individuals who provided comments applicable to the

environmental review and the Commenter ID associated with each person's set of comments.

The individuals are listed in the order in which they spoke at the public meeting, and in

alphabetical order for the comments received by letter or e-mail. To maintain consistency with

the Public Meeting Summary Report, the unique identifier used in that report for each set of

comments is retained in this appendix.

Specific comments were categorized and consolidated by topic. Comments with similar specific

objectives were combined to capture the common essential issues raised by participants.

Comments fall into one of the following general groups:

(1) Specific comments that address environmental issues within the purview of the NRC

environmental regulations related to license renewal. These comments address

Category 1 (generic) or Category 2 (site-specific) issues or issues not addressed in the

Generic Environmental Impact Statement for License Renewal of Nuclear Power Plants

(GELS). They also address alternatives to license renewal and related Federal actions.

(2) General comments: (1) in support of, or opposed to, nuclear power or license renewal;

or (2) on the renewal process, the NRC's regulations, and the regulatory process. These

comments may or may not be specifically related to the Cooper Nuclear Station (CNS)

license renewal application.

(3) Comments that do not identify new information for the NRC to analyze as part of its

environmental review.

(4) Comments that address issues that do not fall within, or are specifically excluded from,

the purview of NRC environmental regulations related to license renewal. These

comments typically address issues such as emergency response and preparedness,

security and terrorism, energy costs, energy needs, current operational safety issues,

and safety issues related to operation during the renewal period.

July 2010 A-1 NUREG-1 437, Supplement 41
Appendix A

Table A-1. Commenters on the Scope of the Environmental Review. Each comment is

identified along with their affiliation and how their comment was submitted.

Commenter ID

CNS-A

CNS-B

CNS-C

Commenter

Martin Hansen

Glen Krueger

Becky Cromer

Affiliation

Village Board of

Brownville

Member of the Public

Falls City Economic

Development and

Growth Enterprise

Comment Source

Afternoon Scoping

Meeting

Afternoon Scoping

Meeting

Afternoon Scoping

Meeting

ADAMS Accession

Number(a)

ML090840062

ML090840062

ML090840062

CNS-D Arnold Ehlers City Clerk/Treasurer for Afternoon Scoping ML090840062

the City of Nebraska Meeting

City, Nebraska

CNS-E James Gerwick Emergency Management Afternoon Scoping ML090840062

Director for Richardson Meeting

County, Nebraska

CNS-F Robert Cole Nemaha County Evening Scoping ML090840063

Emergency Management Meeting

Director

CNS-G Rod Vandeberg Mayor of Falls City, Evening Scoping ML090840063

Nebraska Meeting

CNS-H Larry Shepard U.S. Environmental Evening Scoping ML090840063

Protection Agency Meeting

CNS-l Bob Engles Mayor of Auburn, Evening Scoping ML090840063

Nebraska Meeting

CNS-J Kendall Neiman Auburn Chamber of Evening Scoping ML090840063

Commerce Meeting

CNS-K David Sickel County Commissioner Evening Scoping ML090840063

Richardson County Meeting

CNS-L Ron Asche, Nebraska Public Power Evening Scoping ML090840063

District Meeting

CNS-M Alan Richard Pawnee City Letter ML090720067

Development

Corporation

CNS-N Ashtin Paris Deputy Clerk Letter ML090720068

City of Rock Port

CNS-O James Gerwick Emergency Management Letter ML090720066

Director for Richardson

County, Nebraska

CNS-P Larry Spepard U.S. Environmental Email ML091070269

Protection Agency

CNS-Q Jill Dolberg Nebraska State Historic Letter ML090650061

Preservation Office

CNS-R Jean Angell Nebraska Department of Letter ML090860762

Natural Resources

(a) The accession number for the afternoon transcript is ML090840062.

The accession number for the evening transcript is ML090840063.

NUREG-1437, Supplement 41 A-2 July 2010
Appendix A

Comments received during scoping applicable to this environmental review are presented in this

section along with the NRC response. Comments received during the public meeting have been

transcribed; comments received by letter or e-mail have been copied in this document to

maintain authenticity. Comments are grouped by category. There were two categories as

follows:

* Comments in support of license renewal at CNS, discussed in Section A.2

* General comments regarding the license renewal review of CNS, discussed in

Section A.3

A.1.1 Comments in Support of License Renewal at Cooper Nuclear Station

Comment CNS-A: My name is Martin Hansen, a member of the Village Board of Brownville. I'm

filling in for our chairman, Marty Hayes, today. I would like to welcome the members of the

Nuclear Regulatory System [sic] to our community for this meeting. Brownville, while being a

small community, we see the importance of Cooper Nuclear Station. It is, of course, the largest

employer in our community and throughout southeastern Nebraska. But for our community, it is

a little more than that. This community was here when the construction on Cooper started nearly

40 years ago. We are here on each day of operation which is around the clock. Cooper

continues to operate safely and our community of Brownville appreciates that very much.

Cooper is a partner with the community. It has lent us support. One of the examples is the

Village of Brownville Volunteer Fire Department. The management of Cooper has allowed our

group of dedicated fire fighters to utilize their training facilities that has enhanced its firefighting

capabilities and has cooperated in an effort and has enabled our department to upgrade its

equipment and training capabilities over a number of years. I'm sure that you will hear a lot

more from other communities about the economic impact of Cooper on the community and the

importance it has on the economy. A 2002 economic study found that there would be

detrimental impact to not only Brownville, but to other communities in this area, so Cooper is

important to continue operation through the license extension of 20 years.

Emergency response is an important part of Cooper operation, and any need for that action to

take place would be handled in a manner that is both professional and done for the protection of

the public. Cooper Emergency Response organization takes it very seriously and each resident

in a 10-mile zone around Cooper always receives the appropriate information about any

possible emergency response activity on the site and would have comfort of knowledge that

these plans are in place and tested annually.

Earlier this month, the Village Board of Brownville unanimously approved a resolution in support

of Nebraska Public Power District at Cooper Nuclear Station license renewal for an additional

20 years. I would like to read that resolution into the official record at this time.

Resolution No. 2-2-09-1

WHEREAS, the Nebraska Public Power District Cooper Nuclear Station in Brownville became

operational with startup in 1974 and has operated safely and efficiently for more than 30 years

and its 828 megawatts of electricity generated; and

WHEREAS, the Village of Brownville has had a longstanding history with Cooper Nuclear

Station since the plant's construction, through refueling outages, and day-to-day operations; and

July 2010 A-3 NUREG-1437, Supplement 41
Appendix A

WHEREAS, the Village of Brownville Volunteer Fire Department has been able to utilize training

facilities to enhance the firefighting capabilities and this cooperative effort has allowed the

department to upgrade equipment in training firefighters over the years;

WHEREAS, Nebraska Public Power District has continually reinvested in the Cooper Nuclear

Station facility to access continued safety, clean, reasonable, and affordable production of

electricity for Nebraskans across the State; and

WHEREAS, the Cooper Nuclear Station is a critical asset as part of Nebraska Public Power

District generation resources and the State's unique public power system, continues to assist in

keeping State electricity rates among the lowest in the country;

WHEREAS, more than 700 permanent jobs at Cooper Nuclear Station and extensive use of

contractors in ongoing maintenance and refueling outages are organized and important to the

economy of the Village of Brownville, Nemaha County, and surrounding communities in

southeastern Nebraska; and

WHEREAS, a 2002 economic study of the impact of the loss of Cooper Nuclear Station would

be detrimental to the Village of Brownville and other communities in southeast Nebraska; and

WHEREAS, the United States Nuclear Regulatory Commission is the Federal agency charged

with oversight of our nation's vital nuclear facilities and encouraged public input and comment

on license renewal and process from the neighborhood and communities; and

WHEREAS, the Cooper Nuclear Station has continued to be a good neighbor to Brownville for

more than three decades;

NOW, THEREFORE, BE IT RESOLVED that the Village of Brownville Council supports the

renewal of the license for the nuclear generation facility at Cooper Nuclear Station and to assure

their continued operations of safe, affordable, and important component of Nebraska's public

power supply system for another 20 years; but

BE IT FURTHER RESOLVED that the Village of Brownville clerk is directed to make available

copies of this resolution to the Nuclear Regulatory Commission at its upcoming Environment

Scope Public Meeting.

Again, I wish to thank the Nuclear Regulatory Commission for hosting this important public

meeting, and we'll make ourselves available to you if you have any questions of us, thank you.

(End of Comment CNS-A)

Comment CNS-B: My name is Glen Krueger and I was the hospital administrator, and I don't

think the present one is here at this time. I was the hospital administrator. I came in 1971, so

was there when it was started and I retired in 2002. And I would like to say that we have had a

full and wonderful cooperation with the Nebraska Public Power District for emergency services.

We were able to send an employee down to Tennessee to learn more about radiation. Yes, we

were learning more when it first started up, but we finally came that we were very comfortable,

that we knew how to take care of if an accident did happen over here. We had full cooperation

from them and I would totally support this new license.

But, also, as a citizen of Auburn, I would like to restate and I would like to have this new permit

I be renewed, because of the need that we have in the City of Auburn, if the need-the people

NUREG-1 437, Supplement 41 A-4 July 2010
Appendix A

that work there. We have a lot of those employees who work in our church and a lot of those

employees, in fact, I have three of those employees in my block where I live. Very appreciative

of them. (End of Comment CNS-B)

Comment CNS-C: I also would like to thank you for the opportunity to speak here this

afternoon. My name is Beckie Cromer. I'm Executive Director of our Falls City Economic

Development and Growth Enterprise. And I'm here this afternoon on behalf of the economic

development team from Falls City. We would like to confirm our unwavering support for the

20-year license extension of Cooper Nuclear Station. Falls City EDGE did pass a resolution of

support for the 20-year license extension, and we have forwarded that resolution to NPPD

officials, although, after reading the materials here today, I think we'll also forward that NRC with

the information provided within the packets today. And in addition to that, our mayor will be

speaking in support of Nebraska Public Power District this evening, as well.

Cooper Nuclear Station is an economic development gem that injects millions into our local

economy by providing almost 800 jobs that pay more than double the Nebraska state average.

The decommissioning of Cooper Nuclear Station would result in monumental loss of revenue

and jobs for our southeast Nebraska area. Additionally, Cooper Nuclear Station runs a very safe

operation. It allows Nebraska to offer a diverse portfolio of power to our citizens.

I had the opportunity to tour Cooper Nuclear Station this week with many Falls City community

leaders. The facility was top notch. The staff was professional and knowledgeable, and the

safety measures in place for workers and the surrounding public exceeds benchmarks set by

government agencies.

Southeast Nebraska is proud to have Cooper Nuclear Station as a partner in economic

development and we ask that you grant the licensing request being made by Cooper Nuclear

Station. Thank you. (End of Comment CNS-C)

Comment CNS-D: Good afternoon. My name is Arnold Ehlers, City Clerk/Treasurer for the City

of Nebraska City, Nebraska. I am here to present a resolution passed unanimously by the City

Council and Mayor of Nebraska City, supporting the license renewal of Cooper Nuclear Station.

I would also like to make you aware of the economic impact Cooper Nuclear Station has on

southeast Nebraska, as well as southwestern Iowa and northwest Missouri, an economic impact

that is over $500 million a year. But the economic impact is just one part of the contribution

made by Nebraska Public Power District and its employees. NPPD employees belong to

volunteer fire departments, serve on library boards, school boards, and many other boards and

committees too numerous to mention. Their spouses and families are also very important

contributors to the communities in which they live.

Over the years, Cooper has been a good safe partner and good neighbor to all of us. They have

attracted employees from around the world, enhancing the multicultural experiences of the area.

We've actually become a global community due to this. It is a privilege to live in a public power

state and in a city that owns its own utilities. Nebraska City, in fact all of Nebraska, benefits from

the low-cost electricity that Cooper Nuclear plays a significant role in providing.

I have a resolution that I would like to have entered into the record. I won't bore you with the

reading of it, unless it needs to be read. I thank you for this opportunity. (End of Comment

CNS-D)

July 2010 A-5 NUREG-1437, Supplement 41
Appendix A

Comment CNS-E: Good afternoon. Many thanks to the Nuclear Regulatory Commission for

hosting this public forum. My name is Jim Gerwick, and I'm the Emergency Management

Director for Richardson County, Nebraska, the county just south of here.

In my position, hardly a month has gone by where some form of interchange has not transpired

between Cooper Nuclear Station's Emergency Management Department and other nuclear

operations staff and my office in Richardson County. The referenced activities include quarterly

emergency communication drills, unannounced communications checks, written

correspondence involving improvements in emergency plans and training in many forms, to

include FEMA, Federal Emergency Management Agency, evaluated radiological emergency

preparedness exercises.

Other joint training activities include NPPD staff involvement in annual training of our local

radiological emergency response organization, and our joint quarterly off-site training meetings.

Cooper Nuclear Station has fully demonstrated its ability to provide safe, reliable electricity for

the citizens of the state of Nebraska. Richardson County has supported Cooper Nuclear Station

in its off-site responsibilities to protect the public and property for many years, since the plant

started, actually, and is glad to be part of the team that supports nuclear power. The bottom line

in our realm of experience, the staff at NPPD and Cooper Nuclear Station is thoroughly

professional and meticulous in attention to detail concerning their approach to public safety. In

short, they are fully integrated and a key member of our public safety team.

And in view of their professional performance and contributions to our community, we support

NPPD's application to continue to operate Cooper Nuclear Station for another 20 years.

In closing, Richardson County is proud to have Cooper Nuclear Station in the Richardson

County area. (End of Comment CNS-E)

Comment CNS-F: Thank you for the opportunity to speak tonight. I'm Robert Cole. I'm the

Nemaha County Emergency Management Director. I wanted to make a few short statements.

I've already submitted a letter of support on the relicensing application; however, I wanted to

touch on a few of the highlights that I mentioned in the letter.

One of the great things about our relationship with Cooper Nuclear Plant is that they have been

good partners for the communities that they are neighbors to. One example of that would be the

fact that most of my day today was spent taking delivery on sirens that Cooper Nuclear has

donated for several local communities in the area, both in Nebraska and Missouri, that lacked

operational or modern sirens. These retired sirens from Cooper, although they are dating back

to the 1970s, are well maintained and very functional and will certainly be a vital asset to

communities that could not otherwise afford replacement of their siren equipment. That's a real

benefit to everybody.

Also, my relationship with Cooper has been excellent. I correspond or talk to Cooper

representatives at least monthly, generally more often, in regard to emergency planning

exercises and just day-to-day communications checks. Every time I have talked to somebody

from the station, they have always been very professional and very competent, and I have very

great confidence in the plant and their operations. It's a joy to be here in Nemaha County, and

one of that joys is serving the County in this relationship to Cooper Nuclear. Thanks very much

for the opportunity to be here. (End of Comment CNS-F)

NUREG-1437, Supplement 41 A-6 July 2010
Appendix A

Comment CNS-G: Good evening. I have prepared comments which I'd be happy to give to you

if you would like them at the end of the meeting. I apologize. I maybe have gotten a little bit too

lengthy, but I'll try to talk fast.

My name is Rod Vandeberg, and I am the mayor of Falls City, Nebraska. Falls City is a

community of 4,200, and is located about 20 miles south of Cooper Nuclear Station as you head

toward the Nebraska/Kansas border.

Interestingly, I personally had the opportunity, along with 18 community members from Falls

City, to tour Cooper Nuclear Station last Monday. I can speak for myself and the others who

took the tour that we were very impressed by the serious and cordial manner in which NPPD

employees were watching out for our personal safety while we were on tour, and also by the

extent of the security presence at the site. This opportunity gave us all a little better first-hand

look at Cooper Nuclear Station, which many of us had not seen, but have heard so much about

over the years. Perhaps properly so, Cooper is a well kept secret. And I would like to take this

opportunity to thank everyone who participated with us in that tour. We had the opportunity to

hear from the gentleman who heads the management company. And then we had the

opportunity to be with several NPPD employees. And it was really an outstanding experience.

The impact of going inside such a facility and seeing how well the facility is maintained and how

expansive the facility is, how it serves to protect employees, public, and the environment was

time well spent. I want to thank NPPD for this opportunity.

Several months ago, I sat in a breakfast meeting right here in this building in Auburn and heard

from your CEO, Ron Asche, and other NPPD employees about the license renewal process,

what the needs for extending of licensing of Cooper for an additional 20 years means, and what

does that mean not only for my community, but all of Nebraska. What I learned is that NPPD

has put an extensive amount of money into facility improvements for safety and operations of

the facility so that it can be an operation that will be able to operate safely and efficiently for an

additional 20 years. What I also heard at that time was that replacing Cooper would take several

billion dollars to construct another generating facility, probably using coal as fuel to replace the

electric generation of Cooper. Just getting a facility sited may be a significant task, and

replacing Cooper with that kind of facility may not be the most environmentally friendly one, as

Cooper does not generate any greenhouse gases from its nuclear operations.

I realize that there are numerous areas that are required to be reviewed by the U.S. Nuclear

Regulatory Commission related to the license renewal application, many dealing with the

environment, another part on how equipment is expected to last if Cooper Nuclear Station were

to operate another 20 years. As I heard at our meeting in the fall, Nebraska Public Power

District's Board of Directors has had the foresight to invest millions of dollars into the operation

in order to continue that operation in a safe manner, and that is what we expect for the residents

of Falls City, Richardson County, and southeast Nebraska.

Our community leaders in Falls City also heard from NPPD, at my request, to tell us more about

the license renewal in a luncheon session in Falls City 2 or 3 months ago. Many in the room that

day have had contact with Cooper employees, both personal or for business reasons, for we

have a contingent of employees that reside in Falls City and Richardson County, 101

employees to be exact.

From a socio-economic aspect, that number is important in small communities such as Falls

City. Cooper employees do business in our community. They are part of community activities,

July 2010 A-7 NUREG-1437, Supplement 41
Appendix A

and they support our schools and services. These individuals operate an important electric

generation for Nebraska, and they do it safely in a nuclear operation. On our tour, we were able

to get a peek at a control room simulator and what these highly trained employees must train to

do. The requirements are rigorous to meet the requirements to become a licensed operator.

A loss of Cooper would cause a severe negative impact on Falls City as would it be for all of

southeastern Nebraska.

NPPD's CEO, Ron Asche, spoke to us last year about several maintenance issues at the plant.

He could have easily passed over telling us that information, but he chose to do so, and he

expressed confidence to us that NPPD would resolve these issues to the satisfaction of the

NRC and return Cooper to the top level of operations for nuclear power plants in the country.

And as I have learned, those words have been put into action and those findings have been

resolved. Frankly, I believe Cooper is one of the safest nuclear plants in the United States.

I, and the members of the City Council of Falls City, recently passed a unanimous resolution of

support for Cooper Nuclear Station's license extension for an additional 20 years. We feel that it

is an important asset for southeast Nebraska and Nebraska in general, and I would like for this

resolution to be included in the official meeting transcript tonight.

I want to thank the Nuclear Regulatory Commission for taking the time to hear from

communities such as ours on this very important issue, not only locally, but nationally, as we

work towards future energy independence. Thank you very much. (End of Comment CNS-G)

Comment CNS-H: Good evening. Thank you, Dave. And I'd like to thank the NRC. I'd also like

to thank the cities and counties of southeastern Nebraska for the opportunity to attend this

scoping meeting. My name is Larry Shepard. I'm an environmental scientist with the U.S.

Environmental Protection Agency, in our Kansas City Regional Office. EPA has 10 regional

offices around the country. Our regional office is responsible for EPA program activities in

Kansas, Iowa, Missouri, and Nebraska.

My point in speaking tonight was just to help everyone tonight to understand what EPA's role is

in this process, this relicensing process. EPA will be reviewing the draft supplemental

environmental impact statement and providing comment, but also in actually scoring both the

document and the project itself. And we will also, in addition to that, be providing commentscoping comment to NRC by the March 2 7 th deadline. And that was really my whole purpose. If

anyone has any questions after the meeting, I'll be hanging around also. Thank you very much.

(End of Comment CNS-H)

Comment CNS-I: Good evening. My name is Bob Engles, and I'm the mayor of Auburn,

Nebraska. I'd like to thank the NRC for this opportunity and specifically for holding this public

forum.

As I was watching the NRC presentation, safety review and environmental impact studies were

mentioned as key parts of the process. I trust that both NPPD and the NRC will conduct a

thorough process to identify issues that must be addressed in these areas so that Cooper

Nuclear Station can continue operating for an additional 20 years.

That's exactly why I'm here. I'm here in support of extending the license for Nebraska Public

Power District's Cooper Nuclear Station. I'll speak just a little bit about the socioeconomic

impact on my city in particular. From a practical standpoint, I'm not sure it makes sense to

NUREG-1437, Supplement 41 A-8 July 2010
Appendix A

discard a proven and effective method of power generation, especially when it has served

Auburn, Nemaha County, and the State of Nebraska for so many years as a safe and reliable

source of electrical generation for the last 35 years in a manner that has protected the public

and the environment.

Cooper Nuclear Station is an economic stimulus to Auburn and southeast Nebraska. Their

footprint is a stabilizing factor in our community's economy. For example, they employ

approximately 720 people, and half of those people live in Nemaha County; 234 of those people

live in Auburn.

The plant's annual payroll is approximately $55 million. Over $17 million of that payroll goes to

people that live in Auburn, and with just a little bit of math, that shows that the average income

per employee living in Auburn is about $75,000. These employees are highly educated, highly

trained and skilled, and they do a quality job day in and day out with safety as their prime

responsibility.

Cooper employees have become a part of the fabric of this community over the years. They live

here. They're involved in community activities. They're involved in our churches; they frequent

the business community; they are involved in youth activities and social events within our

community.

These people are our friends. They're our neighbors. Their kids attend our schools. They

volunteer their time to make Auburn and southeast Nebraska a better place in which to live.

Late last year, following NPPD's submittal of a license renewal application, Ron Asche, CEO

and President of NPPD, which owns Cooper, held a series of meetings within the community

with myself and other elected officials from other communities and the business community. Mr.

Asche pointed out that NPPD's Board of Directors has invested over $300 million in

improvements to Cooper in preparation for the license extension. NPPD is serious about making

these improvements that will enhance the safety of the operations, as well as continuing to

generate low-cost electricity, something that Nebraskans expect and which NPPD is mandated

under State law to do.

Several years ago, NPPD discussed the possibility of closing Cooper. This community was

concerned about that, primarily because of the impact on the economy of Auburn and southeast

Nebraska. Closing Cooper would have been unfortunate. But NPPD's Board of Directors saw

the value in keeping the facility operating and have done a great job in moving forward with the

safe operations of the facility, something that was expected to continue for another 20 years.

Indeed, all Nebraskans benefit from the operation of Cooper Nuclear Station. Auburn has

benefited from Cooper's operations directly, even though the plant is 10 miles away. Nebraska

Public Power District has two facilities in our community that we believe are important for the

operations of the site. The former Sheridan Elementary School has been transformed into a

training center for Cooper employees and the many contractors who come into the community

every 18 months for refueling outages. We believe that the training facility plays a great part of

the strong environmental responsibility and safe operations of the facility each day.

A second facility was remodeled in our downtown area and houses a state-of-the-art

Emergency Operations Center which would operate as needed. Exercises are held on a regular

basis from that facility, including ones with local emergency management personnel from

southeast Nebraska.

July 2010 A-9 NUREG-1437, Supplement 41
Appendix A

As mayor, I'm confident in the ability of NPPD to operate and manage in a safe manner. What

we may hear from people that are concerned about safety issues, we can all be concerned

about safety issues. But throughout the years, I've come to know that the people at Cooper and

NPPD have confidence and that they understand the risks associated with nuclear power

generation and that they have been and continue to do everything in their power to ensure my

safety and our community's safety, because the same people that are working at NPPD Cooper

Nuclear Station live in Auburn. They live in Brownville, Nemaha County, Falls City, and

Nebraska City.

And at this time, I'd like to introduce into the formal record a resolution that our City Council

passed a while back unanimously approving support for the extension of the Cooper Nuclear

Station license.

And once again, I'd like to thank the NRC for hosting these meetings in our community, and if

there's anything our town can do to help you further this process, please do not hesitate to

contact us. Thank you. (End of Comment CNS-I)

Comment CNS-J: Good evening. My name is Kendall Neiman and I'm President of Auburn

Chamber of Commerce, and also the publisher of the Nemaha County Herald, the local weekly

newspaper here. On behalf of the Auburn Chamber of Commerce, I'm expressing full support

for the Nebraska Public Power District's application to extend the Cooper Nuclear Station for an

additional 20 years.

We believe that Cooper's safety and performance speaks for NPPD's expertise in nuclear plant

operations. Several years ago, it appeared that NPPD might close down the Cooper Nuclear

Station. This was something that southeastern Nebraska could not afford to have happen. A

community group had an economic study done that gave us a look at what we could see locally

if the facility was closed. That was about 6 years ago, and that picture was not very pretty.

Devastating might be a better word. If Cooper Nuclear were not to continue operating after its

current license expires, we could see those impacts all over southeastern Nebraska.

Over 700 employees live, work, shop, and are involved in the communities in southeastern

Nebraska. A majority of these employees live right here in Auburn and Nemaha County. They

are contributors to the community, but they are also workers at the nuclear power plant that

emphasizes nuclear safety of all as a top priority.

I recently attended an open house held by NPPD in the Cooper Nuclear facility and was able to

learn more about the license extension, safety, emergency response, and other operations of

the facility. It's very complex, but I found that the people that I talked to be very knowledgeable

and they were concerned with safety of the operations, but they were very proud of what they

do on a daily basis. It is our hope that the Nuclear Regulatory Commission's review of the

license application will be thorough in both the environmental review as well as the safety

review of the Cooper Nuclear Station as required for license renewal. We believe that NPPD

has done an excellent job in the operation of the facility as they have turned out a record

generation year in 2007, have maintained a strong safety culture for the safety of the employees

and the public, and maintained a high visible emergency response operation with local

governments and continue to watch over a reliable generating source of electricity for

Nebraskans with a watchful eye.

The Auburn Chamber of Commerce supports this license renewal extension and look forward to

the Nuclear Regulatory Commission's review of the facility and seeing a 20-year extension

NUREG-1437, Supplement 41 A-10 July 2010
Appendix A

added to the existing license of the facility. Again, thank you for coming to Auburn and giving the

community an opportunity to be heard. (End of Comment CNS-J)

Comment CNS-K: My name is David Sickel. I'm one of the three County Commissioners from

Richardson County. I'm pleased to have the opportunity to speak to the Nuclear Regulatory

Commission concerning the extension of the Cooper Nuclear Station's license for an additional

20 years.

While Richardson County may be somewhat outside the influence of Cooper Nuclear Station's

operations, it is important to acknowledge that over the years this facility has been able to

operate in a safe and effective manner for the residents of Nebraska. It is important that a

complete review of the environmental impacts for 20 more years of operation be studied

thoroughly by both the Nebraska Public Power District and the Nuclear Regulatory Commission.

As I understand another critical phase is a safety review. Again, this is important this type of

review be conducted to ensure that equipment at the facility can operate an additional 20 years

without having the impact on employee and public safety. The fact that much of this information

is available to the public and can have public involvement is an important aspect of the entire

process.

Cooper Nuclear Station is an important part of our community. It operates safely. The

employees at Cooper are highly trained. Cooper generates a reliable source of electricity for the

people of the State of Nebraska. Employees reside in communities such as Richardson County.

Over the years, the presence of Cooper employees in southeast Nebraska has been an

important part of our economy, our schools, or business community, and the community in

which these folks live. The impact on this area from the loss of Cooper operations would create

an economic hardship when you consider those losses. That loss would impact Richardson

County, southeast Nebraska, and the complete State of Nebraska.

On behalf of the citizens of Richardson County, we are in support of the extension of the Cooper

Nuclear Station's license renewal for an additional 20 years.

In a letter that I wrote to NPPD's CEO and President, Ron Asche, I explained that Richardson

County was proud to have Cooper Nuclear Station in the Richardson County area. Cooper

Nuclear Station clearly demonstrated its ability to provide safe and reliable electricity for citizens

of Nebraska. I would like to mention that as the only public power State in the country, we enjoy

having the fifth lowest cost electricity rates in the United States. Richardson County, through its

Emergency Management has supported the facility in its offsite responsibilities to protect the

public for many years, and we are glad to be part of that team that supports Cooper and nuclear

power.

Thank you for this opportunity to speak to you this evening. (End of Comment CNS-K)

Comment CNS-L: I'm Ron Asche, the President and CEO of Nebraska Public Power District,

the owner and operator of Cooper Nuclear Station. We began our process of compiling our

license renewal application several years ago, and submitted that to the NRC in September of

this past year. These public meetings tonight conducted by the NRC are a very important

process in that relicensing process. They provide an opportunity for members of the local

communities that surround Cooper Station and for other interested stakeholders to provide input

directly to the NRC regarding our license application and any issues that they may have

regarding the environmental impacts of extending Cooper's license for another 20 years, as well

July 2010 A-1 1 NUREG-1437, Supplement 41
Appendix A

as any public safety issues that they may have. And I'd like to thank all of those that came this

evening to express their comments to the Nuclear Regulatory Commission, both in these

meetings today and for comments that you might submit via letter or e-mail, et cetera. These

are a very important part of that process.

I want to close just by saying that NPPD is committed to operating Cooper Station, both now

and in the future, in a manner that protects the health and safety of the public and all of our

employees and workers at the plant, as well as protecting the environment. We look forward to

working together with the NRC over the course of the next several years in addressing issues

that may arise, which we hope will ultimately result in an extension of our license for another

20 years to operate Cooper Station and continue to provide low cost, reliable, and safe energy

to the members of our communities and the State of Nebraska as a whole. Thank you. (End of

Comment CNS-L)

NUREG-1437, Supplement 41 A-12 July 2010
Appendix A

Comment CNS-M:

PAWNEE CiTY DEVELOPMENT Co iiO I~iTI ON

P.O. Ito S5

Pa"-iee City, NE 018424)

Chief, Rulemaking

Directives and Editing Branch

Divis~in of Administrative Servie•cs, Qftice of Administration

Mailstop T-66D59

U.S. Nuclear Regulatory Commi.s-sion

Washing!on, D.C. 20555-0001

1Fo Whom It May Concern:

17'!2

The Pawnee City Economic Development Corporation is submitting this letter to

support the renewal of the license for Cooper Nuclear Station operated by Nebraska

Public Power in southeast Nebraska. Our group recognizes the importance of the Station

in providing low cost and safe energ.y In oiir regi•n We ra•n assure any potential

business, that the Station is committed to safety by their safe operations for the past 40

years and their investment of $300 million to upgrade the facility. Their trained

worlforce has a rtrong economic impact on our area. We do not ue.v any negative

environmental impact with this facility but if it were to be replaced by a coal-powered

plant, we do not think that would be the case. We urge you to approve the license

reiewal so we have good, cleun, green energy for years to come.

Sincerely,

Znhard

President, Pawnee City Development Corporation

7--.

CNS-M

15 "A) gte- v,- e4.1-1 (Aye -

(End of Comment CNS-M)

July 2010 A-1 3 NUREG-1437, Supplement 41 1
Appendix A

Comment CNS-N:

500 South Main

Rock Port, MO 64482

ý4j ;Z&Z6 ;:'G#

Phone 660-744-2636 - FAX 660-7044.555•3

rpcityhall@, rpironp

February 27, 2009

/,-3: 7~z

Chief, Rules and Directives Branch

Division of Administrative Services

Otfice of Administration

U.S. Nuclear Regulatory Commission

Mailstop T-6D 59

Wanhington, D.C. 20555-0001

C r

} CNS-N To whom it may concern:

Please find enclosed a copy of Resolution #2009-I supporting Nebraska Public Power

District's Cooper Nuclear Station License Renewal passed by the City of Rock Port on

February 18, 2009.

Sincerely,

Ashtin Paris

Deputy Clerk

City of Rock Port

NUREG-1437, Supplement 41

-~ ~

_ (ec~4j> - ~7

A-14 July 2010
Appendix A

RESOLUTION # 2009-1

A RESOLUTION OF THE BOARD OF ALDERIMEN

OF THE CITY OF ROCK PORT, MISSOURI

Supporting Nebraska Public Power District's

Cooper Nuclear Station License Renewal

WHEREAS, Nebraska Public Power District's Cooper Nuclear Station in Brownville became operational with startup

in 1974; and

WHEREAS, Cooper Nuclear Station has operated safely and efficiently for more than 30 years, generated a record 6.6

million megawaut hours of electricity in 2007, and its 828 megawatts of electrical generating capacity remains vital to

Nebraska's economy; and

WHEREAS, Nebraska Public Power District has continually reinvested in the Cooper Nuclear Station facility to assure

confinutrd safe, clean, reliable and affordable production of electricity for Nebraskans across lhe state; and

WHEREAS, Cooper Nuclear Station is a critical asset as part of Nebraska Public Power District's generation resources

and the state's unique public power system, continues lo assist in keeping state electric rates among the lowest in the

country; and CNSIN,

WHEREAS, more than 700 permanent jobs at Cooper Nuclear Station and the extensive use of contractors for ongoing continued

maintenance and relfeling outages are recognized as vitally important to the economies of the City of Rock Port,

Atchison County, and surrounding communities of southeastern Nebraska and northwest Missouri; and

WHEREAS, Nebraska Public Power District submitted an application to renew Cooper Nuclear Station's operating

license to the United States Nuclear Regulatory Commission on September 29, 2008; and

WHEREAS, the United States Nuclear Regulatory Commission is the federal agency charged with oversight of our

nation's vital nuclear facilities and encourages public input and comment on license renewal proceedings from its

neighboring commtunities; and

WHEREAS, Cooper Nuclear Station has been a good neighbor to its communities for more than three decades and its

employees are interwoven into the fabric of the commnnmity, local schools churches, and community activities;

NOW, THEREFORE, BE IT RESOLVED that the City of Rock Port City Council supports the renewal of the license

for the nuclear generating facilities at Cooper Nuclear Station, to assure their continued operation of safe, affordable and

integrally important component of Nebraska's public power electric power supply system for another 20 years; and

BE IT FURTHER RESOLVED that the City of Rock Port City Clerk is directed to make available a copy of this

resolution to the Nuclear Regulatory Commission at its upcoming Environmental Scoping Public mneeting.

Passed antd approved this ISo day of February 2009

helen Jo Sý es Mayor

ATTEST:

Maureen K. Moore. City Clerk/Admin.

(End of Comment CNS-N)

July 2010 A-15 NUREG-1437, Supplement 41
Appendix A

Comment CNS-O:

Emergency response- James Gerweck, Richardson County

Good afternoon, many thanks to the NRC for hosting this public forum. I'm James

Gerweck. I am the Director of the Richardson County, Nebraska, Emergency

Management Agency. In my position, hardly a month has gone by where some form of

interchange has not transpired between the Cooper Nuclear Station's Emergency

Management Department and other nuclear operations staff and my office in

Richardson County.

The referenced activities included quarterly emergency communications drills,

unannounced communications checks, written correspondence involving improvements

in emergency plans and training in many forms to include FEMA evaluated radiological

emergency preparedness exercises. Other joint training activities include NPPD staff

involvement and annual training of our radiological emergency response organization

and our joint quarterly off-site training meetings.

Cooper Nuclear Station has fully demonstrated its ability to provide safe and reliable

electricity for the citizens of the State of Nebraska. Richardson County has supported

CNS in its offsite responsibilities to protect the public and property for many years and is

glad to be a part of the team that supports nuclear power.

The bottom line in our realm of experience, the staff at the NPPD and Cooper Nuclear

Station is thoroughly professional and meticulous in attention.to detail concerning their

approach to public safety. In short, they are fully integrated and a key member of our

NUREG-1437, Supplement 41 A-16

CNS-O

July 2010
Appendix A

public safety team and in view of their professional performance and contributions to our

community, and we support the NPPI's application to continue operating at Cooper CNSO,

Nuclear Station for another 20 years. continued

In closing, Richardson County is proud to have CNS in the Richardson County area.

Thank you. 2ms4/~* 2i/ -5T8 Pal1

(End of Comment CNS-O)

NRC Response to Comments CNS-A through CNS-O: The comments are supportive of

license renewal. The comments are general in nature, provide no new information and,

therefore, will not be evaluated further. No change to the scope of the CNS supplemental

environmental impact statement (SEIS) will be made as a result of these comments.

July 2010 A-1 7 NUREG-1437, Supplement 41
Appendix A

A.1.2 Comments Regarding the License Renewal Review of Cooper Nuclear Station

Comment CNS-P:

Emmanuel Sayoc

From: CoopcrEIS Resource

Sent: Thursday, April 16, 2009 1:39 PM

To: Emmanuel Sayoc

Subject: FW: Scoping Comments for Relicensing of Cooper Nuclear Station, Brownvi

--- Original Message---

From: Shepard.Larry@epamail.epa.gov [mailto:Shepard.Larry@epamail.epa.gov]

Sent: Friday, March 27, 2009 4:59 PM

To: CooperEIS Resource

Cc: Cothern.Joe@epamail.epa.gov; Hooper.ChariesA@epamail.epa.gov; Dunn.John@epamai

Lancaster. Kris@epamall.epa.gov

Subject: Scoping Comments for Relicensing of Cooper Nuclear Station, Brownville, NE

RE: Notice of Intent to Prepare an Environmental Impact Statement and

Conduct Scoping Process for Cooper Nuclear Station; Federal Register

Volume 74, No. 15, January 26,2009, page 4476.

Thank you for the opportunity to provide scoping comments on the

proposed relicensing of Cooper Nuclear Station (CNS), in support of the

U.S. Nuclear Regulatory Commission's (NRC) preparation of an

Environmental Impact Statement (EIS). EPA reviewed this project in

accordance with the National Environmental Policy Act (NEPA) and Section

309 of the Clean Air Act. We request that, in the future, the NRC

provide an adequate period of time after conducting site audits for the

submission of scoping comments by state or federal agencies. In this

instance, scoping comments are to be submitted prior to the NRC site

audit for this project.

Pleased consider the following comments during the EIS development

process.

Radiation - Given the uncertainty involved with licensing the Yucca

Mountain Nevada facility and the extremely long time-frames needed to

secure Congressional approval and complete site preparation for any

possible alternative permanent site for the disposal of spent nuclear

fuel, all utilities planning on extending operation of existing

nuclear units should consider contingencies for long-term storage of

waste on-site.

Water Quality - The current CNS site has an existing infrastructure,

which includes intake and discharge structures. The source of water

for the plant is the Missouri River. Potential impacts to plant

operation associated with available river flow, particularly during

periods of sustained low flow, should be thoroughly described in the

draft EIS. The draft EIS should articulate the assurance of a

long-term water supply (i.e., greater than 20 years) for the

operation of the reactor. This analysis should address contingencies

created by changing regional climate and potential future changes in

the operation of the river by the Army Corps of Engineers (i.e., flow

CNS-P

J

NUREG-1437, Supplement 41 A-1 8 July 2010
Appendix A

releases). The current facility is covered by a National Pollutant

Discharge Elimination System (NPDES) permit issued by the Nebraska

Department of Environmental Quality (NDEQ). New studies and analyses

performed in support of the most recent permit application (e.g.,

thermal and chemical discharges) should be included in the draft EIS.

The draft EIS should also completely discuss issues associated with

entrainment and impingement of aquatic organisms (i.e., Section 316b

of the Clean Water Act) and include alternatives to the present

intake design. From a review of the Environmental Report, it is

apparent that there is a great deal of information available

regarding the impact of plant operation on the river ecosystem.

However, we generally caution that these studies are 30 years old and

the draft EIS should clearly articulate whether these data are CNS-P,

representative of current river condition and ecological impact. We continued

would expect the NRC to provide both its reasoning and data

supporting that additional and more recent research is not required

to adequately document current impacts.

The draft EIS should thoroughly characterize past contamination

associated with the operation of CNS, particularly source and fate of

tritium in the system, and document current condition of surface

water and groundwater upstream and downstream from the site.

Environmental Management System - The Council on Environmental

Quality (CEQ) published "Aligning NEPA processes with Environmental

management Systems-A Guide for NEPA and EMS Practitioners" to improve

NEPA implementation and environmental sustainability goals in NEPA

and Executive Order 13423. The NEPA document should discuss EMS as

appropriate.

Larry Shepard

NEPA Team/Interstate Waters

US EPA Region 7

913-551-7441

(End of Comment CNS-P)

July 2010 A-19 NUREG-1437, Supplement 41
Appendix A

Comment CNS-Q:

161• NEBRASKA STATE HISTORICAL SOCIETY

1500 R STREET, POBO X 82554, LINCOLN, NE 6850t-2554

(402)471-3270 F,=.(012)471-310tu 14-8U0033-6747 ,'rzkihiry.or

Michael J. Smith. Director/CEO

February 2, 2009

Mr. David L. Pelton, Chief

Division of License Renewal

U.S. Nuclear Regulatory Commission

Washington, D.C. 20555-0001

RE: Cooper Nuclear Station license renewal HP# 0801-050-001

Dear Mr. Pelton:

Thank you for submitting the referenced project for our review and comment. Our comment on

this project and its potential to affect historic properties is required by Section 106 of the

National Historic Preservation Act of 1966, as amended, and implementing regulations 36 CFR

Part 800. Before we are able to adequately review the proposed Area of Potential Effect (APE) for this project for its potential to affect historic properties, we require the following information:

o3 A map clearly defining the boundaries of the APE

Please submit this information to: Bob Puschendorf, Nebraska State Historic Preservation

Office, P.O. Box 82554, 1420 P Street, Lincoln, NE 68501-2554.

Sincerely,

. olberg' Review and Compliance Coordinator

Nebraska State Historic Preservation Office

Cc: Tam Tran, NRC

Emmanuel Sayoc, NRC

Steward B. Minahan, Chief Nuclear Officer, Cooper Nuclear Station

(End of Comment CNS-Q)

NUREG-1437, Supplement 41 A-20

CNS-Q

July 2010
Appendix A

Comment CNS-R:

Dave Heineman

(3oueynor

STATE OF NEBRASKA

DEPARTMENT OF NATURAL RESOURCES

Brian P. Dunnig.'n. P.E. -Drw

Maoh9,2 W IN REPLY TO:

David L Pchca. Branch ChWe

Projci Branch I

Divisio of Ucna Renewal

Dear Mr. trn

A utow sMa by you Pebruay 4. M9., to ks Nebraska DegiaUDMa of Natuall Remasare is bWing C S ftmwAd. lWbSlmer requema a M fl - -t ,ianr qwpcims Te apprepriat Nebraska qagecy for N-j

P.O. Rox 30370

Uncobu NE 66503.OS7

Sincerely

CC. KrIswa Stoma. NOWC

• I -

301 Centenruiia Mall South, 41h Floor - PO. Box. 94676 - Unwdrn. Nebraska 68509-4676 - P1hone (402) 471-2363I - iTkfa, (402) 471-29000

A- V4. ,i ,P4 ý/,j

(End of Comment CNS-R)

July 2010 A-21 NUREG-1437, Supplement 41
Appendix A

The NRC subsequently sent correspondence to the Nebraska Game and Parks Commission

and received the requested list of protected species by e-mail as shown in Appendix D1. The

NPPD also received a letter from the U.S. Fish and Wildlife Service that it "concurs with the

NPPD and NRC determination that the proposed relicensing action is not likely to adversely

affect Federally-listed species or result in the destruction or adverse modification of federally

designated critical habitat." This letter is also included in Appendix D.

NRC Response to Comments CNS-P through CNS-R: With respect to the comments from

the Nebraska State Historical Society (CNS-Q), and the Nebraska Department of Natural

Resources (CNS-R), these comments contain matter from consultations with other government

agencies, which support the license renewal review process. No change to the scope of the

CNS SEIS will be made as a result of these comments.

With respect to the Environmental Protection Agency (EPA) scoping comments (CNS-P)

regarding the disposal of spent nuclear fuel, all utilities planning on extending operation of

existing nuclear units should consider contingencies for long-term storage of waste onsite.

The NRC fully evaluated and addressed this issue in the GELS, and in its regulations. The

current and potential environmental impacts from spent fuel storage onsite at the current reactor

sites have been studied extensively and are well understood. The storage of spent fuel in spent

fuel pools was considered for each plant in the safety and environmental reviews at the

construction permit and operating license stage. The NRC has studied the safety and

environmental effects from the temporary storage of spent fuel after the cessation of reactor

operations (which may include the term of a revised or renewed license), and it published a

generic determination of no significant environmental impact (the Waste Confidence Rule) in its

regulations in Section 51.23 of Title 10 of the Code of Federal Regulations (CFR).

10 CFR 51.23(a) states:

The Commission has made a generic determination that, if necessary, spent fuel

generated in any reactor can be stored safely and without significant

environmental impact for at least 30 years beyond the licensed life for operation

(which may include the term of a revised or renewed license) of that reactor at its

spent-fuel storage basin or at either on-site or off-site independent fuel storage

installations.

In September 2009, the Commission reviewed this rule and declined to approve an update of

the rule. In accordance with this determination, the rule also provides that no discussion is

required concerning the environmental impacts of spent fuel storage for the period following the

term of the reactor operating license, including a renewed license. Therefore, the SEIS will not

include a discussion on the storage of spent nuclear fuel.

With respect to the EPA scoping comments (CNS-P), regarding past contamination associated

with the operation of CNS, particularly source and fate of tritium in the system, the SEIS has a

discussion on the impacts of radioactive liquid effluents discharged into the Missouri River. The

discussion evaluates the radiological dose impact to members of the public as well the impact to

the environment. The SEIS also discusses the results of CNS's radiological environmental

monitoring program in which environmental sample media are collected and analyzed in order

to evaluate the radiological impacts, if any, of plant operation on the environment.

With respect to the EPA scoping comments (CNS-P), regarding water quality, the SEIS will

discusses National Pollutant Discharge Elimination System (NPDES) permits and related

activities including any updated information, available river flow including low flows, U.S. Army

NUREG-1437, Supplement 41 A-22 July 2010
Appendix A

Corps of Engineers (USACE) river flow control operations, as well as aquatic and terrestrial

ecosystem issues. The NRC staff does recognize that the river ecological studies are generally

dated, and addresses this issue in the SEIS.

July 2010 A-23 NUREG-1437, Supplement 41
Appendix A

Comments Received on the Draft Supplemental Environmental Impact Statement

Pursuant to 10 CFR Part 51, the staff transmitted the "Generic Environmental Impact Statement

for License Renewal of Nuclear Plants Regarding Cooper Nuclear Station," Draft Report for

Comment (NUREG-1437, Supplement 41, referred to as the draft supplemental environmental

impact statement (SEIS)) to Federal, State, and local government agencies, and interested

members of the public. As part of the process to solicit public comments on the draft SEIS, the

staff:

0 placed a copy of the draft SEIS into the NRC's Public Electronic Reading Room,

on its license renewal website, and at the Auburn Memorial Library, Auburn,

Nebraska.

* sent copies of the draft SEIS to the applicant, members of the public who

requested copies, and certain Federal, State, and local agencies

* published a notice of availability of the draft SEIS in the Federal Register on

February 18, 2010 (75 FR 8757);

announced and held two public meetings in Auburn, Nebraska, on April 7, 2010,

to describe the results of the environmental review and answer questions on the

license renewal process

0 placed newspaper ads and issued press releases announcing the issuance of

the draft SEIS, the public meetings, and instructions on how to comment on the

draft SEIS

0 established an e-mail address to receive comments on the draft SEIS through

the Internet

During the comment period, the staff received a total of six comment letters and e-mails in

addition to the comments received during the public meetings.

The staff has reviewed the public meeting transcripts and the comment letters that are part of

the docket file for the application, all of which are available in the NRC's Public Document

Room. This section of Appendix A contains a copy of each commenter's submission(s) during

the comment period. For those that provided oral comments at the April 7 meetings, comments

are taken from the meeting transcripts. Note that only comments from those transcripts are

included in this document; however, the complete meeting transcripts can be accessed online or

in-person from the Agencywide Documents Access and Management System (ADAMS) at

accession numbers ML101320545 and ML101320618.

Comment letters and e-mails are also available online in ADAMS. A cross-reference of the

speaker or author of the comment, their affiliation (if stated), the comment source, and the

ADAMS accession number of the comment is provided in Table A-2.

Table A-2. Commenters on the Draft Supplemental Environmental Impact Statement.

Each comment is identified along with their affiliation and how their comment was submitted.

ADAMS Accession

Commenter ID Commenter Affiliation Comment Source Number(a)

NUREG-1437, Supplement 41 A-24 July 2010
Appendix A

CNS-S Andrew Smith No Known Affliation Letter ML101040676

CNS-T Bob Engles Mayor of Auburn, Afternoon DSEIS ML101440133

Nebraska Meeting

CNS-U Glen Krueger Former local hospital Afternoon DSEIS Transcript,

administrator Meeting ML101320545

CNS-V Robert Hams U.S. Fish and Wildlife E-mail ML101440172

Service

CNS-W Robert Nebraska State Historic Concurrence on NRC ML101440131

Puschendorf Preservation Office Letter

CNS-X Robert Stewart U.S. Department of Interior Letter ML101440132

CNS-Y R. U.S. Environmental Letter ML101270268

Hammerschmidt Protection Agency

CNS-Z Brian J. O'Grady Nebraska Public Power Letter ML101250348

District

(a) The accession number for the afternoon transcript is ML101320545.

The accession number for the evening transcript is ML101320618.

There was no significant new information provided on Category 1 issues, or information that

required further evaluation on Category 2 issues. Therefore, the conclusions in the GElS and

draft SEIS remained valid and bounding, and no further evaluation was performed. Comments

without a supporting technical basis or without any new information are discussed in this

appendix, and not in other sections of this report. Relevant references that address the issues

within the regulatory authority of the NRC are provided where appropriate. Many of these

references can be obtained from the NRC Public Document Room. Where the comment or

question resulted in a change in the text of the draft report, the corresponding response refers

the reader to the appropriate section of this report where the change was made. Revisions to

text in the draft report are designated by vertical lines beside the text. Comments were grouped

by category. There were four categories as follows:

(1) Comments in support of license renewal at CNS, discussed in Section A.2.1

(2) Comments in support of the conclusions of the DSEIS, discussed in Section A.2.2

(3) Comments on DSEIS by EPA, discussed in Section A.2.3

(4) Editorial comments on the DSEIS, discussed in Section A.2.4

July 2010 A-25 NUREG-1437, Supplement 41
Appendix A

A.2.1 Comments in Support of License Renewal at Cooper Nuclear Station

Comment CNS-S:

Andrew E. Smith

3300 Huntington Avenue

Apt. Four

Lincoln, Nebraska 68504-2354 USA

April 3, 2010

Chief, Rules and Directives Branch"- X'- '

Division of Administrative Services

Mail Stop T-6D59,

U. S. Nuclear Regulatory Commission

Washington, DC 20555-0001

Re Cooper Nuclear Station License Renewal

-Ti

CDear Sir:

I was asked by a news item for comment on this, and they gave the above address. I

believe the nuclear power industry to be safe and reliable, and attempts to limit it by

environmental screaming are politically motivated. The U. S. has an energy crisis

which could be solved, as in Europe, by the use of nuclear power if not for the

negative influence of environmental hysteria. That hysteria is not only false, but

motivated by attempts to keep the United States down and helpless.

I disagree with those environmental idiots and detect the Communism in their efforts

to somehow limit the nuclear industry. I therefore disagree with not renewing the

License of this power plant. It should be renewed.

Nuclear energy is cheaper than coal, water, solar, wind, or anything else. Not only

that, but it is more regulated than any other industry in the country because of

political idiocy. I do not agree with their worries; they are farcical. I view nuclear

power as cheaper, safer, cleaner, and the best for the country in the long run.

I hope you renew this plant's license. I enjoy cheaper electric utility rates as a result

of nuclear power in my area, with some of the lowest rates in America. Let's keep it

that way, please! I fear nothing but the Communist idiots who are so concerned.

Sincerely,

Andrew Smith

> - CNS-S

A- l /3

(End of Comment CNS-S)

NUREG-1437, Supplement 41 A-26 July 2010
Appendix A

Comment CNS-T:

Several years ago NPPD discussed the possibility of closing Cooper. This community was concerned about

that, primarily because of the impact on the economy of southeastern Nebraska. Closing Cooper would

have becn unfortunate. But NPPD's Board of Directors saw value in keeping the facility operating and

have done a great job in moving forward with the safe operations of the facility, something that we expect

to continue for another 20 years.

Indeed, all Nebraskans benefit from the operation of the Cooper Nuclear Station. Auburn has benefited

from Cooper's operations directly, even though the plant is 10 miles away. Nebraska Public Power District

has two facilities in the community that we believe are important fbr the operations of the site. The fbrmer

Sheridan Elementary School has been transformed into a training center for Cooper employees and the

many contractors who come into the community every 18 months for refueling outages. We believe that

the training facility plays a great part of the strong environmental responsibility and safe operations of the

facility each day.

A second facility was remodeled in our downtown area and houses a state-of-the-art Emergency CNS-T

Operations Center that would operate as needed. Exercises are held on a regular basis from that facility

including ones with local emergency management personnel from southeastern Nebraska.

As Mayor, I'm confident in the ability of NPPD to operate and manage Cooper in a safe manner. We'll

hear from, I'm sure, people that are concerned about safety issues and so am I. Throughout the years

though, I've come to know the people at Cooper and NPPD and I have confidence that they understand the

risks associated with nuclear power generation and that they've been and continue to do everything in their

power to ensure my safety. You see, at the same time they're ensuring the safety of their families because

they live in Auburn, Brownville, Nemaha County, Falls City, and Nebraska City too.

At this time I would like to introduce into the formal record a resolution of support for license extension

for Cooper that was approved by the Auburn City Council.

With that, I'd like to thank the Nuclear Regulatory Commission for hosting these meetings in our

community.

Thank you.

-A brB.EnglIes, Mayor

City of Auburn, Nebraska

(End of Comment CNS-T)

July 2010 A-27 NUREG-1437, Supplement 41
Appendix A

Comment CNS-U:

My name is Glen Krueger, G-I-e-n, K-r-u-e-g-e-r.

I was a former hospital administrator here for 31 years, retired in 2002. Totally great cooperation

with Cooper. There was some-a couple of small accidents. Went very well, the cooperation

between them and us. Cooper did a wonderful job of educating, providing the necessary

materials. CNS-U

At first when, many years ago, '71-72, when it first started, we was a little concerned. That was

alleviated very quickly. Soon as we were educated as to how to handle in case there was a

problem and we was very proud to find out that we'd never had any great problems with them.

Some small accidents were handled quite well.

I am very much in support of this, though I am not personally the hospital administrator at this

time, but those 31 years, we was very proud to have them over there and had no problem at all

with them. Thank you. (End of Comment CNS-U)

NRC Response to Comments CNS-S through CNS-U: The comments are supportive of

license renewal. The comments are general in nature, provide no new information and,

therefore, will not be evaluated further. No change to the draft CNS SEIS will be made as a

result of these comments.

NUREG-1437, Supplement 41 A-28 July 2010
Appendix A

A.2.2 Comments in Support of the Conclusions of the Draft Supplemental

Environmental Impact Statement

Comment CNS-V:

Brady, Bennett

From: RobertHarms@fws.gov

Sent: Friday, March 19, 2010 5:19 PM

To: Brady, Bennett; Bulavinetz, Richard

Cc: jlcitta@nppd.com: John _Cochnar@tws.gov

Subject: Concurrence Cooper Nuclear Station

Attachments: CNS concurrence. pdf

Importance: High

Ms. Brady/Mr. Bulavinetz:

Please make reference to your February 18, 2010, letter requesting that the U.S. Fish and Wildlife Service

(Service) concur with a determination of affect made by the Nuclear Regulatory Commission that continued

operation of the Cooper Nuclear Station for an additional 20 years may affect, but is not likely to adversely CNS-V

affect the federally endangered pallid sturgeon. The Service has completed its review of the Biological

Assessment included within the Environmental Impact Statement for the proposed project and has determined

that it is satisfactory. The Service previously provided its concurrence in a letter dated August 26, 2009, which

would conclude section 7 consultation on this matter. It is attached for your use.

(See attachedfile: CNS concurrence.pdf)

Bob

Robert R. Harms

Fish and Wildlife Biologist

U.S. Fish and Wildlife Service

203 West Second Street

Grand Island, Nebraska 68801

Phone: 308-382-6468, Extension 17

Fax: 308-384-8835

robert harmsfws.gov

July 2010 A-29 NUREG-1437, Supplement 41
Appendix A

United States Department of the Interior

FISH AND WILDLIFE SERVICE

Ecolo gical Services

Nebraska Ficid Office

203 West Secotid Succi

Grand I sland, Nebnuka 68801

August 26, 2009

Mr. Joe Citta

Corporate Environmental Manager

Nebraska Public Power District

1414 15th Street

Columbus, NE 68801

RE: Cooper Nuclear Station License Renewal, Nebraska Public Power District

Dear Mr. Citta:

This is in response to your August 25, 2009, letter with an enclosed Memorandum of

Understanding and Restrictive Covenant for Conservation. Both enclosures have been

signed and executed and demonstrate the Nebraska Public Power District (NPPD) and

Nuclear Regulatory Commission (NRC) intention to offset adverse affects to federally

listed species resulting from the proposed Cooper Nuclear Station License Renewal.

After reviewing your August 25 letter, the U.S. Fish and Wildlife Service (Service) has

concluded that it concurs with the NPPD and NRC determination that the proposed

relicensing action is not likely to adversely affect federally listed species or result in the

destruction or adverse modification of federally designated critical habitat.

Please note that the Service may reinitiate consultation if new species become listed or

are proposed to be listed, critical habitat is proposed or designated, or new information

about federally listed species becomes available that previously was not considered

during this consultation. The NPPD and NRC should reinitiate consultation with the

Service if the current relicensing project is modified through a change in scope and/or if

new information becomes available about the project that previously was not considered.

NUREG-1437, Supplement 41 A-30

OCNS-V,

continued

J

July 2010
Appendix A

The Service appreciates the opportunity to work cooperatively with the NPPD and NRC

in assuming a shared responsibility for protecting federal trust fish and wildlife resources

in Nebraska, If you have any questions or require technical assistance, please do not

hesitate to contact Mr. Robert Harms within our office at (308)382-6463, extension 17.

Sincerely,

-ýNS-V

Nebraska Field Supervisor

cc: NGPC; Lincoln, NE (Attn: Frank Albrecht) Nebraska Land Trust; Lincoln, NE (Attn. Dave Sands)

J

(End of Comment CNS-V)

July 2010 A-31 NUREG-1437, Supplement 41
Appendix A

Comment CNS-W:

UNITED STATES

NUCLEAR REGULATORY COMMISSION

WASHINGTON, D.C. 205550001

February 18, 2010 &A?4 0 1 ?0;

Mr. Michael Smith, Director

Nebraska State Historical Society

P.O. Box 82554

1500 R Street

Lincoln, NE 68501

SUBJECT: COOPER NUCLEAR STATION LICENSE RENEWAL APPLICATION REVIEW

(HP NO. 0801-050-01, DESCRIPTION, NPPD, COOPER NUCLEAR STATION)

Dear Mr. Smith:

The U.S. Nuclear Regulatory Commission (NRC) staff is reviewing an application to renew the

operating license for Cooper Nuclear Station, Unit 1 (CNS-1), which is located in Nemaha

County, Nebraska (NE) on the west side of the Missouri River at river mile 532.5. The Village of

Brownville, NE is located about 2.25 miles northwest of the site. CNS-1 is operated by the

Nebraska Public Power District (NPPD). As part of its review of the proposed action, the NRC

staff has prepared a site-specific Supplemental Environmental Impact Statement (SEIS) to its

"Generic Environmental Impact Statement for License Renewal of Nuclear Plants," NUREG1437Y The SEIS includes analyses of relevant environmental-issues, including potential impacts

to historic, archeological and cultural prope6es from extended operation and possible

refurbishment activities associated with license renewal. In accordance with our. letter to the

Nebraska State and.Historical Society (NSHS)dated January 16, 2009, a copy of the draft

supplerment is enclosed. Pursuant to 36 CFR § 800.8(c), we are requesting your comments on

the draft supplement and on our preliminary conclusions regarding historic properties.

As stated in our January 16, 2009 letter, the NRC staff has determined that the area of potential

effect (APE) for a license renewal action is the area at the power plant site and its immediate

environs that may be impacted by post-license renewal land disturbing operation or projected

refurbishment activities associated with the proposed action. The staff views the APE for the

Cooper Nuclear Station, Unit 1, license renewal as including the Cooper Nuclear Station site and

the immediate environs.

The NRC staff has conducted an environmental audit at the site and has reviewed historic and

archaeological records. The NRC staff also contacted 15 federally recognized Native American

Tribes identified as having potential interest in the proposed undertaking. To date, no comments

have been received.

In the context of the National Environmental Policy Act of 1969, under which the draft

Supplemental environmental impact statement was prepared, the NRC staff s preliminary

determination, based on' review of NSHS files, archaeological surveys, assessments, and other

information, is thatthe potential.impacts of license renewal on historic and archaeological

resources is small.. Under the provisions of the National Historic Preservation Act of 1966, the

NRC,'staff's preliminary determination is that no historic properties will be affected by the

propole'l action. Further, NPPD has instituted a stop work order within its Cutura Resources

Protection Plan to ensure that proper notification is taken to protect.any historic and

archaeological resources . .....should .they be discovered. HP# Q. lot

County ;:"1 ' "" "; "STR_ : : •, " " R 'H '

CNS-W

-0(

Rasp. ODate ZottQ)

NUREG-1437, Supplement 41 A-32 July 2010
Appendix A

M. Smith -2-

Please note that the period for public comment expires on May 5, 2010. If your office requires

additional. time, or if there are any other questions regarding this correspondence, please have

your representative contact the Environmental Project Manager, Ms. Bennelt Brady, at 301-415-

2981.

Sincerely,

Bo Pham, Chief

Projects Branch 1

Division of Ucense Renewal

Office of ,Nc•-ear Reactor Regulation

>+

Docket No.: 50-298

Enclosures: As stated

Oi k5L5

J

(End of Comment CNS-W)

July 2010 A-33 NUREG-1437, Supplement 41
Appendix A

United States Department of the Interior

OFFICE OF THE SECRETARY

Office of Environmental Policy and Compliance

Denver Federal Center, Building 67, Room 118

Post Office Box 25007 (D-108)

Denver, Colorado 80225-0007

TAKE PRIDE' INAM ERICA

April 27, 2010

9043.1

ER 10/174

Chief, Rules and Directive Branch,

Division of Administrative Services, Mail Stop T-6D59

U.S Nuclear Regulatory Commission

Washington, D.C. 20555-0001

Dear Sir or Madam:

The Department of the Interior has reviewed the Draft Generic Environmental Impact Statement

(EIS), NUREG-1437, Supplement 41, for License Renewal of Nuclear Plants; Cooper Nuclear

Station, Unit I, Nemaha County, Nebraska and has no comments on the document.

Sincerely,

Robert F. Stewart

Regional Environmental Officer

CNS-X

J

(End of Comment CNS-X)

NUREG-1437, Supplement 41 A-34 July 2010
Appendix A

NRC Response to Comments CNS-V through CNS-X: The comments provide

concurrence on the findings of the draft CNS SEIS. No change to the draft will be made

as a result of these comments.

July 2010 A-35 NUREG-1437, Supplement 41
Appendix A

A.2.3 Comments on the Draft Supplemental Environmental Impact Statement by the

Environmental Protection Agency

Comment CNS-Y:

AW" ~7

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION 7

901 NORTH 5TH STREET

KANSAS CITY, KANSAS 66101

MAY 0 3 2010

Michael T. Lesar, Chief

Rulemaking and Directives Branch

Division of Administrative Services

Office of Administration TWB-05-B01 M

U.S. Nuclear Regulatory Commission

Washington, D.C. 20555-0001

Dcar Mr. Lesar:

RE: NRC Docket ID: NRC-2008-0617, Review of the Generic Environmental Impact

Statement for License Renewal of Nuclear Plants, NUREG-1437, Supplement 41,

Regarding Cooper Nuclear Station, Unit 1, Draft Report for Comment

The U.S. Environmental Protection Agency (EPA) has reviewed the Nuclear Regulatory

Commission's (NRC) Generic Environmental Impact Statement (GEIS), Supplement 41, for the

Cooper Nuclear Station, Unit I (Draft Report). Our review is provided pursuant to the National

Environmental Policy Act (NEPA) 42 U.S.C. 4231, Council on Environmental Quality (CEQ)

regulations 40 C.F.R. Parts 1500-1508, and Section 309 of the Clean Air Act (CAA). The GElS,

Supplement 41, was assigned the Council on Environmental Quality (CEQ) number 20100053.

The NRC is proposing to renew the license of the Cooper Nuclear Station (CNS) for an

additional 20 years beyond the expiration date of the facility's current 40-year license which is

January 18, 2014. CNS is owned and operated by Nebraska Public Power District (NPPD). The

facility is located in Nemaha County, Nebraska, on the west bank of the Missouri River at River

Mile 532.5, approximately 60 miles southeast of the city of Lincoln. The 1,359 acre site includes

239 acres on the opposite bank of the Missouri River in Atchison County, Missouri. CNS

structures occupy approximately 55 acres of the total site area. NPPD leases 715 acres in

Nebraska and 234 acres in Missouri for agricultural activities such as farming and livestock. The

55 acres of facility structures include a control/reactor/turbine complex serving a General

Electric boiling water reactor with a generating capacity of 830 megawatts electric, a low-level

radwaste building, off-gas filter building, elevated release point, diesel generator building,

miscellaneous circulating water system structures, independent spent fuel storage installation

(ISFSI), switchyard and other infrastructure. The facility uses the Missouri River for cooling

water in a single-pass cooling water system. CNS utilizes two wells for potable water supply

and thrce additional wells for service purposes. Wells are finished in alluvial aquifer which is

under immediate influence of Ihe Missouri River. CNS monitors groundwater through sampling

of 14 monitoring wells. CNS does not routinely monitor surface water. CNS discharges process

water to the Missouri River through a discharge canal. It is our understanding that the licensee

NUREG-1437, Supplement 41 A-36

CNS-Y

July 2010
Appendix A

does not intend to undertake any facility refurbishment activities as part of its license renewal

although NPPD is constructing an ISFSI to serve CNS through the renewal term.

Based on our overall review and the level of our comments, EPA has rated the draft

Supplemental Environmental Impact Statement (SEIS) for this project EC-2 (Environmental

Concerns-Insufficient Information). EPA's detailed comments on aspects of the draft SEIS and a

copy of EPA's rating descriptions arc provided as enclosures to this letter. This EC-2 rating is

based on the uncertainty of potential impacts to ground and surface waters friom radiological

contamination, the effects of fuiture changes to the river environment on CNS operation and the

evaluation of alternatives to CNS license renewal. Specific to the draft SEIS, the curtailed

presentation of radiological data limits the ability of the reader to ascertain its strength. In

addition, the presontation of values regarding many parameters lacks any benchmark against

which the reader could determine significance or trend information which would allow the reader

to understand whether emissions were steady, increasing or decreasing over 36 years of

operation. Further, conclusions reached in the GElS which affect alternative assessment and

selection in the SEIS should be brought forward in some more appropriate form in the SEIS.

As reflected in our enclosed issue-specific comments, we request that the NRC include,

as part of its license renewal for CNS, a requirement to collect data on the aquatic community of

the Missouri River in. the vicinity of CNS wlich would provide contemporary ecological CNS[Y,

information of the area of the river receiving immediate impact from facility operation, continued

particularly cooling water withdrawals. As stated in our comments during the scoping process

and referenced in the draft SEIS, currently available data regarding the immediate aquatic

environment of CNS is over 30 years old, With continued operation of CNS to 2034, the

conclusions reached by the licensee in its Environmental Report and the NRC in its SEIS

regarding "any new and significant information on environmental issues," in the context of the

GEIS and 40 CFR 51, Subpart A, Appendix B, treatment of Category I issues, relying solely on

data collected during initial licensing will become unsupportable. The draft SEIS recognizes the

dynamic, unstable nature of the lower Missouri River. As the federal government continues to

expend significant resources on the recovery of species and restoration of historic river structure

and function, the need for current data on the river in the vicinity of CNS and on possible

impacts related to continued CNS operation and its final disposition is critical to the

comprehensive review required by NEPA.

We appreciate the opportunity to provide comments regarding this project. If you have

any questions or concerns regarding this letter, please contact Mr. Joe Cothern, NEPA Team

I.eader, at. (913) 551-7148, cot hern. ioc(epa.ogov, or Larry Shepard, at (913) 551-7441,

shepard.larry@epa.gov.

Sincereclyyou .

Ronald Hanimerschmidt, Ph.D.

Ditector

Environmental Services Division

J uly 2010 A-37 NUREG-1437, Supplement 41
Appendix A

Issue-specific Comments

Purpose and Need

We recognize that the draft SEIS relies upon the GELS for its project purpose and need statement

and that this statement is generic to all NRC license renewal decisions. However, we believe it

is important to comment on this feature of the draft SETS 8s it appears to influence the

thoroughness of the document's evaluation of alternatives. Both the GETS and the draft SEIS

appear to confuse project 'purpose and need' with the proposed action itself (i.e., issuance of a

renewed license) and, thereby, hinders the full consideration of all reasonable alternatives in this

draft SETS. In a NEPA context, the 2roject purpose and need is to "provide an option that allows

for power generation capability beyond the term of a current nuclear power plant operating

license to meet future system generating needs, which may be determined by State, utility, and,

where authorized, Federal decision-makers" (Section 1.2, Chapter 1). The expiration of the

CNS' current operating license and existing and future energy demands in the region is the

'need' to which NRC is "responding [to] in proposing the alternatives including the proposed

action" (40 CFR 1502.13). T'he NRC's proposed action is "issuing a renewed license for Cooper

Nuclear Station, Unit I"; however, this is but one alternative to addressing this 'need.' A fuller

statement of projcct purpose and need is, in our estimation, an important distinction to providing

a full, open review of all possible alternatives to meeting project purpose and need. This

approach to purpose and need fully implements CEQ requirements regarding NRC's

responsibility to "rigorously explore and objectively evaluate all reasonable alternatives",

"devote substantial treatment to each alternative considered in detail", "include reasonable

alternatives not within the jurisdiction of the lead agency" and "include the alternative of no

action" (40 CFR 1502.14(a), (b), (c) and (d)).

The intent of 40 CFR 1502.14 is difficult to achieve when project purpose and need is so directly

linked to the singular decision whether to reissue an operating license. Any alternative which

does not meet project purpose and need does not appear to be a reasonable or viable alternative

by any measure. Inclusion of a 'no action' alternative within the SETS is required under CEQ

regulations at 40 CFR 1502.14(d). The draft SEIS states that the 'no action' alternative does not

meet the project's purpose and need (Section 8.5). Further, if purpose and need are tied to the

proposed action, none of the alternatives to license renewal will meet project purpose and need

and this contradiction appears to affect the rigor of the evaluation of these alternatives later in the

draft SEIS (40 CFR 1502.14(a) and (b)). The draft SEIS links, throughout the document, the

broad project purpose and need to the NRC's determination whether safety issues or

environmental impacts should preclude license renewal. In simple summation, the NRC will

renew the current license, unless its' analysis reveals significant safety or environmental issues

that would preclude it. That appears to create the impression that the licensing decision is the

project purpose. It would seem that the project purpose and need statement should not preclude

selection of any of the alternatives, including the 'no action' alternative, regardless of the

* outcome of the NRC evaluation of the licensee's application for renewal. Regardless of the

outcome of NRC's license renewal decision, the EIS process should inform and support

deliberations by other decision-makers (e.g., "State regulators and utility officials," page xviii,

Executive Summary) on how to meet this energy demand by any means, including continuing ,

CNS-Y,

continued

NUREG-1437, Supplement 41 A-38 July 2010
Appendix A

operation of CNS- I, new generation sources (e.g., supercritical coal-fired, natural gas-fired, a

combination), existing sources operating outside this region, conservation measures responding

to reduced capacity or a combination of these alternatives. In essence, selection of an alternative

other than license renewal as the preferred alternative is not precluded by NRC's regulatory

responsibilities and is fully consistent with 40 CFR 1502.14(c) which provides for the inclusion

of "reasonable alternatives not within the jurisdiction of the lead agency." The SEIS should

clarify whether the purpose of the project is to meet the energy demands of the region currently

met by CNS operation or only a license renewal decision.

Affected Environment and Environmental Impacts of Operation

Radiological Environmental Monitoring Program (REMP) Data

The draft SlITS characterizes its conclusions regarding radiation exposures to humans and

contamination of the environment from radiation releases on a limited amount of REMP data

(e.g., 2003 through 2007) without explanation. Section 2.1.2 characterizes multiple forms of

radioactive waste streams from CNS using data from 2003 through 2007 or only data from 2007.

In Section 4.8.1., the draft SETS generally summarizes "the calculated hypothetical maximum

dose to an individual located at the CNS- I site boundary from radioactive liquid and gaseous

effluents released during 2007." The draft SEIS offers no explanation why that single year of ýNS-Y,

data was relied upon to make the assessment. Similarly, in Section 4.9.7.4, the draft SETS continued

qualitatively summarizes REMP environmental data for only 2007 for several media to assess

exposures from subsistence consunption of fish and wildlife. Again, there is no explanation

offered for why only one year of data is utilized in making these determinations nor does the

draft SEIS present a quantitative summary of available data. The SETS should provide a

rationale for relying on this more limited data set after almost 40 years of operation. Regarding

both the assessment of radiation exposures to humans and contamination of ground and surface

water, the SEIS should characterize REMP data rather than merely reference a data set and the

NRC's judgment of their significance (i.e., "reasonable", "no unusual trends"). Recognizing that

CNS' REMP has a 'indicator-control' design, a presentation of trend and comparison to control

or environmental benchmark, where available, utilizing a more robust data set than just one or

several years would provide support to the NRC's determinations of significance in the SEIS.

The SEIS would be improved if the document provided sonic information on *control' location

and the basis for determining these sites were beyond the influence of CNS emissions and

discharges. Public review of radiological data within the SETS would also be strengthened with a

more complete and thorough organization of that data for each waste stream, including noncontact cooling water (Outfall 001), Currently, the draft SETS relies completely on the NRC's

qualitative expressions that there are "no unusual trends", "no measurable impact" and "small

significance" without the benefit of presenting any characterization of the data supporting these

conclusions, their completeness and their representativeness of the larger operational data set.

Ground Water

The SEIS does not address the potential for radiological contamination of alluvial groundwater

and, therefore, the Missouri River from atmospheric washout in the immediate area of CNS.

There is no description of background or historic groundwater contamination or trends in

July 2010 A-39 NUREG-1437, Supplement 41
Appendix A

groundwater radiological contamination during the current license period as would be expected

from the facility's REMP which was initiated in 1971. In Section 2.1.7.1, the SEIS makes

statements regarding a large number of monitoring wells installed to "measure the concentration

of tritium in ground water" and documented "instances of liquid radiological releases." The SEIS

also states that "none of the releases is a current source of ground water contamination", but

provides no basis for this statement. The document also indicates that sampling and analysis

results from the ground water monitoring program will be included in the final SEIS. The

absence of this information in the draft SEIS interferes with our ability to evaluate radiological

impacts to ground water and, potentially, the Missouri River. The SEIS would be improved if it

included: the rationale behind the installation of the monitoring wells on-site and their locations,

particularly the II installed to measure tritium contamination, the rationale behind the 3

remaining wells installed as part of CNS' INFSI Project, comparisons of the radiological

character of site ground water in comparison with off-site reference or background, an

explanation of benchmarks for both human health and aquatic life exposures and a

characterization of ground water trends with regard to radiological contamination. Further, the

SEIS should specify possible sources of radiological contamination and response actions by the

licensee based on the presence of radiological contamination in these wells. Public review of

these data would be-strengthened if there was more information regarding what radiological

levels are 'expected' by NRC at this facility, what levels might raise concern for the NRC and

what measures CNS intends to take or has taken to address sources of contamination to ground

water.

Surface Water

Section 4.4 of the draft SEIS does not adequately characterize CNS' use of surface water in

comparison to available river flows. The SE1S would be improved if it characterized the

percentage of flow utilized by CNS under low and high flow river conditions under 'wet' and

drought periods in the basin. Given the direct hydrologic link between ground water and the

river, computations of relative facility water consumption should combine ground water and

surface water withdrawals. An assessment of comparative volumes of river flow use by CNS

during varying conditions (e.g., seasonal, climatic) would better characterize both the potential

impact of operation on the river and the facility's dependence upon river flow. Section 2.1.6

mentions that "the circulating water system flow would be about 47 percent of Missouri River

flow" under critical low flow conditions. The fact sheet supporting the State of Nebraska's

NPDES permit for CNS states that 625 MGD is withdrawn from the river at the intakes. The

Missouri River basin appears to be ending a recent long-term drought period during which the

navigation season was shortened several times. In tihe recent past, low winter flows and

continuing river bed degradation in some reaches have caused utilities drawing water from the

lower river to take extreme engineering measures to ensure a continuing flow of water to their

systems. Congress has recently ordered the Army Corps of Engineers to study those purposes

for which the current Missouri River system is operated as well as to develop a formal plan to

recover native species and the river ecosystem. It is reasonable to consider these actions as they

might affect CNS operation during a license renewal period which extends to 2034. In addition,

climatic changes to the region could result in changes in the availability and timing of river flows

for facility operation. Treatment of these complex relationships in Section 4.4 is not robust

enough to aid in the decision-making value of the SEIS,

NUREG-1437, Supplement 41 A-40 Jul)

CNS-Y,

continued

p2010
Appendix A

Given the potential impacts of thermal discharges from any single-pass cooling system, Section \

4.5.3 should provide much more information regarding CNS's NPDES compliance record since

1974 with regard to its temperature limits, recent warming trends in ambient river water and

tributary flows and the impact of warmer receiving water on facility temperature compliance and

a characterization of the relative volume of cooling water discharge to river flow at high and low

river flows. Assimilation of heat by receiving waters without adverse effect to aquatic organisms

has been a significant issue for any energy production facility and is becoming more problematic

for some facilities with recent trends of increasingly warmer receiving waters (i.e., less

assimilative capacity for heat). This issue warrants more detailed treatment in the SEIS. NRC

should consider adding more detailed information regarding the facility's temperature allocation,

modeling and mixing zone calculations as an appendix to the document.

Section 2.1.7.2 states that CNS operations do not affect water quality in the Missouri River based

on a cursory description of data from the Army Corpsof Engineers' Water Control Manual and

listings of impairment by the State of Nebraska. There is no characterization of available

monitoring data for the Missouri River in the vicinity of CNS. The dralt SEIS states that NPPD

does not monitor surface waters as part of its environmental program, In fact, there is limited

ambient water quality data for the Missouri River. The SEIS should avoid making statements

regarding tile impacts of facility operation on the river based on limited and uncharacterized

data. Finally, the State of Nebraska has designated the river for more beneficial uses than is

stated in this section.

Section 2.1.7.3 is incomplete as it does not discuss the two compliance schedules contained

within CNS' NPDES permit for its cooling water intake structure (Clean Water Act, Section

316(b)) and water quality-based limits for total residual chlorine. The SEIS should also clarify

which outfalls discharge to surface water and which outfalls are chlorinated or brominated.

Aquatic Life

Although we continue to have concerns about the age of the data relied upon to characterize the

impacts of entrainment and impingement on river biota (Section 4.5.2.3, page 4-6), we generally

agree with the conclusions of the analysis preformed by NRC staff in this section. However,

Section 4.5.2 would be greatly improved if the analysis included impingement data from other

facilities utilizing the same or other technology and source water (i.e., large river) against which

to compare CNS data. It is difficult to determine if the amount offish impinged at CNS

constitutes a comparatively large or small amount of biomass. Alternatively, data regarding

entrainment at CNS appears to be very limited and inconclusive making the conclusions

expressed in Section 4.5.2 regarding entrainment much more speculative and qualitative. As

addressed in the cover letter to these comments, the basis for asserting that CNS operation has a

small impact on aquatic life in the Missouri River would be better supported if NPPD provided

more contemporary data regarding river biota in the immediate environment of the facility in an

indicator-control design similar to the REMP and better characterized risks to biota from

entrainment.

As with our previous comments regarding the presentation of REMP data, the draft SEIS limits

its characterization of radiological contamination in the environment, in many instances, to one y

/qNS-Y,

continued

July 2010 A-41 NUREG-1437, Supplement 41 1
Appendix A

year's worth of data. The document briefly mentions, in Section 4.9.7.4, monitoring milk,

vegetation, surface water, drinking water, groundwater, fish and sediment, but characterizes data

from only 2007. Relying on conclusions of significance apparently drawn from one year

provides little basis for the NRC concluding that "the routine operation at CNS-I has had no

significant or measurable radiological impact on the environment." The SEIS rcadcr has only

the assurances of NRC staff that these data are representative of ambient conditions to conclude

that a proper evaluation of environmental impact has indeed occurred.

Stormwater and Wastewater Treatment

The draft SEIS does not address possible tritium contamination within the wastewater collection

and treatment system. Downwash from facility venting operations and worker sanitary

contributions are common sources of radiological contamination of nuclear facility liquid

effluent. CNS discharges collected site stormwater into ground water through drainage wells.

T1he draft SETS does not characterize stormwater radiological contamination which reflects

downwash from site structures. The SEIS should sutmnarize REMP data and characterize

radiological contamination resulting from air deposition and resulting surface runoff which is

discharged into drainage wells. Similarly, sanitary wastewater effluent is land-applied on-site,

but there is no characterization of possible radiological ground water contamination associated

with this waste stream.

There is no discussion within the draft SEIS regarding potential wastewater lagoon sludge

contamination with radionuclides or the means by which the sludge is disposed. The SEIS

should characterize this environmental medium and also describe how and where lthe sludge is

disposed.

Spent Fuel Storage and Independent Spent Fuel Storage Installation

Although collective offsite radiological impacts of spent fuel storage are addressed under other

NEPA documentation, the SEIS should describe the current status of the CNS's new Independent

Spent Fuel Storage Installation (ISFSI) and projected capacity over the term of the license

renewal period that extends to 2034. This information does not pertain to radiological risk

assessment and would not be adequately addressed in the 1996 GEIS and Addendum. Given the

current status of the Department of Energy's application for license for the Yucca Mountain site,

this information is germane to a discussion of short-term use and long-term productivity and an

irreversible commitment of resources (40 CFR 1502.15). The need for continued storage, onsite, of spent fuel might extend well beyond the operating life of the facility itself, The status of

each licensed facility with regard to storage of spent fuel varies and each SEIS should

characterize that status and project change to that status over the lifetime of the renewed license.

Environmental Justice

The SEIS should describe socioeconomic factors associated with CNS affecting the Sac and Fox

and Iowa Reservation populations which are within the facility's ROL. These factors are

noticeably absent from the SEIS' assessment of community-based impacts.

NUREG-1437, Supplement 41 A-42 July

CNS-Y,

continued

2010
Appendix A

The discussion of risks from subsistence consumption of fish and wildlife in Section 4.9.7.4

relies on data from 2007 and concludes that risk is minimal without the benefit of any summary

data from the facility's REMP. With regard to multiple pathways of exposure, the draft SEIS

concludes that "the routine operation at CNS-I has had no significant or measurable radiological

impact on the environment (page 4-33)." Given that the REMP began in 1971, it is unclear why

this analysis is performed on a single year's worth of REMP data, This statement would be

better supported with the characterization of more REMP data than from only 2007.

Environmental Impact of Alternatives

The SEIS carries forward, for detailed evaluation, in addition to the proposed action, three

alternatives and the 'no action' alternative, although the SEIS states that the 'no action'

alternative does not meet project purpose and need. Fifteen other alternatives were considered,

but dismissed before detailed evaluation. T[he three alternatives evaluated are: supercritical coalfired generation; natural gas combined-cycle generation; and a combination of natural gas

combined-cycle generation, conservation capacity increases and wind power.

Super Critical Coal-Fired Generation

The cumulative air impacts of emissions associated with this alternative in combination with

those of existing coal-burning facilities in eastern Nebraska, western Iowa and northwestern

Missouri should be considered in Section 8.1. The significance of the impacts of this alternative

on air quality and total regional carbon emissions should be evaluated in the context of all other

carbon sources.

Mercury is a significant contaminant of concern associated with coal combustion. Many

watersheds downwind of the CNS site have been listed by Iowa and Missouri for mercury

contamination. Further, mercury contamination is measured in fish tissue in areas far from their

estimated source, primarily from air deposition. Section 8.1 does not provide an assessment of

impacts from hazardous air pollutants, specific to this alternative, particularly with regard to

mercury emissions. For this alternative, more information is needed in the SEIS regarding

projected mercury emissions and the status of surface waters in the depositional path with regard

to mercury.

Evaluation of Alternatives

Given the comparatively cursory evaluation of the three alternatives compared to the preferred

action, it is not clear how the Alternatives Summary could conclude that "All other alternatives

capable of meeting the needs currently served by CNS- I entail potentially greater impacts than

the proposed action of license renewal of CNS-1." This conclusion is not sufficiently supported

by the alternatives analysis, consistent with the requirements of 40 CFR 1502.14(a).

Notwithstanding the requirements for "rigorous" and "objective" altcrnatives analysis at 40 CFR

150.14(a), the NRC's expressed view of its responsibilities to determine whether "there are

findings in the safety review required by the Atomic Energy Act of 1954 (AEA) or findings in

the NEPA environmental analysis that would lead to the rejection of a license application.."

(Executive Summary, page xviii) does not appear to necessitate any alternatives analysis.

CNS-Y, •"continued

July 2010 A-43 NUREG-1437, Supplement 41 1
Appendix A

The summary of impacts contained in Tables 1 and 8-5 does not appear to be a rigorous

evaluation of the five alternatives carried forward in the draft SEIS for detailed review as is

required in 40 CFR 1502.14(a), (b) and (c). In our view, the power of the evaluation required by

NEPA, particularly an evaluation of a reasonable range of alternatives to a proposed action, is in

a detailed and well-documented determination of whether it is good public policy to proceed

with an action instead of an alternative to the proposed action. The discussion of this evaluation

of a range of reasonable alternatives within the Executive Summary and Chapter 9 is not

compelling and separation points critical to a decision to select the preferred alternative over an

alternative are not evident.

As presently described in the draft SEIS, the impacts of the alternatives are characterized

according to rather broad categories, primarily in isolation from each other and the proposed

action. Rather than weighing of tile impacts of each alternative, none of these alternatives are

evaluated in direct comparison to the license renewal of the CNS, In effect, the license renewal

of the CNS, or any existing facility, stands separately from all other alternatives and is evaluated

on its. merit alone. This intent is reflected, initially, in project purpose and need. Additionally,

some significant impacts associated with continued operation of any existing facility are not

addressed within the SMIS, but are addressed generically in the GEIS or other NEPA

documentation, making a complete comparison of several large scale impacts of continued

operation to the alternatives impossible. No comprehensive assessment or comparison of the

merits of generating power by the existing facility or one of the alternatives is performed in this

documentation. Unless the economic costs and environmental impacts of spent fuel

transportation and disposal and facility decommissioning are somehow incorporated or

summarized in the decision documentation supporting this license renewal decision, an equal

comparison of alternatives to license renewal by the reader is not possible. This issue reflects an

apparent disconnect between the broad treatment of license renewal for all facilities in the GELS

and facility-specific assessments in the SEIS.

(End of Comment CNS-Y)

NUREG-1437, Supplement 41 A-44 July 2C

CNS-Y,

continued

)10
Appendix A

NRC Response to Comment CNS-Y: In the June 5, 1996, final rule for the Environmental

Review for Renewal of Nuclear Power Plant Operating Licenses (61 FR 28467), the NRC

addressed the concerns of the Council of Environmental Quality (CEQ) relative to consideration

of appropriate alternatives and the narrow definition of purpose and need. The definition of

purpose and need in the 1996 GElS reflects the Commission's recognition that the NRC has no

role in the energy planning decisions of State regulators and utility officials, and the NRC will

neither perform analyses of the need for power nor draw any conclusions about the need for

generating capacity in a license renewal review. The purpose of renewing an operating license

is to maintain the availability of the nuclear plant to meet system energy requirements beyond

the term of the plant's current license.

The operation of a nuclear power plant beyond its initial license term involves separate

regulatory actions, one taken by the utility and the NRC, and the other taken by the utility and

the State regulatory authorities. The NRC would determine whether it is reasonable to renew

the operating license and allow State and utility decision makers the option of considering a

currently operating nuclear power plant as an alternative for meeting future energy needs. The

focus of the analysis is whether the environmental impacts anticipated for continued operation

during the term of the renewed license reasonably compare with the impacts of alternatives

considered for meeting generating requirements. The NRC would reject a license renewal

application if the analysis demonstrated that the adverse environmental impacts of license

renewal were so great that preserving the option of license renewal for energy planning decision

makers would be unreasonable.

Given the uncertainties involved and the lack of control that the NRC has in the choice of energy

alternatives in the future, the Commission believes that it is reasonable to exercise its NEPA

authority to reject license renewal applications only when it has determined that the impacts of

license renewal sufficiently exceed the impacts of all or almost all of the alternatives that

preserving the option of license renewal for future decision makers would be unreasonable. The

decision will not affect the scope or rigor of NRC's analyses, including the consideration of the

environmental impacts relevant to the license renewal decision and associated alternatives.

The staff forwarded this comment to the group currently working on Revision 1 to NUREG-1437,

the Draft Revised GElS. The approach used in the Draft Revised GElS more-clearly presents all

alternatives (proposed action and other energy alternatives that are outside the agency's

purview) in a more parallel and directly comparable format. The NRC staff also notes that EPA

headquarters staff provided specific comments on the Draft Revised GElS during the comment

period for that document that closed in January of 2010.

Following receipt of the EPA's comment letter, the NRC initiated a followup telephone call with

the EPA to better understand their concerns. As discussed on that phone call, the NRC staff

requests the EPA's early and continued communication in future projects.

The NRC staff notes that the comments provided by the EPA staff on the draft SEIS for CNS

are made in the context of compliance with the EPA's regulations 40 CFR Parts 1500-1508 and

Section 309 of the Clean Air Act. The NRC takes its responsibility to perform an environmental

impact statement in accordance with NEPA programmatic guidance very seriously.

The NEPA regulations direct Federal agencies on matters related to environmental policy,

including the public scoping process, use of lead agencies, and selection of alternatives. The

NRC is an independent regulatory agency. As an independent agency, the NRC established its

own regulations to implement NEPA. The Commission set policy to take account of the CEQ's

July 2010 A-45 NUREG-1437, Supplement 41
Appendix A

1978 regulations voluntarily. The NRC's requirements for compliance with NEPA are contained

in 10 CFR Part 51, Subpart A; National Environmental Policy Act - Regulations Implementing

Section 102(2).

The Commission recognizes a continuing obligation to conduct its domestic licensing and

related regulatory functions in a manner which is both receptive to environmental concerns and

consistent with the Commission's responsibility as an independent regulatory agency for

protecting the radiological health and safety of the public.

Response to EPA Comments on Affected Environment and Environmental Impacts of Operation

In order to address the EPA comments in other areas of their document and to better

understand the NRC's responses below, it is important to understand the NRC's license renewal

process which classifies environmental and human health issues as either Category 1 (generic

to all nuclear power plants) or 2 (requires a site-specific evaluation). For license renewal, the

NRC performed a comprehensive evaluation of all nuclear power plants in the United States to

assess the scope and impact to public health and safety and the environment from radioactive

material released from a nuclear power plant for an additional 20 years of operation.

The impact evaluation performed by the staff and presented in the GElS identified 92

environmental issues that were considered for the license renewal evaluation for power reactors

in the United States. The industry, Federal, State, and local governmental agencies, members

of the public, and citizen groups commented on and helped identify these 92 issues during the

preparation of the GELS. For each of the identified 92 issues, the staff evaluated existing data

from all operating power plants throughout the United States. From this evaluation, the staff

determined which issues could be considered generically and which issues do not lend

themselves to generic consideration. The GElS divides the 92 issues that were assessed into

two principle categories:

* one for generic issues (which are termed "Category 1 issues")

" the other for site-specific issues (termed "Category 2 issues")

Category 1 issues are termed "generic" issues because the conclusions related to their

environmental impacts were found to be common to all plants (or, in some cases, to plants

having specific characteristics such as a particular type of cooling system). For Category 1

issues, a single level of significance was common to all plants, mitigation was considered, and

the NRC determined that it was not likely to be beneficial. Issues that were resolved generically

are not reevaluated in the site-specific supplement to the generic environmental impact

statement on license renewal (SEIS) because the conclusions reached would be the same as in

the GELS, unless new and significant information is identified that would lead the NRC staff to

reevaluate the GEIS's conclusions. During the environmental reviews of license renewal

applications, the NRC staff makes a concerted effort to determine whether any new and

significant information exists that would change the generic conclusions for Category 1 issues.

The issues of radiological impacts on human health and radiation doses to members of the

public from the current operation of nuclear power facilities were examined from a variety of

perspectives, and the impacts were found to be well within the NRC's and EPA's radiation

protection standards in each instance. As a result, the issues are classified as Category 1

issues.

Category 2 issues are those that require a site-specific review. For each of the Category 2

issues applicable to the site under review, the staff evaluates site-specific data provided by the

applicant, other Federal agencies, State agencies, Tribal and local governments, as well as

NUREG-1437, Supplement 41 A-46 July 2010
Appendix A

information from the open literature and members of the public. From this data, the staff makes

a site-specific evaluation of the particular issues and presents its analyses and conclusions in

the SEIS for the facility.

This does not mean that the NRC takes the generic (Category 1) issues "off the table" for public

review. If there is new and significant information that would change the conclusions reached in

the GELS, the issue requires a site-specific analysis.

During the scoping process and the environmental review, the NRC looks for any information

that could demonstrate that there are unique characteristics related to the facility or the

environment surrounding the facility that would lead to the conclusion that the generic

determination for a particular issue is not valid for a specific site. The NRC staff discusses and

evaluates potential new and significant information on impacts of operations during the renewal

term in the SEIS.

As discussed above, the generic issues of radiological impacts on human health and radiation

doses to members of the public from the current operation of nuclear power facilities have been

examined from a variety of perspectives, and the impacts were found to be well within

regulatory requirements in each instance. The NRC expects its licensees to continue to comply

with its radiation protection standards during the period of license renewal; therefore, there is no

reason to expect radioactive effluents to increase during the period of the renewal license.

However, as with all Category 1 conclusions, the NRC staff review evaluates each license

renewal application and the site to determine if there is new and significant information that

would change the conclusion in the GELS. In addition, the staff notes that effective use of

radioactive waste treatment systems and practices at nuclear power plants have resulted in

public radiation doses being well within NRC's as low as reasonably achievable (ALARA) dose

criteria contained in Appendix I to 10 CFR Part 50. The NRC staff concluded in the GElS that

the significance of radiation exposures to the public attributable to operation after license

renewal will be small at all sites and that this is a generic (Category 1) issue.

Additionally, in accordance with NRC regulations, a number of issues are not considered in the

environmental review for license renewal conducted by the NRC, including but not limited to:

a safety

* operational issues that require a separate NEPA review (such as an

independent spent fuel storage installation (ISFSI))

* security and safeguard issues

* emergency preparedness (including distribution of potassium iodide)

0 need for power

0 spent fuel disposal and storage

• economic feasibility

• cost-benefit analyses

July 2010 A-47 NUREG-1 437, Supplement 41
Appendix A

These issues are covered in other NRC regulations, licensing actions, the inspection and

enforcement program, and the environmental assessment specific to the issue to ensure

adequate protection of the public's health and safety and the environment.

In summary, the comments relating to radiological issues has been evaluated in the GElS for

license renewal and no new and significant information was identified during the scoping

process, the review of CNS's environmental report (ER), and the staffs site visit that contradict

the GEIS's findings. Therefore, there are no impacts beyond those identified and evaluated in

the GELS.

Response to EPA Comments on Radiological Environmental Monitoring Program Data

The comments relating to radiological issues has been evaluated in the GElS for license

renewal and no new and significant information was identified during the scoping process, the

review of the CNS ER, and the staffs site visit that contradict the GEIS's findings. Therefore,

there are no impacts beyond those identified and evaluated in the GELS. No changes will be

made to the SEIS based on the comments.

The radiological issues cited in the EPA's comment are Category 1 issues that have been

generically resolved in the GElS for license renewal. The staff previously discussed the NRC's

license renewal process for handling Category 1 and 2 issues. In summary, the comments

relating to radiological issues has been thoroughly evaluated in the GElS for license renewal

and no new and significant information was identified during the scoping process, the review of

the CNS ER, and the staffs site visit that contradict the GEIS's findings. Therefore, there are no

impacts beyond those identified and evaluated in the GELS.

The radiological data in Sections 2.1.2.1, 2.1.2.2, 2.1.2.3, and 4.8.1 of the SEIS were updated to

include data from 2003 through 2009 based on the comment and the availability of more recent

data since the draft SEIS was published.

Response to EPA Comments on Ground Water

The comment raises a concern regarding radiological contamination of alluvial ground water

and the potential for contamination to the Missouri River. While there are no programs at CNS

to specifically sample and monitor alluvial ground water, the staff evaluated two specific aspects

of CNS's ground water monitoring programs that do provide data for consideration: (1) the

analysis of drinking water from an onsite well, as documented in the radiological environmental

monitoring program (REMP); and (2) indications of potential leaks of radioactive fluids from

plant systems and buried piping through the ground water protection program.

The REMP is an NRC-required program that monitors releases and buildup of radioactive

material from the plant to assess the potential impact to man and the environment. The NRC

staff reviewed the REMP data over a 7-year period and found no instances where tritium or

gamma emitting radionuclides were detected above the lower limit of detection in samples from

an onsite drinking water well and surface water from the Missouri River.

NUREG-1437, Supplement 41 A-48 July 2010
Appendix A

In addition, the ground-water protection program at CNS is an industry-wide voluntary initiative

designed to serve as an early warning indicator of abnormal spills or leaks of radioactive fluid

from a plant system, component, or buried piping. As reported by CNS in their annual

radiological environmental report, the long-term objectives of the program are as follows:

(1) Identify suitable locations to monitor and evaluate potential impacts from station

operations before significant radiological impact to the environment and potential

drinking water sources.

(2) Understand the local hydrogeologic regime in the vicinity of the station and maintain

up-to-date knowledge of flow patterns on the surface and shallow subsurface.

(3) Perform routine water sampling and radiological analysis of water from selected

locations.

(4) Report new leaks, spills, or other detections with potential radiological significance to

stakeholders in a timely manner.

(5) Regularly assess analytical results to identify adverse trends.

(6) Take necessary corrective actions to protect ground water resources.

The programs evaluated by the staff above did not indicate any adverse radiological impacts to

the ground water at CNS and the Missouri River. Such finding is consistent with the Category 1

generic finding documented in the GElS for license renewal. The staff previously discussed the

NRC's license renewal process for handling Category 1 and 2 issues. In summary, the comment

did not provide new and significant information regarding radiological impacts associated with

license renewal at CNS.

No changes were made to the SEIS as a result of the comment.

Response to EPA Comments on Surface Water

The comment suggests the inclusion of additional data and analysis in Section 4.4 of the SEIS

for surface water issues associated with the CNS site. The NRC staff found that the information

contained in the CNS ER and developed in SEIS Sections 4.4 and 4.5.3 was sufficient to

assess the surface water issues. Also, as illustrated in Table B-1 to Appendix B to Subpart A of

10 CFR Part 51, the Commission has assessed the environmental impacts associated with

surface water quality, hydrology, and use, and determined them to be Category 1 issues that

have been discussed and generically resolved in the GElS for license renewal. The only

exception to this generic finding is in the case where there exists water use conflicts for plants

with cooling ponds or cooling towers drawing makeup water from a small river with low flow,

which is not applicable to the CNS site. In accordance with 10 CFR 51.71(d), this SEIS relies "on conclusions as amplified by the supporting information in the GElS for issues designated as

Category 1.." In summary, the comment relating to the surface water issues has been previously

addressed in the GElS for license renewal. While the commenter presents various hypothetical

scenarios to consider, no new and significant information was identified to contradict the

previous findings in the GELS.

Therefore, no changes were made to the SEIS as a result of the comment.

July 2010 A-49 NUREG-1437, Supplement 41
Appendix A

Response to EPA Comments on Aquatic Life

Regarding comparison of impingement at CNS to impingement by other facilities using the

same or other technology and source water, NRC's regulations define levels of impact in terms

of the effects that NRC's Federal action (license renewal or nonrenewal) would have on the

resources. NEPA calls for agencies to look at the direct and indirect effects of the proposed

action and their consequences (Sec. 1502.16 Environmental consequences), not the relative

effect of the proposed action compared to the effects of some other unrelated stressor. Even so,

a good comparison for the effects of impingement at CNS is Fort Calhoun Generating Station,

which is located about 113.5 river miles (183 river kilometers) north of CNS. Aquatic ecology

sections of the CNS and Fort Calhoun Generating Station SEISs summarize studies by Hesse

et al. (1982) that monitored the effects of both stations. Although Fort Calhoun Station is smaller

(1,500 megawatts-thermal (MWt)) than CNS (2,419 MWt), aspects of the structures and

operation that affect aquatic resources are similar (Table A-2). The NRC found the level of

impact at both generating stations to be small.

Table A-2. Structures and Operations of Cooper and Fort Calhoun Generating Stations

That Affect Aquatic Resources

Structure or Operation Cooper Nuclear Station Fort Calhoun Generating Station

Output (MWt) 2,419 1,500

Type of cooling system Once-through Once-through

Orientation and location of intake Along the shore of the Missouri River Along the shore of the Missouri River

structure

Traveling screens Yes Yes

Traveling screen mesh 118 x 1

/ in. (1.27 x 3.175 cm) 3/8 in. (1 cm) square

Screen approach velocity 0.7 to 1.1 2

(f/s; m/s) 0.2 to 0.3 0.6

Number of cooling water system 4 3

pumps

Capacity per pump (gpm; m3

/s) 159,000 120,000

10 7.6

Fish return system No No

Regarding the age and amount of impingement data, the EPA, not the NRC, regulates cooling

water intake structures through the Clean Water Act and oversees collection of information on

the effects of entrainment and impingement for Section 316(b) demonstrations in NPDES

permits.

The NRC does not have a regulatory framework for radiological protection of nonhuman species

to use in the SEIS. The NRC believes that if humans are adequately protected, other living

things are also likely to be sufficiently protected. Nevertheless, a qualitative assessment of the

impact to biota from radioactivity released into the Missouri River was performed using radiation

protection standards for biota from recognized scientific organizations.

The International Atomic Energy Agency (IAEA) and the National Council on Radiation

Protection and Measurements reported that a chronic dose rate of no greater than 1 radiation

absorbed dose per day (rad/d) (10 milligrays per day (mGy/d)) to the maximally exposed

individual in a population of aquatic organisms would ensure protection of the population. The

IAEA also concluded that chronic dose rates of 0.1 rad/d (1 mGy/d) or less do not appear to

NUREG-1437, Supplement 41 A-50 July 2010
Appendix A

cause observable changes in terrestrial animal populations. The NRC assessed the cumulative

effects to aquatic biota from radionuclides, including tritium, released into the Missouri River

from CNS in relation to the calculated dose to a member of the public from radioactive liquid

effluents. For 2009, the calculated annual whole body dose to a member of the public from

radioactive liquid effluents was 2.45 E-2 millirems (mrem) (2.45 E-4 milliseiverts (mSv)). This

dose assumes an exposure point at the effluent and pathways appropriate for a human

receptor. This dose is well below the 25 mrem (0.25 mSv) EPA radiation protection standard in

40 CFR Part 190 and the NRC's ALARA criteria of 3 mrem (0.03 mSv) in Appendix I to

10 CFR Part 50. In comparison to the dose rate criteria for aquatic and terrestrial biota, a dose

of 2.45 E-2 mrem (2.45 E-4 mSv) delivered over the course of a year from periodic radioactive

liquid effluent discharges represents a negligible impact.

No changes were made to the SEIS as a result of the comment.

Response to EPA Comments on Stormwater and Wastewater Treatment

The GElS resolved the human health impacts from the release of radioactive effluents from

nuclear power plants as a Category 1 issue that is generic to all plants. The GElS evaluated the

radioactive gaseous and liquid effluents released into the environment and concluded that the

impacts are of small significance, provided they are within NRC dose standards. The evaluation

was based on the radioactive effluent release reports submitted by licensees to the NRC on an

annual basis. These reports contain information on the types and quantities of radioactive

material released from the plant from various plant specific release points (i.e., plant vent, liquid

discharge line, stormwater drains, and wastewater treatment facility) into the environment and

the calculated dose to a member of the public that may be exposed to the material. The GElS

reported that trends for average doses for persons living around nuclear power plants reflect the

small radiation dose levels seen in the calculated doses reported by the nuclear power industry.

The GElS further reported that radiation doses to members of the public from the operation of

nuclear power plants were found to be well within the NRC's regulatory standards.

The NRC requires that radioactive effluents discharged into the environment be accounted for,

regardless of where they originated from (i.e., plant vent, liquid discharge line, stormwater

drains, or wastewater treatment facility), and be reported in the annual effluent release report. In

addition, the licensee is required to calculate the dose to a member of the public from

radioactive gaseous and liquid releases. The calculated doses are required to be within NRC

dose limits. Compliance with NRC dose limits is inspected by NRC regional inspectors on a

routine basis. In addition to the radioactive effluent monitoring program, the NRC requires the

plant to have a REMP that monitors the environment around the site for radioactive

contamination. The REMP supplements the radioactive effluent monitoring program by verifying

that the measurable concentrations of radioactive materials and levels of radiation in the

environment are not higher than those calculated using the radioactive effluent release

measurements and transport models. The REMP can also provide an indication that there is an

abnormal radioactive release if unusual or unexpected data is observed.

In summary, the comments relating to radiological issues, such as the impacts from radioactive

gaseous and liquid effluents released into the environment from the facility, have been

evaluated in the GElS for license renewal and no new and significant information was identified

during the scoping process, the review of the CNS ER, and the staff's site visit that contradict

the GEIS's findings. Therefore, there are no impacts beyond those identified and evaluated in

the GElS.

No changes will be made to the SEIS based on the comment.

July 2010 A-51 NUREG-1437, Supplement 41
Appendix A

Response to EPA Comments on Spent Fuel Storage and Independent Spent Fuel Storage

Installation

The storage of spent nuclear fuel is a Category 1 issue and discussed in Chapter 6 of the SEIS.

The safety and environmental effects of spent fuel storage have been evaluated by the NRC

and, as set forth in the Waste Confidence Rule (10 CFR 51.23), the Commission has made a

generic determination that, if necessary, spent fuel generated in any reactor can be stored

safely and without significant environmental impacts for at least 30 years beyond the licensed

life of operation (which may include the term of a revised or renewed license) of that reactor at

its spent fuel storage basin or at either onsite or offsite ISFSIs.

The GElS evaluated a variety of spent fuel and waste storage scenarios, including onsite

storage of these materials for up to 30 years following expiration of the operating license,

transfer of these materials to a different plant, and transfer of these materials to an ISFSI.

During dry cask storage and transportation, spent nuclear fuel must be "encased" in

NRC-approved casks. An NRC-approved cask is one that has undergone a technical review of

its safety aspects and been found to meet all of the NRC's requirements. These requirements

are specified in 10 CFR Part 72 for storage casks and 10 CFR Part 71 for transportation casks.

For each potential scenario involving spent fuel, the GElS determined that existing regulatory

requirements, operating practices, and radiological monitoring programs were sufficient to

ensure that impacts resulting from spent fuel and waste storage practices during the term of a

renewed operating license would be small and is a Category 1 issue. This conclusion is

contained in NRC regulation; in Table B-1 of Appendix B to Subpart A to Part 51, the

Commission concluded that the impacts associated with spent fuel and high level waste

disposal are acceptable in that these impacts would not be sufficiently large to require the NEPA

conclusion, for any plant, that the option of extended operation under 10 CFR Part 54 should be

eliminated. The staffs evaluation of the CNS license renewal application did not find any new

and significant information related to the storage of spent nuclear fuel. Thus, there are no

impacts related to spent nuclear fuel storage beyond those discussed in the GELS.

No changes will be made to the SEIS based on the comment.

Response to EPA Comments on Environmental Justice

Socioeconomic conditions at the Sac and Fox and Iowa Reservation would not change as a

result of renewing the CNS operating license. Employment levels at CNS would remain

relatively unchanged, so direct and indirect employment opportunities caused by CNS would

remain unchanged. The Sac and Fox and Iowa Reservations receive no income from tax

monies paid by NPPD to the State of Nebraska. Nevertheless, the SEIS has been revised to

more fully describe the overall potential human health and environmental effects that could

affect minority and low-income populations including the Sac and Fox and Iowa Reservation

populations.

The discussion in Section 4.9.7.4 summarizes the results from the CNS 2007 REMP report and

incorporates this document by reference. The analysis of impacts was performed on more than

a single year's worth of REMP data. While the REMP generates an annual report, each report

provides several years of analytical and historic trend information on a number of critical

pathways (e.g., airborne iodine, fish, milk, and broadleaf food crop vegetation). For example, the

2007 REMP report provides a trend analysis of cesium-137 in fish samples going back to June

1995. The results of the REMP continues to demonstrate that the operation of CNS does not

result in a significant measurable dose to a member of the general population nor adversely

impacts the environment as a result of radiological emissions and effluents.

NUREG-1437, Supplement 41 A-52 July 2010
Appendix A

Section 4.9.7.2 of the SEIS was revised to describe the impact on the Sac and Iowa

Reservation as a result of renewing the CNS operating license.

Response to EPA Comments on Supercritical Coal-Fired Generation

While there are many coal-burning facilities in the area, any of the proposed alternatives would

add to these current emissions. As mentioned in Section 8.1, air quality regulations are currently

in place for these facilities, and any new construction would be subject to the Prevention of

Significant Deterioration of Air Quality Review by the Nebraska Department of Environmental

Quality. The NRC staff is of the opinion that, unless regional carbon regulations and monitoring

systems are in place, assessing the air impacts of the coal-fired alternative in addition to the

emissions of existing coal-burning facilities in the area does not meaningfully add to the

alternatives discussion in Section 8.1.

The NRC staff recognizes that mercury contamination of fish in fresh water streams is an issue

in Nebraska. Mercury is brought up as a contaminant of concern in Section 8.1; however, the

potential effects are not discussed in further detail because, upon evaluation, the coal-fired

alternative is the clearly inferior option. The NRC staff did not think it necessary to go into further

detail on the issue of potential mercury contamination because the results would not have

affected the impact level determination.

No changes will be made to the SEIS based on the comment.

Response to EPA Comments on Environmental Impact of Alternatives

In the SEIS, the NRC staff concluded that license renewal of CNS would result in smaller

impacts than the other considered alternatives. All alternatives were considered in detail, based

on the technical review of the potential environmental impacts found in Chapters 4, 5, 6, 7, and

8. The NRC staff found that the alternatives to license renewal of CNS resulted in larger

potentially adverse environmental impacts than the proposed action, the impacts of which were

evaluated in Chapter 4 of the SEIS.

The staffs SEIS for the proposed CNS license renewal, in addition to evaluating potential

alternatives, must satisfy NRC regulations in 10 CFR 51.95(c)(4) which states that, "the NRC

staff, adjudicatory officers, and Commission shall determine whether or not the adverse

environmental impacts of license renewal are so great that preserving the option of license

renewal for energy planning decisionmakers would be unreasonable." Thus, by regulation, the

final SEIS must contain the staff's recommendation on whether the impacts of license renewal

ought to preclude its availability as a future system generating option.

The NRC staff rigorously explored and devoted sufficient treatment to each considered

alternative to determine which alternatives were environmentally preferable. Each of the

alternatives considered were evaluated in terms of potential environmental impacts by NRC

technical staff in the same resource areas evaluated for the proposed action in Chapter 4 of the

SEIS. Potential environmental impacts in each resource area were determined to be SMALL,

MODERATE, or LARGE based on these technical evaluations in order to provide a clear basis

for choice among the alternatives. These findings are presented in Table 8-5 alongside the

impacts of the proposed action in order to present a clear comparison of the overall impact

levels.

Each alternative is evaluated separately to obtain a more accurate picture of the potential

impacts. Table 8-5 is included at the end of Chapter 8 in order to provide a direct comparison of

July 2010 A-53 NUREG-1437, Supplement 41
Appendix A

the potential impacts of each discussed alternative, including license renewal. From this

comparison, the NRC staff determined that these alternatives resulted in larger potentially

adverse environmental impacts than the proposed action.

A.2.4 Comments on the Draft Supplemental Environmental Impact Statement from the

Applicant

Comment CNS-Z:

NLS2010037

April 29, 2010

U.S. Nuclear Regulatory Commission

Attention: Document Control Desk

Washington, D.C. 20555-0001

Subject: Comments on Draft Generic Environmental Impact Statement Supplement 41

Regarding the Cooper Nuclear Station License Renewal Application

Cooper Nuclear Station, Docket No. 50-298, DPR-46

References: 1. Letter from Bo Pham, U.S. Nuclear Regulatory Commission, to Stewart B.

Minahan, Nebraska Public Power District, dated February 18, 2010, "Notice of

Availability of the Draft Plant-Specific Supplement 41 to the Generic

Environmental Impact Statement for License Renewal of Nuclear Plants

Regarding Cooper Nuclear Station, Unit 1 (TAC Nos. MD9763 and MD9737)."

2. Letter from Stewart B. Minahan, Nebraska Public Power District, to U.S.

Nuclear Regulatory Commission, dated September 24, 2008, "License Renewal

Application" (NLS2008071).

Dear Sir or Madam:

The purpose of this letter is for the Nebraska Public Power District (NPPD) to provide comments

on the draft Generic Environmental Impact Statement (GELS) Supplement 41 per Reference 1.

This draft GElS supplement was prepared in response to NPPDs License Renewal Application

(LRA) for Cooper Nuclear Station (Reference 2). The NPPD comments are itemized in

Attachment 1. Section 2.1.6 of the draft GElS supplement had significant number of comments,

and so a recommended underline/strikeout revision is provided in Attachment 2. Attachment 3

contains certain changes to the LRA Environmental Report resulting from the review of this draft

GElS supplement.

Should you have any questions regarding this submittal, please contact David Bremer, License

Renewal Project Manager, at (402) 825-5673.

I declare under penalty of perjury that the foregoing is true and correct.

Executed on

(Date)

NUREG-1437, Supplement 41 A-54 July 2010
Appendix A

Sincerely,

Brian J. O'Grady

Vice President-Nuclear and

Chief Nuclear Officer

/Wv

Attachments

cc: Regional Administrator w/ attachments

USNRC - Region IV

Cooper Project Manager w/ attachments

USNRC - NRR Project Directorate IV-1

Senior Resident Inspector w/ attachments

USNRC - CNS

Nebraska Health and Human Services w/ attachments

Department of Regulation and Licensure

NPG Distribution w/ attachments

CNS Records w/ attachments

July 2010 A-55 NUREG-1437, Supplement 41
I Appendix A

NRC Response to Comments in CNS-Z: NPPD provided comments and corrections to the

draft SEIS as shown in the letter dated April 29, 2010, above. The NRC staff response to their

comments is as follows:

Comments: #1-9, 11-13, 15-44, 46-85, 87-143, 146, 148-172, 174-199, 201-211, 213-234,

236-286, and 288-327 consisted of editorial comments (e.g., spelling, grammar, word choice)

and suggestions for clarifications in the draft SEIS.

Response: The staff made corrections, as appropriate, for editorial comments within the text of

this SEIS. Where the commenter requested clarifications, the staff provided additions or

deletions of text, as appropriate, to better convey the intended meaning of the discussion.

Comment #10: The statement "...plans to implement others..." regarding impingement

mitigation measures should be clarified with a rejoinder to pending changes to Section 316(b) of

the Clean Water Act.

Response: The statement of concern is part of the Executive Summary and is not meant to be

specific, as details are provided in Chapter 4. No changes to the SEIS were made as a result of

this comment.

Comment #14: The discussion of "Comparison of Alternatives" seems to be missing a summary

of the Staff's conclusions regarding the combination alternative. Recommend a summary

statement in the Executive Summary as it pertains to the "Comparison of Alternatives."

Response: The statement of concern is part of the Executive Summary and is not meant to be

specific, as details are provided in Chapter 4. No changes to the SEIS were made as a result of

this comment.

Comment #45: The sentence "The EPA's clearinghouse can be used as a source for additional

opportunities for waste minimization and pollution prevention at CNS, as appropriate." makes

the implication that NPPD does not have an effective waste minimization plan.

Response: The implication regarding NPPD's waste minimization program is inferred by the

commenter, not the statement in the SEIS. No changes to the SEIS were made as a result of

this comment.

Comment #86: It is not clear what this figure is trying to communicate. Recommend clarification

or deletion.

Response: The discussion associated with Figure 2.2.5-1 is in Section 2.2.5.2, "Conceptual

Model of Midwestern Rivers." No changes to the SEIS were made as a result of this comment.

Comment #144: The race percentages do not add up to 100%.

Response: The individual percentage values for race in Table 2.2.8.5-2 were rounded off

individually during the staffs estimation and thus resulted in a total summation slightly off

100 percent. Nevertheless, the percentages provide a qualitative basis for comparison across

the regions. No changes to the SEIS were made as a result of this comment.

Comment #145: If some other race category has been eliminated from the Census estimate,

why is it being included in the table? Consider eliminating the category of "Other Race."

NUREG-1437, Supplement 41 A-56 July 2010
Appendix A I

Response: The comment is noted. However, such artifact from previously available information

provides some context for comparison. No changes to the SEIS were made as a result of this

comment.

Comment #147: The numbers provided for "Nebraska in Lieu of Taxes to Counties with NPPD

Retail Electric Sales Attributed to the CNS-1 ," "Payments to Retail Communities Attributed to

CNS-1," and the Total values do not match what was provided in ER Table 2.7-1. Recommend

revision to conform with ER information.

Response: The staff acknowledges the values provided by NPPD in ER Table 2.7-1. However,

the values provided in Table 2.2.8.6-3 represent the staff's independent verification of figures

tabulated using NPPD's financial reports for those years. The slightly higher figures in the SEIS

are most likely due to the staff's inclusion of smaller generating capacity from NPPD other than

CNS. Nevertheless, Table 2.2.8.6-3 provides a comparison basis for such figures over the

years, and the difference in accounting when compared with the ER values does not change the

staff's findings on the socioeconomic impacts of taxes. No changes to the SEIS were made as a

result of this comment.

Comment #173: Recommend the use of the word "reasonable" over "useful."

Response: The recommendation is noted. However, no changes were made to this SEIS based

on the comment.

Comment #200: NPPD has procedural administrative controls in place to ensure that cultural

resource reviews are conducted prior to engaging in construction or operational activities in

previously undisturbed areas that may result in a potential impact to cultural resources at the

site [NPPD, 2007c]. Areas depicted in Phase 1A Literature Review and Archeological Sensitivity

Assessment were identified as higher probability archeological site areas on the CNS Owner

Controlled Area. However, NPPD has developed a Cultural Resources Protection Plan in an

effort to meet state and federal expectations and includes measures for archeological

investigations (Phase 1B) and consultations with the Nebraska and Missouri State Historic

Preservation Offices (SHPO), and the appropriate Native American groups prior to any future

ground disturbing activities [CNS, 2008]. These measures provide adequate protection for

potential area cultural resources.

Response: The comment reflects a preference and provides no additional basis. In accordance

with NEPA, it is appropriate for the staff to document its findings of environmental impacts and

State recommendations for further mitigation if such actions are appropriate. No changes were

made to the SEIS as a result of this comment.

Comment #212: This section states:

"The impact of introduction and stocking of native and introduced fish species is also somewhat

similar to the impact of CNS, because the effect of a power plant that impinges and entrains

aquatic organisms is somewhat similar to that of a large predator introduced into an aquatic

system."

This appears to be subjective and is not substantiated. Recommend deletion.

July 2010 A-57 NUREG-1437, Supplement 41
I Appendix A

Response: The statement of concern in the SEIS is the staffs attempt to provide context for a

qualitative comparison and not meant to be proven or substantiated. No changes were made to

the SEIS as a result of this comment.

Comment #235: It is not clear why a discussion of alternatives is made in this cumulative

impacts assessment. The National Environmental Protection Act requires the cumulative impact

conclusions be based on known and foreseeable actions, not hypothetical alternatives.

Recommend deletion.

Response: The discussion regarding the fossil-fuel alternative is meant to provide a context for

comparison with respect to greenhouse gas (GHG) emissions. No changes were made to the

SEIS as a result of this comment.

Comment #287: It does not appear to be reasonable to conclude that 250 MWe of CNS

baseload generation can be replaced by conservation. The Staff claims that this is supported by

the state's energy efficiency goals, but this does not seem realistic.. Request NRC verify and

provide reference of the source of the Nebraska energy efficiency goals.

Response: The commenter asserts that 250 megawatts-electric (MWe).is not a realistic

assumption for CNS's generation to be replaced by conservation, but does not provide

additional information to support. The 250 megawatis-electri (MWe) was taken from the

Nebraska and State Goals for Energy Efficiency under the Energy Policy Act of 2005

(http://appsl.eere.energqy.qov/states/economic indicators.cfm/state=NE) . Although the 250

MWe estimate does not specify how such conservation will be achieved, the quantity of concern

is not a significant amount considering the energy production and consumption throughout the

entire State. No changes were made to the SEIS as a result of this comment.

Comment in Attachment 2 of its letter dated April 29, 2010, NPPD suggested revisions to

Section 2.1.6 of the draft SEIS to clarify: a) ER changes from NLS2009036, b) the U.S. Army

Corps of Engineers Missouri River flow regulation, and c) suggest a different format to present

the discussion for the cooling and auxiliary water systems.

Response: The staff reviewed and incorporated, where appropriate, the information provided

by NPPD, previously provided in a request for information response. The staff also confirmed

that the changes were limited to describing the system and its interaction with the environment,

and that such changes did not alter the staffs findings, as documented in Chapters 4 and 9.

Comment in Attachment 3 of its letter dated April 29, 2010, NPPD provided revisions to its

ER to reflect changes based on the development of its 316(b) determination under the Clean

Water Act requirements.

Response: The staff reviewed changes to NPPD's ER and confirmed that such changes did not

alter the staffs findings, as documented in Chapters 4 and 9. As of publishing date of this SEIS,

NPPD has not physically installed the fish handling system, whose final design and

implementation will be dependent upon the content of the final 316(b) Clean Water Act

requirements.

A.2. References

U.S. Nuclear Regulatory Commission (NRC). 2009a. "United States Nuclear Regulatory

Commission, Nebraska Public Power District, Cooper Nuclear Station, Notice of Intent to

NUREG-1437, Supplement 41 A-58 July 2010
Appendix A

Prepare an Environmental Impact Statement and Conduct Scoping Process," Federal Register,

Vol. 74, No. 15, pp. 4476-4477, January 26, 2009.

Hesse, L.W., G.L. Hergenrader, H.S. Lewis, S.D. Reetz, and A.B. Schlesinger (Hesse et al.).

1982. The Middle Missouri River: A Collection of Papers on the Biology with Special Reference

to Power Station Effects, The Missouri River Group, Norfolk, Nebraska.

U.S. Nuclear Regulatory Commission (NRC). 2009b. "Summary of Public Environmental

Scoping Meeting Related to the Review of the Cooper Nuclear Station License Renewal

Application," Agencywide Documents Access and Management System (ADAMS) Accession

No. ML000910308.

July 2010 A-59 NUREG-1437, Supplement 41

NLS2010037 CNS-Z

Attachment 1

Page 1 of 49

Attachment 1

Comments on Draft Generic Environmental Impact Statement Supplement 41

Regarding the Cooper Nuclear Station License Renewal Application

Cooper Nuclear Station, Docket No. 50-298, DPR-46

July 2010 A.1-1 NUREG-1437, Supplement 41
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CNS-Z

Commn PgNubr U. ' Cmment ' -

1 GENERAL The draft Supplemental Environmental Impact Statement (DSEIS) uses Change "CNS-1" to "CNS" through draft SEIS.

the acronym "CNS-1" when referring to Cooper Nuclear Station. No

other nuclear units have ever been contemplated at the site. Consistent Basis for Change: List of Acronyms in the CNS

with other single unit SEISs (e.g., "KPS" (Kewaunee), "WCGS" (Wolf Environmental Report.

Creek), and "JAFNPP" (Fitzpatrick) the acronym "CNS" should be used

for Cooper Nuclear Station, without "-1."

2 GENERAL Measurement units are inconsistent. Sometimes metric units are

provided in the text and U.S. customary units are provided in

parentheses. Sometimes the reverse is presented. Both measurements

are not always provided.

Examples:

Page 2-19, lines 19-20: mg/I, but not ppm

Page 2-19, line 4:1000 ft., does not have accompanying meters

Page 2-20, line 21: 50 miles, but not kilometers

3 GENERAL Punctuation within references in text is inconsistent. Periods, commas,

semi-colons, or no punctuation at all are all used for the same purpose/

location within a reference.

Examples:

Page 2-29, lines 45-46: No punctuation within reference

Page 2-29, line 18: Same reference, comma used

Page 4-15, line 43: Semi-colon within reference

4 GENERAL Inconsistent use of abbreviations/ acronyms, etc.

Example: Page 2-31, lines 29-30: River miles, river mile, and RM are all

used within the same sentence. RM has been used previously and

should be used from that point forward.

I NUREG-1437, Supplement 41 A.1-2 July 2010
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ý,Comment P.•. Ucb2Su.g.o " oPaeN "utioNn' "' o 

NO, Line ,Number .-. r ';: ~ .~ ~~

5 GENERAL Inconsistent application of 'C and *F. Degree symbol should be

immediately after the number. No spaces between number, symbol, or

C/F.

Example: Page 2-33, line 15

6 GENERAL Per the Chicago Manual of Style, whenever there are multiple

references in a given year from a single author, the series starts with "a."

Example, Reference "(NPPD 2008)" should be "(NPPD 2008a)" on Page

2-82/Line 27; Reference "(NCDC 2009)" should be "(NCDC 2009a)" on

Page 2-80/Line 10.

It is recommended that all of the DSEIS Reference Sections be reviewed

for this writing style inconsistency and renumbered, with corresponding

changes made in the text.

7 iii/2 Brownville is a village, not a city. Revise to read: "...in the Gi4yi of

Brownville..."

Basis for Change: CNS License Renewal

Application Environmental Report (ER) Section

2.1

8 xvii/11 References "(May 1996), (NRC 1996)" are not defined. They should

either be deleted or a reference section added at the end of the

Executive Summary.

9 xix/10 and 11 It is not clear what the Staff means regarding the absence of "generic Revise to read: "...Category 1 or g,,o,,c .r.unground water issues." water

Basis for Change: A finding on "new and

significant information" for ground water use and

quality is unrelated to generic ground water

issues.

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Com-ment ~Page Numb&ir comment, w< Rqesolution,- 'NO .LinieNunbert, ''~-., -~-

I10 xixI30 The statement "..ians to implement others." regarding imo~inoement Revise to read: NPPD has implemented some

mitigation measures should be clarified with a rejoinder to pending

changes to Section 316(b) of the Clean Water Act.

impingement mitigation measures and plans to

implement others, as necessary for compliance

with Section 316(b) of the Clean Water Act."

Basis for Change: Clarification. See Attachment

3, Changes 2, 4, 5, 6, 7, 8, 9, 10, and 11.

Insert space after "fields." Revise to read: "electromagnetic fields-- acute

effects..."

Basis for Change: Typographical correction.

Incomplete list of Category 2 socioeconomic impacts. Revise to include "public services (education -

refurbishment)."

Basis for Change: NUREG-1 555 Supplement 1

No change. NPPD has informed NRC that it does

not plan

There should be a space inserted with "...impacts(..." Typographical

correction.

The discussion of "Comparison of Alternatives" seems to be missing a

summary of the Staff s conclusions regarding the combination

alternative. Recommend a summary statement in the Executive

Summary as it pertains to the "Comparison of Alternatives."

Insert symbol of mercury and period after mercury. Delete dash. Delete Revise to read: "...and mercury (Hg). The

"and" and capitalize "the" to form a new sentence. Otherwise it is a corresponding..."

run-on sentence.

Basis for Change: Grammatical enhancement

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irnber~ Co me t,,-,4

'rq6ý~ Reouin

I Ixxii/31 The statement "The gas-fired alternative would have slightly lower air

emissions,..." makes it sound like gas-fired alternative would have lower

air emissions than a nuclear plant.

Revise to read: "The gas-fired alternative would

have slightly lower air emissions than the

coal-fired alternative,

Basis for Change: Verbiage enhancement for

clarity

xxvi/3 "CWERCLA" should be changed to "CERCLA." Revise to read: "CWERCLA"

Basis for Change: Typographical correction

xxix/1 "NDED" is defined as the "Nebraska Department of Education" in the

Table of Acronyms. However, "NDED" is defined as the "Nebraska

Department of Economic Development" on Page 2-81, Line 17. The

Nebraska Department of Education is "NDE," as stated on Page 2-81

Line 26. Recommend the Table of Acronyms be revised and include an

"NDE" entry.

xxxi/10 Delete "SPDES" and "State Pollutant Discharge Elimination System"

since this program is designated as the "NPDES" program in Nebraska.

1-1/7 and 8 The sentence reads awkwardly. Revise to read: "The Atomic Energy Act of 1954

(AEA) e-ieinally specifies4 that licenses for

commercial power reactors be granted for up to

40 years, and permits license renewal."

Basis for Change: Grammatical enhancement

1-1/19 After "2014," a reference should be provided to the CNS License Revise to read: "...2014. (NPPD 2008a)"

Renewal Application.

Basis for Change: Referencing enhancement

1-2/Figure 1-1 The asterisked statement and block connector lines are difficult to read

against the dark background.

July 2010 A.1 -5 NUREG-1437, Supplement 41 I
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21 -. ~r. {.. ~.. Suggested Resolution

R in

The entry:

"Mr. Ron Asche

NPPD

1414 1 5 th Street

Columbus, NC 68601"

is a duplicate entry from Page 1-8, and is also the wrong address, it is

Nebraska, not North Carolina. Recommend deleting this entry.

General NPDES Permit Expiration Date is incorrect. Revise to clarify that this is the stormwater permit

and to read: "Expires: 9/17/2042 2002." (Add

footnote that this has been administratively

extended by the Nebraska Department of

Environmental Quality (NDEQ)).

Basis for Change: NLS2009036 Change 12.

Hazardous Waste Generator Identification Number is not correct. Revise to read: "NED1055071061 2

NED055071062."

Basis for Change: NLS2009036 Change 12

Permit Number 0218-26-08-X with the South Carolina Department of Revise to delete the entry for CNS-1 Radioactive

Health and Environmental Control is expired and is no longer being Waste Transport Permit.

used.

Basis for Change: NPPD is no longer authorized

to ship radwaste under this permit. See

Attachment 3, Change 12.

Missing Stormwater NPDES Construction Permit for Independent Spent Revise to include a third line item provided in

Fuel Storage Installation construction. NLS2009036, replacement page 9-5.

Basis for Change: NLS2009036 Change 12

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CNS-Z I

9, ~ , *eso> .2Cu',4 %t4\ihuA2 'Co .--.me t' 

28 1-1 1/Table 1-1 The Section 404 Permit for dredging at intake structure and discharge of Revise to include a fourth line item provided in

dredge material to the Missouri River is missing from the table. NLS2009036, replacement page 9-5.

Basis for Change: NLS2009036 Change 12

29 1-11/Table 1-1 Missing Section 404 Permit for intake structure ice deflectors. Revise to include a fifth line item provided in

NLS2009036, replacement page 9-5.

Basis for Change: NLS2009036 Change 12

30 1-1 1/Table 1-1 Permit Numbers T-NE002-L08 and 0111000042 need to be updated Revise.to read:

with latest expiration dates. [T-NE002-L08] "Expires: 12/31/200810"

[0111000042] "Expires: 1/3/200911"

Basis for Change: NPPD has received new

expiration dates for these permits from the

relevant State agencies. See Attachment 3,

Changes 13 and 14.

31 Chapter 2 Global The NAS 2002 and National Research Council 2002 are the same

document. Change all references to "National Research Council 2002"

throughout the chapter to "NAS 2002," and delete National Research

Council reference in Section 2.4.

32 2-1/9 Change "including" to "inclusive of the." Grammatical enhancement.

33 2-1/10 This sentence could be read (in light of previous and subsequent Revise to read: [Relocate to the end of Line 12]

sentences) to apply to the Nebraska Public Power District (NPPD) land "Over 99 percent of the total acreage in Nemaha

in Nemaha County. County is used for agriculture and farming."

Basis for Change: Clarification

July 2010 A.1-7 NUREG-1437, Supplement 41 I
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Comment Pagei Numberf omnt.'' ..

34 2-1/11-12 These lines mention that 234 acres is leased for agricultural purposes, Revise to read: "A significant portion of NPPD

but that is the land that is now subject to the environmental easement property at CNS-1, 234 acres in Missouri and 715

that is mentioned later. For consistency, the text should mention the acres in Nebraska, is currently leased for

environmental easement in addition to the use for agricultural purposes. agricultural activities such as farming and raising

livestock or conservation purposes."

Basis for Change: Change for consistency

35 2-1/20 The 100m meteorological tower is 328.08 ft, not 328.8 ft. Revise to read: "... and the approximately

328,8-foot tall..."

Basis for change: Clarification

36 2-7/27 A reference should be provided for "40 CFR Part 190" in the Section 2.4

references for consistency with other CFR references provided.

37 2-8/19 "NAC Title 128 was updated in 2004..." This is incorrect, it was updated Revise to read: "...was updated in 2-042007..."

August 18, 2007.

Basis for Change: NAC Title 128 was last

updated on August 18, 2007.

38 2-8/23 and 24 The sentence "State-level regulators may add wastes to the EPA's list of Revise to read: "States authorized to administer

hazardous wastes." should be clarified, the RCRA program may require generators to

manage additional wastes, in addition to those

hazardous wastes listed by EPA."

Basis for Change: Clarification

39 2-8/24 and 25 The sentence "RCRA provides the standards for the treatment, storage,

and disposal of hazardous wastes for hazardous waste generators

(regulations are available in 40 CFR Part 262)." is not correct in that

40 CFR 262 only addresses generators, while 40 CFR 264 and

40 CFR 265 address treatment, storage and disposal facilities.

I NUREG-1437, Supplement 41 A. 1-8 July 2010
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Co6mment No.Pg Nmber!gete uag ~slti Line N r Con~~R~ ime:nw

ieN umber - ~ ~~

40 2-8/27 The reference to 40 CFR 260.10 is not correct. It should be Revise to read: "The EPA recognizes three main

"40 CFR Part 262." Additionally, add 40 CFR Part 262 to Section 2.4 types of the hazardous waste generators

references. (40 CFR 269.10 Part 262) based on the quantity

of the hazardous waste produced:..."

Basis for Change: CFR correction

41 2-8/29 Definition of Large Quantity Generators does not match Environmental Revise to read: "...Large Quantity Generators

Protection Agency (EPA) definition. (LQGs), that generate more than 2,200 pounds

(1,000 kg) per month eF-mer-e of hazardous

waste...."

Basis for Change: EPA website Glossary of

Terms

42 2-8/36 The sentence is missing an initial definite article. Revise to read: Insert "The" before "State..."

Basis for Change: Grammatical correction

43 2-9/36 "(NPPD, 2008)" is an incorrect reference. Revise to read: "(NPPD, 2088 2009c)"

Basis for Change: NLS2009036 Enclosure 5.3

44 2-9/39 The "(EPA, 2009a)" reference appears to be incorrect based on Section Revise to read: "...approaches to pollution

2.4, which shows the EPA 2009c reference addressing waste prevention (EPA,_2009ac)..

minimization.

Basis for Change: Reference correction

45 2-9/40 and 41 The sentence "The EPA's clearinghouse can be used as a source for Revised to read: "The EPA's clearinghouse can

additional opportunities for waste minimization and pollution prevention be used for waste minimization and pollution

at CNS-1, as appropriate." makes the implication that NPPD does not prevention opportunities by RCRA-regulated

have an effective waste minimization plan. facilities, as appropriate. Note that Cooper

already has an effective waste minimization

program in place."

Basis for Change: Clarification

July 2010 A.1-9 NUREG-1437, Supplement 41 I
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CNS-Z

Statement that ER notes that four transmission lines are owned and Revise to read: "T4he-NPPD notes in their ER that

operated by NPPD is incorrect. four transmission lines, three of which are owned

and operated by NPPD, are..."

Basis for Change: ER Section 3.2.7.

Transmission line "TL301" should be "TL3501." Revise to read: "Two of these numbered lines,

NPPD TL3501 and..."

Basis for Change: ER Section 3.2.7

The 145 mile transmission corridor length should be 146 miles. Revise to read: "...transmission line corridor

extending 1456 miles (2335 km)

west-northwest..."

Basis for Change: ER Section 3.2.7, 63.6 + 82.6 =

146.2

I4

The paragraph as written does not accurately characterize the Omaha

Public Power District lines that connect with the CNS switchyard.

Revise to read: "There are several transmission

lines ri4g§intin, at that connect with the CNS-1

switchyard that are neither owned nor operated

by GNS-1-NPPD. These consist of tT-wo

transmission lines r~igintqiqat-connectinq with

the CNS-1 switchyard, which are owned by the

Omaha Public Power District (OPPD). Another

transmission line connecting with one of the

OPPD lines, not connected to the CNS switchyard

and- a th-d is owned by Aq~iWKansas City Power

and Light.

Basis for Change: ER Section 3.2.7. Also, Aquila

became Kansas City Power and Light on

7/14/2008.

I I

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Cmet ýPe ubr'Comment .sc Su Resolution

50 2-11/4 and 5 The discussion regarding the transmission lines that are in the scope of Revise to read: "As these three transmission line,

license renewal does not seem to indicate a proper rationale for are not owned or under the control of NPPD and

inclusion; i.e., that the lines originally connected the plant to the grid. ,were not constructed to connect CNS to the

Instead, the Staff seems to indicate that the in-scope lines are those transmission system, they are not within the

owned or under the control of NPPD. scope of license renewal for CNS-1 (NPPDA

2008a).

Basis for Change: Refer to ER Page 3-20,

Section 3.2.7.

51 2-11/6 and 7 A word search was performed of the ER, and no statement could be Revise to read: "The transmission lines do not

found that transmission lines do not cross any Federal, State, or local cross any Federal, State, or local parks (NPPDparks. Only one transmission crosses the United States Fish and. 2008). However, the western half of the only one

Wildlife Service (USFWS) rainwater basin area. in-scope transmission line corridor traverses

counties that..."

Basis for Change: No ER information supports th

statement. Clarification on transmission line

corrodors.

52 2-11/11 The "(USFWS, 2009h)" reference appears to be inaccurate based on the

Section 2.4 references, which shows it being associated with the Salt

Creek tiger beetle.

53 2-11/14 There are actually two separate farmers, one on each side of the Revise to read: "On th• GNS 1 prOPOrty the

Missouri River. It is not important to describe the number of farmers. agriu•ltr•al and iS m.a.ag.d by a single farm,,.

uoranA agroomont with NPPID.

Basis for Change: The statement appears to be

irrelevant.

54 2-11/26-27 Misquote of the ER. Revise to read: "Native grasses and low4ying

growing woody plants..."

Basis for Change: "Low-lying woody plants" is not

the same as "low growing woody plants."

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CNS-Z

omment, a Numer , Comment ...... .. . olution

55 2-12/1 Incorrect inspection periodicity. Revise to read: "ROW aerial inspections occur

bi month•y six times annually, and there is an

annual foot patrol inspection."

Basis for Change: Inspections do not occur every

two months.

56 2-15/Figure 2.1.6-2 NLS2009036 Change 10 has not been incorporated. Replace: Figure 2.1.6-2 with NLS2009036

Attachment 2, Enclosure Figure 3.2-4.

Basis for Change: NLS2009036 Change 10

57 2-17/34 The "(NPPD, 2008c)" appears to be incorrect based on the Section 2.4

references, since it refers to a 2007 NPPD Annual Report, which does

not appear to support this information.

58 2-17/42 "(NHHSS, 2000)" is defined as "Nebraska Department of Health and

Human Services" on Line 42. On Page 2-81/Line 39, this reference is

defined as "Nebraska Department of Health and Human Services

System." Which is correct?

59 2-18/8 For consistency with Page 2-20 (Line 7), change "This water eventually

reaches the water table and disperses." to "This water eventually

reaches the water table and disperses before likely discharging to the

Missouri River."

60 2-18/13-15 The DSEIS states: "Preliminary sampling and analysis results from the Revise to read: "The NRC staff will request that

ground water monitoring program for tritium will be submitted and NPPD submit p~reliminary sampling and analysis

summarized in the final SEIS." NPPD has not committed to provide this results from the ground water monitoring program

information, and believes it is inappropriate to use the DSEIS as the for tritium will be rubmitted and for

venue to solicit this action. However, NPPD is willing to provide this summarizedation in the final SEIS."

information following a request from the NRC staff.

Basis for Change: No communication has been

received requesting this information.

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61 2-18/29-30 NDEQ Title 117 lists additional beneficial uses for the Missouri River Revise to read: "Beneficial uses of surface water

than those provided, identified in the CNS-1 area are recreational,

aquatic life (Warmwater A), public drinking water

supply, agricultural water supply, industrial water

supply, and aesthetics for agricu!turFa! nd

indutria . .ator .upply (NDEQ, 2004)."

Basis for Change: Clarification

62 2-18/34 Reference to NPDES Permit NE-0001244 is not the correct designator. Revise to read: "...Nebraska NPDES permit

- NE0001244."

Basis for Change: ER Table 9.2-1

63 2-19/Table 2.1.7-1 Table 2.1.7-1 listed NPDES outfalls from an earlier permit. The present Revise Table 2.1.7-1 to: a) remove Outfalls 002a,

NPDES permit for CNS does not have Outfalls 002a, 003, 005, or 006. 003, 005 and 006 from this table since there are

Also, the present NPDES permit has pH limits for each of the remaining no such outfalls listed in the current NPDES

outfalls. Limits are Min. 6.5 SU and Max 9.0 SU. Permit, and b) for Outfalls 001, 002b, 002c, 004,

008 and 009, the pH effluent limitation of 6.5

(Minimum) and 9.0 (Maximum) should be added.

Basis for Change: NPPD NPDES Permit No.

NE0001244.

64 2-19/ Table 2.1.7-1 This table should have a reference to NPPD NPDES Permit No.

NE0001244.

65 2-19/Table 2.1.7-1 The "Max. proposed" temperature column should be deleted, as the

proposed NPPD NPDES Permit was approved.

66 2-19/6 "Outfall 006" should be "Outfall 001." Revise to read: ",,,through Outfall 0061..."

Basis for Change: NPPD NPDES Permit No.

NE0001244.

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,,-Comment' Page N~u'b '". Comi ,enti" Sugete Resluio

___________ý, er ~ ~ -~-

67 2-19/9-17 The outfall description does not match the latest NPPD NPDES Permit Revise to read: Outfalls-O,2a, 002b is the

as issued on June 26, 2007, by the NDEQ. discharge of industrial well ground water bypass,

RO reject, and boiler blowdown., a4d Outfall 002c

is the discharge of diesel generator, turbine fan

heater, boiler room floor drains, and HVAC

blowdown di..har.. wator from. roof drain sumps

AULU LIIUH 1H, i~iio cor~I

diGGchargc, and HYAC blow;.Adown, FrccpetivolyAlong with the intako ScreeR backwash

dischargod through Outfal! 003, Outfalls, 902a, b.

aF•id These outfalls discharge to the Missouri

River. Outfll 005 d-c-h-rgoc_ batch --lumcs of

canitar,' Waste 4fro the sewage lagoon 6ystem.

The dicchargo ic •Gprayd an nearby farm land

and is net directly rconnected to area curface

watr-ber .es

Basis for Change: NPPD NPDES Permit

NE0001244, Expiration Date June 30, 2012

Sentence reads awkwardly. Revise to read: "The only NPDES

non-compliance reported in the last five years

was for total suspended solids..."

Basis for Change: Grammatical enhancement.

Referenced Figure should be 2.2.1-1. Revise to read: "...Atchison County, Missouri, see

Figure 2.2.1-1."

Basis for Change: Typographical error

The cited source for Figure 2.2.1-2 is "(NPPD, 2008a)." This reference is

not provided in Section 2.4.

Reference "(David J. Wishart, 2004)" is not consistent with citation in Revise to read: "...(David J. Wishart, 200•)•

Section 2.4. (Wishart 2004)."

Basis for Change: Citation consistency

I NUREG-1437, Supplement 41 A.1 -14 July 2010
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Com ent~. ..... mitPug96sted Rh'olution1

72 2-23/31-32 Change @ symbols to "at" (grammatical enhancement).

73 2-24/18-36 Paragraph should be rewritten to state that CNS's potential to emit is

less than the criteria defined in Title V of the United States EPA Clean

Air Act and in Chapter 5, Title 129 of Nebraska Administrative Code for

criteria pollutants and hazardous air pollutants (HAPs). The

presentation of the emissions in tons should be clarified to more clearly

identify which pollutant is associated with which value for emissions, and

the source for the basis of those emissions should be provided as a

reference. Remove the mention of used oil as it is not relevant to air

emissions as discussed.

Revise to read: "CNS-1 has a number of

stationary emission sources, such as three

standby emergency power supply diesel

generators, auxiliaries required for safe starting

and continuous operation and which are tested

periodically to ensure their reliability to perform

their intended function, and several petroleum fuE

storage tanks. which do not roquiro thc faGcility to

cocuro Titlo V pormit. Since CNS's actual annual

emissions are less than the c~rite~ria de~fine~d in Titli

emissions are less than the criteria defined in Titil

V nf the l(GIe;n Air Ar-i nnd in Chqntfr .; Title 19Q

of Nebraska Administrative Code for criteria

pollutants and hazardous air pollutants (HAPs),

CNS-1-is has been granted a low emitter status

LY . f .~JA U a.4 II E ,CULU V 0 I ,,8-G---R -GW

quantitieS Of Om~iSSione that ara roguired to moot

critoria and not to exceodI thrAsholdc; for the

emsin f pollutants defined in Chaptor 5, Title

129 of Webr-aska; Adminnic-trativa CoGdo for theoiiosof particulato m~atter PM1O, carbo

MOnoxide (GO), velatile OF-ni copons

(VOC), oxidos of nitrogon ('0 ), -- 2 orS03 or

any combination of the Nve (S~x), single

Hazardous Air Pollutant (HAP) or Hazardous Air

Pollutant (HA12\) and load. As reported and

submitted to NDEQ, aetuai total annual emissionc

froM All courec at CNS-1 from 2004 to 2008

were 11.52 tons (10.45 MT) pef-yea , 10.73 tons

(9.73 MT) per-yea , 13.21 tons (10.73 MT) peryear, 11.43 tons (10.37 MT) per-year, and 9.85

tons (8.94 MT) per-yea respectively. Higherst e.icsons Ffrom 2004 to 2008, maximum

reported annual emissions occurred wereFePerted in 2006 at 13.21 tons (10.73 MT): 0.16

tons (0.15 MT) per-year of PM10, 2.41 tons (2.19

MT) per-yea of CO, 0.22 tons (0.20 MT)

of VOC, 9.0 tons (8.16 MT) pFer-year of NOx, 1.41

tons (1.28 MT) per-year of Sox, and 0.01 tons

.1. L _____________________________________________________________ L

July 2010 A.1-15 NUREG-1437, Supplement 41
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ýSuggested Resolution-

(0.009 MT) PeF-yea of single HAP (NPPD,

2009c). The g•nerators aFr tested priodicall'; to

encro- th~or continuedAi ability to peortorm thr

intendod function; and tharo aro procodurec i

placo to onsuro continouGU monitForin, sampling,

and filtoring of the oil. Used oil is collected for

offsite disposal: therefore, no used oil incineration

activities occur on the CNS site. Used ell d!speais discuss;,ed further in the waste management

rseefie*n,"

Basis for Change: Clarification

2-24/24-25 "PM10," "S02," and "SO3" should all have the numbers as subscript

("PM1O," "S02," and "S03"). Grammatical enhancement.

2-24/32 "Sox" should be "SO.." Grammatical correction.

2-24/38-39 Text suggests that the two monitoring sites are more than the 100-m Revise to read: "These -st-monitoring sites

tower and the 1 0-m tower. consist of ac•,,cmmodates a 328-foot (100-in)

primary meteorological tower and a 32.8-foot

(10-m) back up tower."

Basis for Change: Clarification

2-24/40 NLS2009036 Change 2 has not been incorporated. Revise to read: "The former is located

approximately 3,1,230 feet (488375 m) and the

latter..."

Basis for Change: NLS2009036 Change 2

I NUREG-1437, Supplement 41 A.1-16 July 2010
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Comment t~

Suggested ~

~

A .~.-

.9j>..

78 2-24/42-44 NLS2009036 Change 3 has not been incorporated. The text suggests,

incorrectly, that the second monitoring site is the new 100-m tower

erected to support dry cask storage at CNS. See also Comment 76.

Relocate text to Page 2-25 (new paragraph after

Line 8) and revise to read: "The- seccnd A new

monitoring site, a 328-foot (100-m) meteorologicz

tower is being planned for 2010, The design

details are incomplete, but the new tower will

meet or exceed thea nerfnrmance standards of thF

existing tower and will be fully compliant with

NRC requirements with equipment and m9nitorin

328 feot (100 in) tOWor, wac rccontl'; builtaprmtely 2~,000 feet (61u m)j nonnhwest toir*

fB sirst te."

Basis for change: NLS2009036 Change 3

79 2-25/11 Change "fresh water" to "freshwater." Grammatical enhancement.

80 2-25/18 The acronym "CRA" is not defined after its use here (although it is listed Revise to read: "As part of a hydrogeologic

in the Table of Acronyms). Some discussion of who "CRA" is would be investigation undertaken by CNS-1 for the study

helpful; e.g., some indication of their expertise. of radioisotopes in ground water, Conestoga

Rivers Associates (CRA) (a noted industry vendo

in such studies) reviewed..."

Basis for Change: Clarification

81 2-25/38 "Main-stem" should be "mainstem."

2-29/16

82 2-26/4 The metric flow rate for 31,000 cfs is missing. Revise to read: "... north of CNS-1, is 31,000 cfs

(878 m3 Is).''

Basis for Change: Correction

July 2010 A.1-17 NUREG-1437, Supplement 41
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Comet ago'NIu~ co rqent_,.,:Sugested Reso uto

83 2-26/4 and 5 The minimum permitted 3,000 cfs sanitary flow is not correct. The value Revised to read: "In December through February,

should be 4,320 cfs per the U.S. Army Corps of Engineers Master the minimum flow permitted is 3000 4,320 cfs (85

Manual. 122 m3

/s), primarily for sanitay wat. . , ... ,,-

Basis for Change: U.S. Army Corps of Engineers

Master Manual. See Attachment 3, Change 1.

84 2-26/35 Change "...we derive..." to "...are derived..." Grammatical

enhancement.

85 2-27/12 and 13 Sentence does not read correctly. Revise to read: "The authors presented a

conceptual model to illustrate the links between

these activities and those for recovery and

restoration anid of Midwestern river fish

communities."

Basis for Change: Grammatical correction

86 2-28/Figure 2.2.5-1 It is not clear what this figure is trying to communicate. Recommend

clarification or deletion.

87 2-29/22-23 Appears the terms "lentic" and "lotic" are interchanged. The reservoirs Revise to read: "The reservoirs have changed

would cause lentic flow, not lotic. letieloti.c (i.e., pertaining to flowing or running

water) habitat into letielentic (i.e., pertaining to still

or standing water) habitat..."

Basis for Change: Merriam-Webster Dictionary.

88 2-29/23 Insert comma after "i.e." Grammatical correction.

89 2-29/30 "Draught" should be "drought." Revise to read: "...as fire, draughtdrouaht,

flooding,..."

Basis for Change: Spelling correction

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~Cmmelt, ;-age Ntmbe~ ~ ~ Comment ~ ution~* 

90 2-33/2 The upstream reservoir produces a lentic environment, not a lotic Revise to read: "...be largely determined by

environment. upstream reservoirs, where the lotiG lentic

environment

Basis for Change: Merriam-Webster Dictionary.

91 2-34/23 "Louis" should be "Lewis." Revise to read: "...included the upstream hLeuis

Lewis and Clark..."

Basis for Change: Grammatical correction

92 2-35/12 "USACE 2003" is not listed in the Section 2.4 references. Add reference

to "USACE 2003" to Section 2.4.

93 2-35/26 Sentence reads awkwardly. Revise to read: "Within the main channel..."

Basis for Change: Grammatical correction

94 2-36/4 Insert "are" between "fish near." Grammatical correction.

95 2-36/24 The site acreage differs from the number provided on Page 2-1, line 8. Revise to read: "According to the ER, the CNS-1

facilities are located within 55 acres (22 ha) of a

1,121-0-acre (454 ha) site in Nemaha County,..."

Basis for Change: Consistency change

96 2-36/31 The statement "...cropland on north, south, and east sides..." is not Revise to read: "The CNS property in Missouri is

correct. adjacent to the eastern bank of the Missouri Rive,

and is bordered by cropland on its ieFt-, seu.h.

aPd-east and timberland on its north and south

sides (Figure 2.2.1-1) (NPPD, 2008)."

Basis for Change: ER Figure 2.2.1-1

July 2010 A.1-19 NUREG-1437, Supplement 41 I
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An incorrect number of acres is devoted to agricultural acres on the Revise to read: "On the Nebraska side of the

Nebraska side of CNS site. CNS-1 site, approximately 9GQ715 acres (364

289 ha) are currently used..."

Basis of Change: CNS ER Section 2.1

This line states "...a 55-acre (22ha) wetland mitigation site." The site Revise to read: "...and, according to NPPD staff,

does not have a 55-acre wetland mitigation site. It has an approximately a 55-acre (22 ha) wetland area, which includes an

1.5-acre wetland mitigation site on a 55-acre parcel of ground. approximately 1.5-acre mitigation site."

Basis for Change: Letter from L. Peterson

(USACE) to B. Shanks (NPPD), July 6,1995.

There is an improper attribution to the License Renewal Application ER

for 40-acre agricultural activity use on the Missouri side of NPPD

property. Delete/relocate "NPPD, 2008" reference.

The greater prairie chicken is not commonly found in the vicinity of CNS.

Recommend that "greater prairie chicken" be deleted, as it is not

indigenous.

"(Bubo virginianus)" should be in italics.

Incorrect number of bird deaths. Revise to read: "...horned owl (Bubo virginianus),

three a number of additional birds, and the

death..."

Basis of Change: ER Page 2-52 cites more than

three bird deaths.

Incorrect spelling of Blue sucker scientific name. Revise Blue sucker entry to read: "Cycleptus

elongateus."

Basis of Change: NatureServe- "Blue sucker."

I NUREG-1437, Supplement 41 A. 1-20 July 2010
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comment ~Page.Numbe' Comment &~ S.'ete Reolut

'Line Nu'mnber ~4

104 2-40/Table 2.2.7-1 The scientific name of the pallid sturgeon is listed as "Scaphirhyncus Revise Table 2.2.7-1 entry to read:

albus." Page 2-48/5 calls the pallid sturgeon "Scaphirhynchus albus" "Scaphirhynchus albus." (emphasis added). Basis for Change: NatureServe- "Pallid sturgeon.1

105 2-41/Table 2.2.7-1 Incorrect spelling of "Western ribbonsnake" (needs space between Revise entry to read: "Western ribbon-snake." "ribbon" and "snake").

Basis of Change: NatureServe- "Western ribbon

snake."

106 2-41/Table 2.2.7-1 Incorrect spelling of Whooping crane scientific name. Revise Whooping crane entry to read: "Grus

Americana."

Basis of Change: NatureServe- "Whooping

crane."

107 2-41/Table 2.2.7-1 Need to include the "Bald Eagle" since it is listed as threatened in

Nebraska and endangered in Missouri.

108 2-43/Table 2.2.7-1 Incorrect spelling of Salt Creek tiger beetle scientific name. Revise Salt Creek tiger beetle entry to read:

"Cincindela nevadica lincolnaina."

Basis of Change: NatureServe- "Salt Creek tiger

beetle."

109 2-43/Table 2.2.7-1 Per reference MDC, 2009c, the American burying beetle should be listed

as possibly extirpated as other items are also listed as such.

110 2-43/Table 2.2.7-1 Incorrect spelling of Thimbleweed scientific name. Revise Thimbleweed entry to read: "Anemone

cylindrical."

Basis of Change: NatureServe- "Thimbleweed."

111 2-43/Table 2.2.7-1 "Harry Woodmint" should be "Harry woodmint." Revise entry to read: "Harry Wwoodmint."

Basis of Change: Typographical correction.

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,Cm mebt ' .iige - Nurnber/

112 2-44/Table 2.2.7-1

C~omment~ ., ese Re~souto

For Buffalo grass, there should be a Habitat description beyond

"Possibly extirpated" for consistency with other flora and fauna that are

statused as possibly extirpated.

The State Status for Toothed ticktrefoil, Glades gayfeather, and Twisted

ladies'-tresses are "S1?" or "S2?" It is unclear what the '?" signifies.

The State Status for Bush's sedge, Frank's sedge, Plains frostweed, and

Maryland senna are "S1S2." It is unclear what this classification

signifies.

"Gastrophe olivacea" (Great Plains narrowmouth toad) should in the

amphibian section rather than the plant section of the table.

"Seaside Heliotrope" should have a lower case "h." Revise to read: "Seaside Nheliotrope."

Basis for Change: NatureServe - "Seaside

heliotrope."

For hairy creeping lovegrass, it should be noted in the Habitat column

that it is possibly extirpated.

The common name for "Nothocalais cuspidate" is "Prairie false Revise to read: "Prairie false dandelion."

dandelion."

Basis for Change: NatureServe - "Prairie false

dandelion."

"Locoweed" is not a single species of plant. "Oxytropis lambertii var. Revise to read: "L-eGeweedStemless point vetch."

lambertii" corresponds to "Stemless point vetch."

Basis for Change: NatureServe - "Stemless point

vetch."

"Panax quinquefolium" should be "Panax quinquefolius." Revise to read: "Panax quinquefoliusis."

Basis for Change: NatureServe - "American

ginseng."

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Com~Conment Sugstd Resolbr~ ~~<~~'.~ 

9ution' j,~ 0;;e IuLe r ;t

121 2-46/Table 2.2.7-1 "Pediomelum argophylltum" should be "Silvery scurtpea." Revise to read. "Silvery psovlea scurpoea."

Basis for Change: NatureServe - "Silvery

scurfpea."

122 2-48/15 "(Iowa Administrative Code, Chapter 77)" is not included in the Section

2.4 references.

123 2-48/46 Regarding the pallid sturgeon, the statement "The populations are Revise to read: "The populations are believed to

largely older fish that will die off in the near future" is too definitive, be mostly tafgely-older fish that may wil-die off in

the foreseeable Rear-future."

Basis for Change: Clarification

124 2-50/17 Insert comma after "chlordane." "Chlordane" and "DDT" are two different

chemicals.

125 250/36 Delete "had." Grammatical enhancement.

126 2-51/8 Change "200b" to "2003b." Referencing correction.

127 2-51/16 Incorrect scientific name for piping plover. Revise to read: "...piping plover (Charadrius

melodius), and the ... "

Basis for Change: NatureServe - "Piping plover."

128 2-51/37 Delete "but" following the comma. Grammatical enhancement.

129 2-51/38-43 These lines should be deleted. The critical habitat for plovers in

Nebraska was vacated and remanded for new designation but that has

not occurred yet. This discussion is no longer accurate as the USFWS

designation of critical habitat has been overturned.

Reference: Case: 4:03-cv-03059-LES-DLP Document #: 53 Date Filed:

10/13/2005, Case: 4:03-cv-03059-LES-DLP Document #: 54 Date Filed:

10/13/2005

July 2010 A. 1-23 NUREG-1437, Supplement 41 I
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~.Comment" 'S S.ugg6steO`Rq'*q qtion,

2-52/4 and 9 Change "NGPC 2009a" to "NGCP 2009b" to correlate with the Section

2.4 references.

2-52/13 and 16 Delete the space between "NYS DEC" to be shown as "NYSDEC" for

consistency with Section 2.4 references.

2-52/27 Delete the space between "MN DNR" to be shown as "MNDNR."

2-52/46 The whooping crane population discussion is no longer accurate, as the Revise to read: "There are currently three-two

experimental population of whooping cranes in Idaho is extinct, populations of whooping cranes totaling less than

400 adult and juvenile birds, including one wild

population and two one experimental,

nonessential populations.

Basis for Change:

http://www.whoopingcrane.com/FLOCKSTATUS.

HTM

2-52/35, 38, 41 Change "(NGPC, 2009b)" to "(NGPC, 2009a)" to correlate with the

Section 2.4 reference.

2-53/7-8 The experimental population of whooping cranes in Idaho is extinct. Revise to read: "Ono of th• t-o oxporimontaI

populations broods in Idaho and ov;c,-intcrc in

I The seGend experimental population

breeds in Wisconsin and overwinters in Florida

and several other southeastern States

(NatureServe, 2008a)."

Basis for Change:

http://www.whoopingcrane.com/FLOCKSTATUS.

HTM

2-53/13 Recommend that the word "significant" be deleted since it implies that

there are large populations, which is not the case.

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No m •'OPage6humber) •Mment`. "Co` `.-- i4SUgested:Resolutionp'..

137 2-53/26 The statement that "...collisions with transmission lines are the main Revise to read: "The USFWS has indicated that

4-42/44-45 cause of whooping crane mortality during their migrations" should be collisions with transmission lines are the main

clarified that these are the main known cause of mortality, known cause of whooping crane mortality during

their migrations "..

Basis for Change: It is not known what the main

reason is for loss of whooping crane numbers

during migratory transit. Therefore, it is

appropriate to characterize transmission line

collisions as a "known" cause.

138 2-58/1-2 Section 2.4 contains no reference "(NDED and NPPD, 2008a)."

2-59/4

139 2-59/Table 2.2.8.2-1 "City of Nebraska" should be "City of Nebraska City."

140 2-59/10 There is no "(NDE, 2008)" listed in the Section 2.4 references.

141 2-62/44 There has been no indication that noise levels at CNS have exceeded Revise to read: "The EPA uses H"w...., neico

2-63/1-2 the 55 dBA threshold noise level. levels . may .m.times . Xc..d the 55 dBA level

that the EPA uccs as a threshold level to protect

against excess noise during outdoor activities

(EPA, 1974)."

Basis for Change: There is no data that noise

levels at CNS have exceeded the 55 dBA noise

level.

142 2-63/Table 2.2.8.5-1 In title "2006" should be "2007."

143 2-63/Table 2.2.8.5-1 Footnote: Reference "(USCB, 2009)" does not exist in Section 2.4.

Reference "University of Nebraska-Lincoln, Nebraska Population

Projections (2008)" does not exist in Section 2.4.

144 2-64/Table 2.2.8.5-2 The race percentages do not add up to 100%.

2-65/Table 2.2.8.5-3

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Comment- Peubr'' &Commn~' -N: ~

'LirinwNfiffber.-'. V

145 2-65/Table 2.2.8.5-3 If some other race category has been eliminated from the Census

estimate, why is it being included in the table? Consider eliminating the

category of "Other Race."

It is not clear what the nexus is between NPPD's charter to provide Revise to read: "NPPD!s would continue Ghe~eFie

electricity to it's customers in Nebraska, and that payments would to be responsible for prov.do oelcticity to

continue regardless of the operation of CNS. cuctomorB throughout tho Statc, these payments

would- ntin- regardless of whether or not the

CNS-4-is operating."

Basis for Change: Clarification

The numbers provided for "Nebraska in Lieu of Taxes to Counties With

NPPD Retail Electric Sales Attributed to the CNS-1," "Payments to Retail

Communities Attributed to CNS-1," and the Total values do not match

what was provided in ER Table 2.7-1. Recommend revision to conform

with ER information.

Reference "NPPD, 2008b" is incorrect. Change "NPPD, 2008b" to

"NPPD, 2008" to correlate with the reference in Section 2.4.

Delete random ")" following "population."

The reference "50 CFR Part 22" is not referenced in the Section 2.0

discussion.

Hesse, LW., [et all. 1982a is not referenced in the Section 2.0

discussion.

Missouri Conservation Department 2009 is not referenced in the Section

2.0 discussion.

MDC 2009d" is not referenced in the Section 2.0 discussion.

NRCS. 2000" is not referenced in the Section 2.0 discussion.

Change "2004a" to "2004" to correlate with the reference listing in the

Section 2.0 discussion.

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& ,•( - -"fl'. b l',(.. 2i.. • " •j" .... • ' ... .. . . * . ... . . . ......... . .... b& " ,.C& » 4...... <Nb- <'.9..,•,••'> z S '-t,a t, j• t.-.!> • * ,&9 -..' ," .V-• .

Comme~nt 'Page Numberl i. . .~f !<Cmit. :,* '''KSuggest RitOI,

156 2-82/12 Change "2005a" to "2005" to correlate with the reference listing in the

Section 2.0 discussion.

157 2-82/24-26 NPPD 2007c is not referenced in the Section 2.0 discussion.

158 2-82/35-37 NPPD 2008d is not referenced in the Section 2.0 discussion.

159 2-82/42-43 NPPD 2009b is not referenced in the Section 2.0 discussion.

160 2-83/9 Insert "2009a" after "(NGPC)" to correlate with the reference listing in the

Section 2.0 discussion.

161 2-84/27-30 USCB 2009b is not referenced in the Section 2.0 discussion.

162 2-85/34-37 USFWS 2008c is not referenced in the Section 2.0 discussion.

163 2-86/5 and 6 USFWS 2009d is not referenced in the Section 2.0 discussion.

164 2-86/7-11 USFWS 2009e is not referenced in the Section 2.0 discussion.

165 2-86/12-15 USFWS 2009f is not referenced in the Section 2.0 discussion.

166 3-4/3-5 Need to separate 10 CFR 54 as a stand alone reference.

167 3-4/10-12 NRC 1999 is not referenced in the Section 3.0 discussion.

168 4-1/14 For consistency, "10 CFR Part 51" should be listed in the Section 4.12

references.

169 4-2/13 Insert a "period" after "(gpm)."

170 4-5/22 Delete "the" before "Section 316(a)." Grammatical enhancement.

171 4-5/15 and 16 Delete the duplicated phrase "...for minimizing adverse environmental

impact."

172 4-5/35 On line 35, the NRC appears to be calculating a fish impingement value

for the year 1974, not 1978. Please verify.

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Commen

I

Sugspe'Rsluin

Recommend the use of the word "reasonable" over "useful."

+

The Staff indicates that NPPD has committed to change out the fish

screens during the 2011 refueling outage, as opposed to the more

general characterization of during the initial operating term. This should

be clarified to be consistent with the discussion suggested in Attachment

2 for Page 2-13/Lines 26-31.

Revise to read: "CNS-1 has not yet completed the

fish protection system. and plar- to install, during

* 2011 rofuling outage, The intention is to install

a fish handling and return system to mitigate fish

impingement cOcnicting of incidc and ut-tcido

.p.a.. O ,wash fish fr. the ,PrPonna anda

coparato fish rotuFr trough (INPPID, 2008, pgc 4

1 1 l id p i ti [ u 1.:.j.... .

rsuppi'; wator for tho cpra'; Wash The now

6croonc, firsh handling system, and fich Fou8

trOUgh primnarily affoct imnpingomn8t but notfinal design of the fish handling system are

dependent upon the content of the final 316(b)

Clean Water Act requirements."

Basis for Change: Clarification. See Attachment

3, Changes 2, 4, 5, 6, 7, 8, 9, 10, and 11.

I

175 4-6/39 The "(EPA, 2009)" reference should be changed to "(EPA, 2009b)"

based on the Section 4.12 references.

176 4-7/1-6 The NRC states the following:

"The NRC staff examined the question of how the age of the data might

affect the conclusions regarding entrainment and impingement at

CNS-1. The NRC staff found that the argument used in the NPPD's ER

is inconsistent because it assumed at different points that the aquatic

resources are both stable and unstable, although in fact they cannot be

both. In describing the aquatic resources, the ER stated that fish

communities have long been responding to changes in the river brought

on by man's activities."

These statements should be deleted. The CNS ER does not present an

argument that aquatic species are stable or unstable. NPPD's evaluation

of the aquatic resources in the vicinity of CNS did not assume or

conclude that the aquatic resources were stable. In fact, the available

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chane hav s ea o, -Tstudies of Missouri River communities indicate little historic information

is available related to the aquatic communities in the Missouri River prior

to its damming and channelization. There have, however, been

numerous studies that conclude alterations of the river flows and

channel may have had significant impact on the communities that may

have once existed. NPPD's ER made several statements that some

species may be in decline while others may be aggressively and

invasively increasing (e.g., Asian carp). NPPD's ER discusses at length

the anthropogenic factors that have and continue to affect the aquatic

resources. These anthropogenic factors, however, are unrelated to the

operation of CNS or other power plants on the Missouri River.

177 4-7/30 and 31 The "EPA (2009)" reference should be changed to "EPA (2009b)" based

on the Section 4.12 references.

178 4-7/45 The "(Berry et al.)" reference is not listed in the Section 4.12 references.

179 4-8/15-16 Delete extra closing parentheses in two locations.

180 4-8/38-40 NPPD's plans for installing a fish handling system should indicate that Revise to read: "...and NPPD plans to install a the final design is dependent on the content of the final 316(b) fish handling and return system consistring ofregulations. inido and outsido .p.ays to wa. h fish from the

Scroons an a coaaoFic turn trough tom.itigato ada...r. o off.t. of impingm..t whose

final design is dependent upon the content of the

final 316(b) Clean Water Act requirements,"..

Basis for Change: Clarification. See Attachment

3, Changes 2, 4, 5, 6, 7, 8, 9, 10, and 11.

181 4-8/40 Replace "NDEC" with "NDEQ."

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S~~~ si~ugg *so,'uti.

The design of the fish handling system is contingent on content of the

final 316(b) regulations.

Revise to read: "Whatever the total effects of

CNS-1 on the fish community were in the past,

the installation of the modified dual-flow traveling

screens in 2006 and future installation of a fish

handling and return systemlow prccsure scrGon

wash and fish rctum trough (dependent upon the

final design and implementation of the final

316(b) Clean Water Act reauirements) would

mitigate those impacts....

Basis for Change: Clarification. See Attachment

3, Changes 2, 4, 5, 6, 7, 8, 9, 10, and 11.

183 4-1 I/Table 4-4 Table 4-4 is not in the Table of Contents.

184 4-12/10 and 17 As noted in Section 2.0, the number of acres owned by NPPD on the

Missouri side of the river is 239 acres, not 230 acres. This entire parcel

was offered for a conservation easement. The acreage values should be

revised.

185 4-12/21 and 22 The conservation agreement discussions should be updated. Revise to read: "At the tim5 Of riti*ng thi ,SEIS

The deed restriction for conservation has been

placed upon the 239 acres that NPPD owns on

the Missouri side of the river, and the MOU

including conditions regarding the additional

payment of $250,000, has been finalized and

signed by the parties involved particc aro

discussing dtailcs of the co.nsor-•Rti

Basis for Change: Status update

186 4-12/31 The "Hrabik et al. (2007)" reference is not listed in the Section 4.12

references.

187 4-13/3 Change "section" to "Section." Grammatical correction.

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-Commet ;

188 4-13/25-33 It is not necessary for the NRC to solicit a commitment for NPPD to Revise to read: "The staff roq'u-sts that NPPD

report the existence of endangered or threatened species via the draft repert the oAGWoGnco of any Federally listed or

SEIS. Reporting is conducted in accordance with State and Federal State listed cndango..d Or thmroatnod s... pc

regulations. ,.,ithin the CNS 1 Site Go r the tra.nsm.ision• n,,,

corr*d•or to NGPC, ID, aRd the UStWS, if ny

sucih specis are identified duryig the license

mrnwal ter. in addition, the NPPD is required

promptly rrepet to the apprepriate wildlife

anaragement agniovine and to NRC, any qvidere Of injur; to, Or mor~tality of, mi 'grater,' bFird Or

thrpecietnd r ndangroted ctpeios 2bsc07d

wisthin the tranmi E i nae 4orridor, espctio4.

uinuey to, Or moetality of, Federally listed whheapin

cranor, intedir least toeFW, and piping plovers aleng the Plallo Rivr Anoar the weste#rn limit of

ins1transmissdivor le ntsPPiD T13502, near

G randd Isl-;and, NE. All of NPPID operations.

including these necessary for transmission line

maintenance and operation, are conducted in

accordance with NPPD policies and procedures

that require special precautions related to_

operations involving threatened and endangered species and avian protection I`NPPD 2007aL

NPPD 2007b1."

Basis for Change: ER Page 4-47, Section 4.10.5

189 4-13/40-41 The status of the bird diverters should be updated. Revise to read: "Th4e-NPPD is aIee has

coordinatedjo with USFWS staff and has tGinstalled bird diverters on transmission line NPPD~

TL3502 where it traverses the Platte River."

Basis for Change: Status update.

190 4-15/32 Insert space after "0.0031."

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*'*,z Sugse Reso ut on.,ý... %

The verbiage needs to be revised to more accurately reflect the

applicability of the issue since CNS is not a closed-cycle plant.

Revise to read: "The effects of thermophilic

microbiological organisms on human health, listed

in Table B-1 of Appendix to Subpart A of

10 CFR Part 51, are categorized as a Category 2

issue and require plant-specific evaluation during

license renewal process for the plants located on

t-he a small river, that use clcosd cycle cooling."

Basis for Change: 10 CFR 51.53(c)(3)(ii)(G)

"3.15x1012 ft3/year (9x1010 m3/year)" should be revised as follows:

"3.15x1012 ft3 /year (9xl 010 m3/year)"

Recommend that NRC confirm the subject matter of Table 4-7, as it

appears to be nearly identical to Table 4.6. Should Table 4-7 cover

Category 2 socioeconomic issues?

Delete the period following "proximity."

Add a space after the comma as follows "...history, (2)..."

Extra "(" at end of the line.

There is no "pending research" anticipated for historic archeological sites Revise to read: "All surface structures associated

in the vicinity of CNS. with the earlier house sites have been

demolished; however, remnants of these

buildings remain as historic archaeological sites

and could be eligible for inclusion to the NRHP

under Criteria A and D pn4ding futher .... a..h."

Basis for Change: Clarification

The "(Gibbon and Ames, 1998)" reference is not listed in the Section

4.12 references.

The "(NSHS, 1937)" reference is not listed in the Section 4.12

references.

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V S 'ggested :R~solt!6

NPPD has procedural administrative controls in place to ensure that

cultural resource reviews are conducted prior to engaging in construction

or operational activities in previously undisturbed areas that may result

in a potential impact to cultural resources at the site [NPPD, 2007c].

Areas depicted in Phase 1A Literature Review and Archeological

Sensitivity Assessment were identified as higher probability

archeological site areas on the CNS Owner Controlled Area. However,

NPPD has developed a Cultural Resources Protection Plan in an effort

to meet state and federal expectations and includes measures for

archeological investigations (Phase 1 B) and consultations with the

Nebraska and Missouri State Historic Preservation Offices (SHPO), and

the appropriate Native American groups prior to any future ground

disturbing activities [CNS, 2008]. These measures provide adequate

protection for potential area cultural resources.

Revise to read: "NPPD could furt4hor roducc&

potental Fmpacts Wo nisteri andi aFRcaeooogical roo ecs g-'-t-d at th GN •e 1, by t;ai.i g NPP

staff in tho SoctiOn 106 cOnsultation process and

cu ltu ral awaronoss tra'inig to onsuro thatinformed deciSions aFo made pricr to any grcur'd.

disturbing actiViticS. In addition, NPPD raould alst

forwvard its Cultural Resourcoc Protection Plan tothe NSHS and the M!ssouri SHPO for review and commont. Thc iN0ll -nsuro tha't hi4ctrIc and

archacological roco)urcos arc protoctod at the

CNS 1 Gite. Any ro"isions to tho C-ultural

Rosourccs Protoction Plan shoul-d bo dc'-cpcd in Rconcultation with the NRC, NSHS, and MiGssou11

SH1-12. In addition, lands not supvoyed should be

aiRvcstigated by a qualified archacolOgict prior to

any ground disturbing act.. NPPD should

continue to fulfill all site, state, federal, and NEP.A

requirements regarding future land disturbances

on-site."

Basis for Change: It is not necessary for the

DSEIS to make recommendations on actions

NPPD could take to further reduce the SMALL

impacts on historic and archaeological resources

at CNS.

201 4-26/16 The "(USCB, 2009)" reference is not listed in the Section 4.12

references.

202 4-26/17 There is a big space at the end of this line that should be filled with text -

check the carriage return.

203 4-27/3 The "(USCB, 2008)" reference is not listed in the Section 4.12

4-28/3 references.

4-29/7

4-30/3

4-31/3

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LieNubr t. ~ ý u'ggested. ' Rdsolutiion

204 4-29/11 The "(USCB, 2009)" reference is not listed in the Section 4.12

references.

4-33/14 Change "Thorium" to "Naturally occurring thorium" to indicate that it's not Revise to read: "Naturally occurring Thorium-228

plant-related. was measured in one sample."

Basis for Change: Clarification

4-33/23 Sentence does not read correctly. Revise to read: "There were 26 broadleaf

vegetation samples were-collected from June

through September.."

Basis for Change: Grammatical correction

4-33/37 Change "10 CFR Part 72" to "10 CFR Part 50" since CNS has not yet Revise to read: "The REMP continues to

implemented a General License under Part 72. demonstrate that the dose to a member of the

public from the operation of CNS-4 remains

significantly below the Federally required dose

limits specified in 10 CFR Part 20,

10 CFR Part 507-2, and 40 CFR Part 190."

Basis for Change: CNS has a Part 50 license, but

not a General License under Part 72.

4-33/39 "Soils" are not monitored. Revise to read: "Based on recent monitoring

results, concentrations of contaminants in native

leafy vegetation, seils-and sediments, surface

water, and fish in areas surrounding CNS-1 have

been quite low (at or near the threshold of

detection) and seldom above background levels."

Basis for Change: CNS Offsite Dose Assessment

Manual

4-34/18 The "(NRC, 2000)" reference is not listed in the Section 4.12 references.

4-36/3 The "(USGCRP, 2009)" reference is not listed in the Section 4.12

4-44/21 references.

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Comment,-PageNumbed b Res,..f,. i

,No.', ~Line Numberrý *..~<''~~.

211 4-36/5 "(14 'C)" should be "(3.3°C)."

"(12 'C)" should be "(5.6°C)."

212 4-37\36-39 This section states:

"The impact of introduction and stocking of native and introduced fish

species is also somewhat similar to the impact of CNS-1, because the

effect of a power plant that impinges and entrains aquatic organisms is

somewhat similar to that of a large predator introduced into an aquatic

system."

This appears to be subjective and is not substantiated. Recommend

deletion.

213 4-38/1 Recommend clarification as to which states are being referred to.

214 4-38/4 The "Nelson-Stastny (2004)" reference is not listed in the Section 4.12

4-40/Table 4-9 references.

215 4-38/22-25 The characterization of the Missouri River aquatic ecosystem being Revise to read: "While the level of impact due to

4-47/Table 4-10 potentially past the point of reparable change is not adequately justified. direct and indirect impacts of CNS-1 on aquatic

communities is SMALL, the cumulative impact

':fhAn cmbnoqd with of all other sources of impac

has resulted in the Missouri River aquatic

ecosystem being unstable and has resulted in a

largqe and G1o6o to, if not part, the poi~nt of

F~p~abe han.This conditioR n mots NSRC's

d.finiti.n of a LARGE level of impact."

Basis for Change: Clarification

216 4-40/Table 4-9 Why is this table titled "Stastny 2004?" No other tables have titles from

the reference name.

217 4-41/2, 13, and 20 The "(NGPC, 2005)" reference is not listed in the Section 4.12

references.

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"Comment -Page'Number!,11- C.-mn wSuggested Resolution4

-'~LineNumbe ... ,> UC

218 4-41/27-29 The acreages listed do not match the values provided in ER Section 2.1. Revise to read: "Approximately 900 acres (364

hectares) of the 1,1204-acre (4534 hectare)

CNS-1 site is used for agriculture (NPPD, 2008).

Much of the 5590-acres (2236 hectares) of land

where the CNS-1 facilities have been constructed

was cropland prior to construction of the facility,

so disturbance to wildlife habitat had occurred

prior to construction of CNS-1."

Basis for Change: CNS Environmental Report,

Section 2.1.

219 4-41134-36 The site does not have a 55-acre mitigation site, it has an approximately Revised to read: "NPPD was recently required by

1.5-acre mitigation site on 55-acre parcel of ground. the USACE to restore approximately 1.5 5,-acres

(._622 hectares) of disturbed wetlands habitat

eqrsite on a 55-acre (22-hectacre) parcel of

around as mitigation for NPPD filling in other

disturbed wetlands for construction of CNS-1

parking facilities.

Basis for Change: Letter from L. Peterson

(USACE) to B. Shanks (NPPD), July 6, 1995.

220 4-41/47 The "(NDNR, 2009)" reference is not listed in the Section 4.12

references.

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Commen~t Oag-Nm'brl ~Coimment .souto "Sciiete 

221 4-42/9-13 This discussion should be updated based on the recently reached Revised to read: "Baced upon discussions with

wetland agreement. NPRID staff during the enyv~romental site audit,

NPPD is currFotly coordinating with Fodoral and

State rosourGo agoncios to Placo thiS Mi6souri

l-and into -A Aoonc-R~atio-n easement, Which Mayload to long torm, protoction of this land from any

dovelepm nt as woll as remgyal of tho e0 acro0

Of Ecropland froem agricultural production. A

conservation deed restriction has been placed

upon the 239 acres of land located on the

Missouri side of the river to provide for long-term

protection of this land from any development as

well as agricultural production.

Basis for Change: Clarification

222 4-42/18 The "(NCRS), 2007" reference is not listed in the Section 4.12

references.

223 4-42/25 The "(NGPC, 2005)" reference is not listed in the Section 4.12

references.

224 4-43/3 "(NPPD, 2009)" appears to be an incorrect reference since it does not

correlate with the Section 4.12 NPPD references.

225 4-43/30-35 The NRC concluded that the cumulative impacts on terrestrial resources

would be MODERATE. However, the information presented in Section

4.11.4 makes it unclear how that conclusion was reached. Additional

justification should be provided.

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Comment f Page. Numrberi ýComment C S ut ~ ~ 47., ~ ~ .~~~'uggestedResoluton.

226 4-43/33-35 It is recommended that this section be revised for consistency with the Revise to read: "...however, th cu-m--UatiV-o

language utilized on Page 4-38 of the DSEIS regarding aquatic impacts., ,,pact On toFr•9otial rFeGoures r.sulting from . ll

31 Past, preconit, and roa6onably fGrocoabl

fu-turo -actions, including nonCGNIS 1 ac~tK.ifitics

while the level of impact due to direct and indirect

impacts of CNS on terrestrial communities is

SMALL, the cumulative impact when combined

with all other sources, even if CNS was excluded,

cwould be moderate."

Basis for Change: Clarification

227 4-43/35 Moderate should be in all capital letters.

228 4-44/1 Delete "the" before 34. Grammatical enhancement.

229 4-44/21 and 22 "(14 'C)" should be "(3.3°C)"

"(12 'C) should be "(5.6°C)"

230 4-44/34-38 This sentence appears to be out of place for this air quality discussion:

"As discussed in Nonradioactive Waste Management Section 2.1.3,

NPPD is committed to the EPA's Reduce, Reuse, Recycle program at its

major and minor facilities, with a growing Green Team, that focuses on

pollution prevention, waste minimization, education and training of the

personnel, and incorporates EPA recommendations on the national

implementation of the climate change energy conservation techniques

(EPA, 2009a)."

231 4-44/42-45 In Comment 73, a significant rewording was suggested for Section

4-45/1-10 2.2.2.1. If these changes are accepted by the NRC, conforming changes

to Page 4-44/42-45 and Page 4-45/1-10 are necessary.

232 4-44/45 Insert "(CO)" after carbon monoxide. Grammatical enhancement.

233 4-45/2 A cross-reference is made to Air Quality Impacts in Section 2.2.2.2. This

should be Section 2.2.2.1.

234 4-45/13. Delete the second "The staff concludes." It is repeated.

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Commet:,.- Ný 'uqcist6J-Resoi ution

It is not clear why a discussion of alternatives is made in this cumulative

impacts assessment. The National Environmental Protection Act

requires the cumulative impact conclusions be based on known and

foreseeable actions, not hypothetical alternatives. Recommend deletion.

4-46/13 and 14 NPPD has made no commitments to initiate further consultations with

the NRC and SHPO should plans change for future land-disturbing

activities. NPPD procedures stipulate when outside agency

consultations should be initiated. Accordingly, the statement: "Should

plans change, further consultation would be initiated by NPPD with the

NRC and SHPO." should be deleted.

It is unclear if the NRC is describing the potential cumulative impacts of

CNS operation alone, or the cumulative impacts of CNS operation

combined with other Federal or non-Federal actions (ref. Council on

Environmental Quality implementation of 40 CFR 1508.7).

If describing CNS operation alone, the text should be: "...resulting from

CNS-1 operation alone during the period of extended operation would be

SMALL. to MODERA\TE" based on the Staffs conclusions in Sections

4.1 through 4.9.

If describing CNS operation with other non-CNS actions, the text should

read: "... resulting from CNS-1 operation combined with these other

actions during the period of extended operation would be SMALL to

,M, QODRAEF, LARGE" due to the previous aquatic determination of a

LARGE impact in Section 4.11.3.

238 4-47/Table 4-10 It is unclear what NPPD's commitment to "the EPA's Reduce, Reuse,

Air Quality Recycle program at its major and minor facilities, with a growing Green

Team, that focuses on pollution prevention, waste minimization,

education and training of personnel..." relates to air quality. Recommend

deletion.

239 4-48/6 and 7 10 CFR Part 54 is not referenced in the Section 4.0 discussion.

240 4-48/8 and 9 36 CFR Part 60 is not referenced in the Section 4.0 discussion.

241 4-49/5-7 AEC 1972 is not referenced in the Section 4.0 discussion.

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Comment 'PageNumrber/> 'Comment

242 4-50/12-15 EPA 2009b is not referenced in the Section 4.0 discussion.

243 4-50/42-46 MDC 2009a is not referenced in the Section 4.0 discussion.

244 4-51/9-11 NEIHS 1999 is not referenced in the Section 4.0 discussion.

245 4-51/12 and 13 Change "2009a" to "2009" so that the reference will correlate with how

it's listed in the Section 4.0 discussion.

246 4-51/17-19 NDEQ 2008 is not referenced in the Section 4.0 discussion.

247 4-51/20 and 21 NDEQ 2009 is not referenced in the Section 4.0 discussion.

248 4-51/22-24 NIEHS 1999 is not referenced in the Section 4.0 discussion.

249 4-52/6-9 NPPD 2008a is not referenced in the Section 4.0 discussion.

250 4-52/10 and 11 NPPD 2008b is not referenced in the Section 4.0 discussion.

251 4-52/12-14 NPPD 2008c is not referenced in the Section 4.0 discussion.

252 4-53/16-20 NRC 1999 is not referenced in the Section 4.0 discussion.

253 4-54/8-10 USAEC 1973 is not referenced in the Section 4.0 discussion.

254 4-54/24-27 Delete the "USFWS 2009a" reference since it is already listed on Lines

20-23.

255 4-54/42-44 WHO 2007a is not referenced in the Section 4.0 discussion.

256 5-3/2 Replace verb "requires" with "require" to agree with subject,

"Regulations."

257 5-3/9 Incomplete sentence and misspelled word. Revise to read: "of severe accident mitigation

alternatives..."

Basis for Change: Grammatical correction

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Suggestedo

5-3/11-12 Incorrect corporate name. Revise to read: "...conducted by the Nebraska

Public Power DistrictNPPD Enorgy Company,

L"7 (NPPD)..."

Basis for Change: Correction

5-3/27-33 Section states, "NPPD identified 33 potential SAMAs for CNS-1. NPPD

performed an initial screening to determine if any SAMAs could be

eliminated because they are not applicable to CNS-1 due to design

differences, or have estimated implementation costs that would exceed

the dollar-value associated with completely eliminating all severe

accident risk at CNS-1. No SAMAs were eliminated based on this

screening, leaving all 33 for further evaluation."

Revise to read: "NPPD identified 33 244 potentia

SAMAs for CNS-1. NPPD performed an initial

screening to determine if any SAMAs could be

eliminated because they are not applicable to

CNS-1 due to design differences, ef because the,

have ostimated implormntation ccste that would

This is not consistent with the information provided in Section E.2 of the

ER, with the summary in DSEIS Section 5.3.3 (page 5-5), or with DSEIS

Appendix F (Section F.3.1, page F-13). In fact, 244 potential Severe

Accident Mitigation Alternatives (SAMA) were identified for CNS. The

dollar-value of completely eliminating severe accident risk was not used

in the screening phase, and 80 SAMAs were left for further evaluation.

complctol'; oliminating all co':oro accidcnt rick

already been implemented at CNS-1, or because

they are addressed by another SAMA candidate.

Ne 164 SAMAs were eliminated based on this

screening, leaving all 3 80 for further evaluation.

Basis for Change: Clarification

260 5-5/8-10 Section states, "Accordingly, the staff based its assessment of offsite Revise to read: "Accordingly, the staff based its

risk on the CDFs and offsite doses reported by NPPD in their December assessment of offsite risk on the CDFs and offsitE

2009 letter (NPPD, 2009b)." doses reported by NPPD in theif DecembBr 2009

lettei LRA Environmental Report (NPPD,

It appears that the Staff actually based its assessment of the offsite risk 200_89b)."

on the Core Damage Frequencies and offsite doses reported by NPPD

in the ER (NPPD, 2008). The December 2009 letter merely indicates Basis for Change: Clarification

that the ER results are conservative compared to the results that would

have been obtained using corrected meteorological data.

261 5-7/25-28 Section states, "NRC staff reviewed NPPD's re-analysis as submitted by

NPPD and agrees that the error was conservative relative to the average

population dose and offsite economic cost and that no SAMAs were

inappropriately excluded from consideration in the LRA as a result of the

error."

This paragraph is not clear as a stand-alone paragraph. Suggest

moving this paragraph to Section 5.3.2, page 5-4, following lines 11-17.

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CPaimei Pag Nu49l

ment PieN1ib I Campin .... . Sg dRsolution, p,.. 

262 5-8/4 Insert an open parenthesis "(" at the beginning of the line, prior to "e.g."

Also, recommend changing "e.g." to "i.e." since this statement appears

to be paraphrasing for clarity of meaning rather than providing an

example of managing the effects of aging.

263 5-8/14 and 15 10 CFR Part 100 is not referenced in the Section 5.0 discussion.

264 5-8/16-22 The NPPD 1993 (ML073600192 and ML073600193) references were

not found in ADAMS search.

265 5-8/30 NPPD 2009 reference should be ML091880319 (delete trailing 3).

266 5-8/40 and 41 Add, "September 2004" at the end of the reference for consistency with

same reference on page F-39 (line 25).

267 6-3/1 Change "lifecycle" to "life cycle."

6-4/2, 15, 16, 19, 26

and 28

6-5/9 and 15

268 6-3/24 "(Keepin, 1988; Hagen et al., 2001; and MIT, 2003)" are not listed in the

Section 6.3 references.

269 6-5/Table 6-2. The POST (2006) line of data contains an arrow after coal. There is

nothing like it elsewhere so it appears it should be deleted.

270 6-5/Table 6-2 "POST (2006)" is not listed in the Section 6.3 references.

6-6/Table 6-3

6-7/Table 6-4

271 6-9/8 and 9 10 CFR Part 63 is not referenced in the Section 6.0 discussion.

272 6-9/10-12 40 CFR Part 191 is not referenced in the Section 6.0 discussion.

273 7-2/24-26 NPPD 2008 is not referenced in the Section 7.0 discussion.

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Cofi~iiment .KigekNumbt&~ Vd T'* ~'ufi 

~ /&~~ ~ine Nme -''''~~

274 8-2/Box The "EIA 2009a" reference appears to be inaccurate based on the

Section 8.7 references. Based on Section 8.7, it appears that it should

be "EIA 2009."

275 8-4/8 There is no "(NPPD, 2008)" in the Section 8.7 references.

8-6/22 and 23

8-10/12 and 25

8-17/21

8-18/8, 38 and 39

8-19/8

8-23/18 and 21

8-24/39

8-31/5 and 27

8-35/4

276 8-4/20 and 21 Since the DSEIS had not previously discussed coal ash and scrubber Revise to read: "As ntcd above, much of tThe

sludge being recycled, the following sentence is incorrect: "As noted coal ash and scrubber sludge (about 38,300 tons

above, much of the coal ash and scrubber sludge (about 38,300 tons (34,800 MT)) could be recycled."

(34,800 MT)) could be recycled."

Basis for Change: Correction

277 8-4/40 Change "(EPA, 2008a)" to "(EPA, 2008)" to correlate with the Section

8.7 reference.

278 8-5/19-24 The Table of Acronyms identify "MT" as "metric tonnes." This section

spells it "metric tones." Recommend replacing with "MT." Grammatical

correction.

279 8-5/22-23 The numbers after PM should be subscript in two locations.

8-6/28

280 8-6/15 The citation "40 CFR 60.44Da(1)" should be "40 CFR 60.44Da(a)(1)."

281 8-6/24 Insert space after "SO2."

282 8-13/17 Change "driveshaft" to "drive shaft."

283 8-15/3 PM10 should be PM0o.

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Comrment. <Pfimn 'bl io

284 8-15/17 and 18 The statement that "there is no required reporting of GHG emissions in

Nebraska" is inaccurate. EPA finalized the mandatory reporting of

greenhouse gases rule which was effective January 1, 2010. This

sentence should be deleted.

285 8-16/16 Delete extra parentheses after "2 m 3

/s."

286 8-20/13 Large space at the end of line needs to be corrected.

287 Page 8-21/10-17 It does not appear to be reasonable to conclude that 250 MWe of CNS

baseload generation can be replaced by conservation. The Staff claims

that this is supported by the state's energy efficiency goals, but this does

not seem realistic. Request NRC verify and provide reference of the

source of the Nebraska energy efficiency goals.

288 8-21/14 Change "is" to "would be." Grammatical enhancement.

289 8-21/22 Change "will" to "would." Grammatical enhancement.

290 8-22/2 Delete the "s" after "require."

291 8-22/28 Insert ")" after Congress.

292 8-31/7 There is no "(Nucleonics Week, 2008)" in the Section 8.7 references.

293 8-32/4 There is no "(NREL, 2008)" in the Section 8.7 references.

294 8-32/23 There is no "(ORNL, 2007)" in the Section 8.7 references.

295 8-33/24 There is no "(Integrated Waste Services Association, 2007)" in the

Section 8.7 references.

296 8-40/4-6 ACAA, 2007 is not referenced in the Section 8.0 discussion.

297 8-40/34 Change "2000a" to "2000" to correlate with the reference listing in the

Section 8.0 discussion.

298 8-40/37 Change "2008a" to "2008" to correlate with the reference listing in the

Section 8.0 discussion.

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aaSuggeft49 Comment Page Number/Comment Sgese Resolution ~ No.

299 8-40/39 and 40 EPA 2009a is not referenced in the Section 8.0 discussion.

300 9-1/3 Incorrect corporate name for NPPD. Revise to read: "...Nebraska Public Power Distric.

(NPPD) Enargy Company, LL.''....

Basis for Change: Correction

301 9-1/25-30 The discussion states that the NRC staff has identified a variety of

measures to mitigate potential acute electromagnetic field (EMF)

impacts. The discussion of EMF impacts, however, does not indicate

the consideration Qf any such mitigation alternatives in this case.

Recommend deletion.

302 9-1/31-37 The discussion states that the NRC staff has identified a variety of

measures to mitigate potential impacts of thermophilic microbiological

organisms resulting from continued operation of CNS. These measures

are not enumerated in section 4.8.2 of the document, so it is unclear

where the NRC staff identified mitigation measures. Recommend

deletion.

303 11-1/33-37 It is unclear how regulatory agencies in Pennsylvania are related to

license renewal at CNS. Recommend deletion.

304 11-2/3 Unclear how the Susquehanna River Basin Commission is related to

license renewal at CNS. Recommend deletion.

305 F-1/5 Change "In December 7, 2009" to "On December 7, 2009." Grammatical

correction.

306 F-1/19 There is no "(NRC, 1998a)" in the Section F.8 references.

307 F-1/22 Change "...who addressed..." to "...that addressed..."

308 F-5/3 The "(8.9 x 10-5 per year)" value does not agree with the CDF value Revise to read: "...(8.90 x 10-5 per year)..."

reported in Section E.1.4 of the ER and in DSEIS Table F-3.

Basis for Change: Correction

309 F-7/23-27 Recommend providing a reference to "(NPPD 2009a)." 1

July 2010 A.1-45 NUREG-1437, Supplement 41
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CNS-Z

Page Number/ Comen SugseRslto

Line Number~ 4~~

F-10/44 through

F-1 1/2

Recommend providing a reference to "(NPPD 2009a)."

F-1 1/11-13 Recommend providing a reference to Measurement Uncertainty

Recapture power uprate approved by the NRC in 2008 (NPPD License

Amendment 231 ADAMS Accession Number ML081540280).

F-1 1/46 through Section states, "Year 2004 tourist information was used to estimate the Revise to read: 'Year 2005 tourist information

F-12/2 transient population for year 2005 (Global Insight, 2006; IDED, 2006; was used to estimate the transient population in

Kaylen, 2006; NDED, 2006)." Iowa, Missouri, and Nebraska (DED, 2006:

Kaylen, 2006; NDED, 2006). Year 2004 tourist

These references were used for the tourist information. Although this information was used to estimate the transient

information was not provided in the ER or the responses to Requests for population in Kansas for year 2005 (Global

Additional Information, it was included in the supporting Engineering Insight, 2006; IDED, 2006; Kaylon, 2006; NDED,

Report (CNS-RPT-07-PRA3). This report indicates that year 2004 2x06)."

tourist information was used for Kansas since 2005 data was not

available. However, 2005 data was used for the other states (Iowa, Basis for Change: Clarification

Missouri, and Nebraska).

Thus, the statement in the DSEIS is not accurate.

F-12/10 and 11 Add reference to the time estimate studies (listed on Page F-38/Lines

1-4) for the following sentence: "The evacuation speed and time were

based on the average values identified in the Missouri and Nebraska

time estimate studies."

F-12/2-14 Section states, "NPPD performed sensitivity analyses in which the

evacuation delay time was increased to 4.0 hours, and the evacuation

speed was decreased to 1.0 m/s. These sensitivity cases resulted in less

than 1 percent and 2 percent increases in the total population dose,

respectively."

Table E.1-15 of the ER provides the results of the sensitivity cases.

Comparison of the sums of the third and fourth columns with the sum of

the second column shows that both sensitivity cases resulted in less

than- 1% increase in the total population dose.

Thus, the statement in the DSEIS is not accurate.

Revise to read: "NPPD performed sensitivity

analyses in which the evacuation delay time was

increased to 4.0 hours, and the evacuation speed

was decreased to 1.0 m/s. Each of tT-hese

sensitivity cases resulted in less than a 1 percent

and 2peFeR increases in the total population

dose, .E.SPO.ti"el ."

Basis for Change: Correction

I NUREG-1437, Supplement 41 A. 1-46 July 2010
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Pacie 47 of 49

CNS-Z I

315 F-12/19-21 Section states, "In response, NPPD performed a sensitivity analysis that Revise to read: "In response, NPPD performed a

showed only a slight increase in population dose (less than 1 percent for sensitivity analysis that showed only a slight the late release) would result (NPPD, 2009a)." increase in population dose (less than 1 percent

total for the late roto8ce) would result (NPPD,

The RAI response letter (NPPD, 2009a) states, "If only 95 percent of the 2009a)."

population had been assumed to evacuate the EPZ, then the offsite

exposure risk would have been 2.15 person-rem/yr for the baseline Basis for Change: Correction

severe accident consequences."

This represents an increase of less than 11% for the total population

dose. Since the increase in total population dose, rather than "late

release" population dose was reported, suggest deleting "for the late

release."

316 F-21 through For consistency with the rest of the table, remove horizontal lines prior to

F-30/Table F-5 SAMAs 12, 26, 31, and 66.

317 F-24 and F-30/Table Details in modeling assumption for SAMA 78 are beyond the level of Revise to read: "Reduce failure of operator F-5 detail provided for other SAMAs. Suggest deleting, "to 5.OE-02 for actions to provide alternate injection via the fire

events FPS-XHE-FODFPAL and FPS-XHE-FO-RPVIN and to 9.5E-03 water system by a factor of two to 5.0E 02 for

for event FPS-XHE-FODISEL.(c)" and note (c). evAnts FPS XHE FO RPVIN and to 9.5E 03 for

avont FPS XHE= FO DISEL.(c.)"

Also, delete note (c).

Basis for Change: Level of detail consistency

318 F-28/Table F-5 Typo in modeling assumptions for SAMA 70; "drywall" should be

"drywell."

July 2010 A. 1-47 NUREG-1437, Supplement 41 1
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Paae 48 of 49

CNS-Z

CommN~mbdent Sugg.edesolution

"o. tLie Number

319 F-30/Note (a) Note (a) indicates that SAMAs in bold are potentially cost-beneficial, but

no SAMAs are bold. The following SAMAs are potentially cost-beneficial,

based on the CNS SAMA analysis:

SAMAs 14 and 25 on page F-23

SAMAs 78 and 33 on page F-24

SAMAs 30 and 68 on page F-25

SAMAs 40 and 45 on page F-26

SAMA 64 on page F-29

SAMAs 75 and 79 on page F-30

320 F-31/33-34 For each of the averted cost calculations, the text states, "For the Revise to read: "For thc pu'rpecc of initial

F-32/8-9 and 25-26 purposes of initial screening, which assumes elimination of all severe scrcnI..g, Which a-'-.moc• e•limination of all

F-33/8-9 accidents caused by internal events, NPPD calculated..." However, Gcavro accidaNc. caucod by .i.tcrnlal ev,-ntz,

NPPD did not use the value of eliminating all severe accidents in the NPPD calculated..."

initial screening task.

Basis for Change: Correction

321 F-32/31 and 32 Section states, "Repair and refurbishment costs are considered for Revise to read: "Repair and refurbishment costs

recoverable accidents only and not for severe accidents." Wording are c.n..dorod for roc....ablo ac.ido.t. only not

incorrectly suggests that repair and refurbishment costs are considered considered for severe accidents."

in the analysis.

Basis for Change: Clarification

322 F-33/28 and 29 Section states, "...also referred to as the Modified Maximum Averted Revise to read: "...external event severe accident

Cost Risk (MMACR)." This qualifying statement is not necessary since risk at CNS-1, a1rs roforrod to AM th- Modified

the ER and DSEIS do not use the term MMACR. Recommend deletion. Maximum Avo.t. d Cost Risk (MMACR)."

Basis for Change: Clarification

I NUREG-1437, Supplement 41 A. 1-48 July 2010
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CNS-Z I

No G; 8uggestediieiolution ' COmmn 'PgNumberI

323 F-35/36 and 37 Section states that the NRC "requested that NPPD reassess whether or

not SAMA 13 would be cost-beneficial if it were to use the same portable

generator as for SAMA 14, which was determined to be cost beneficial

(NRC, 2009). In response, NPPD stated that since the SAMA submittal,

SAMA 13 has been implemented at CNS-1 (NPPD, 2009a)."

As stated, it sounds like NPPD did not address the question. However,

in the RAI response, NPPD also stated that the available skid mounted

portable power supply considered in the cost estimate for SAMA 14 was not sufficient to supply the battery chargers as proposed in SAMA 13.

No DSEIS change needed.

324 F-38/1 and 2 Missouri State Emergency Management Agency (1991) is not

referenced in the Section F discussion. It appears to be related to Page

F-12/Lines 10 and 11.

325 F-38/3 and 4 Nebraska Civil Defense Agency (1993) is not referenced in the Section F

discussion.

326 F-38/21 Add "ADAMS Accession No. ML091880319" for consistency with same

reference on page 5-8 (line 30).

327 F-39/21-23 NRC 2002 is not referenced in the Section F discussion.

July 2010 A.1-49 NUREG-1437, Supplement 41

NLS2010037 CNS-Z

Attachment 2

Page 1 of 4

Attachment 2

Proposed Revision to Section 2.1.6 of the

Draft Generic Environmental Impact Statement Supplement 41

During the course of reviewing draft Supplement 41 to the Generic Environmental Impact

Statement, the Nebraska Public Power District identified an extensive number of comments for

Section 2.1.6, "Cooling and Auxiliary Water Systems." These comments included: a) the need

to incorporate Environmental Report changes from NLS2009036, b) the need to clarify the U.S.

Army Corps of Engineers Missouri River flow regulation, and c) to reorganize the paragraphs in

a more topical manner. As this section describes one of the key environmental interfaces of

Cooper Nuclear Station, an underline/strikeout version of this section has been generated for

the Nuclear Regulatory Commission's consideration.

2.1.6 Cooling and Auxiliary Water Systems

CNS4 lies on the western shore of the Missouri River, withdraws river water for its once

through cooling system, and discharges heated water back to the river. Unless otherwise cited,

NRC staff drew information about CNS4's cooling and auxiliary water systems from

NPPD(2006c) and the applicant's ER. Under the present flow regulation, a minimum Nebraska

City flow of 31,000 cfs (878 m3

/sec) is maintained for navigational purposes beginning in March

and extending through November. In • the i•ciity of the plant, the Mis.ouri River has a regulated

minim~um floW of 31,000 cubic foot per second (cfS) (878 cubic meters per Second (mn3/sec)) to

the southoa During the winter months, the winter flow in recent years has routinely been

maintained at approximately 6,000 cfs (170 m3

/sec) or greater. Since the establishment of

present flow regulation, the lowest flow at Nebraska City to date (16 year record) was 4,320 cfs

(122 m3/sec) in January 1957, which is also the minimum regulated flow by the U.S. Army Corps

of Engineers. [see Attachment 3, Change 1] Should a prolonged drought occur such that water

is not available to maintain the above required flows, the navigational season will be shortened

so that the minimum sanitary flows can always be maintained, if needed. The annual mean

river flow is 38,251 cfs (1,083 m3/sec)(1 930-2001) at the United States Geological Survey

(USGS) gauging station at Nebraska City, Nebraska, which is located approximately 30 river

miles north of CNS (NPPD 2008a).

The circulating water intake structure is located on the western shore of the river behind a guide

wall and submerged weir meant to reduce the amount of suspended sediment in the cooling

water. The weir attaches to shoreline structures north of the intake and then runs parallel to the

face of the intake at a distance of 14.25 feet (4.3 m). The wall continues past the intake and

ends approximately 40 feet (12 m) downstream of the downstream corner of the intake

structure. in a line ri.e..a.d of the weir wall and extending downstream of it, 23 sheet pile

vanes (10 ft wide by 6 ft high, 3 m wide by 2 mn high) oriented at a 22 degree angle to the weir

redirect sand and gravel outard from, the w..r and the Jntake s•.tructue•. After flowing generally

south alonRg the weir and vans ie ater must reverse co)urse and turn northwest to move

between the wo'r and shore and reach the intake bays. An array of 20 submerqed flow turning

vanes has been installed east of the guide wall in the river channel. Each vane is constructed of

steel sheet piling and driven into the river bed to a top elevation below barge navigation depth.

The vane array functions to induce scouring of the river bed adiacent to the guide wall to

prevent sediment accumulation. The prevention of sediment accumulations increases the

effectiveness of the guide wall. River water flows over the weir wall leaving heavier sediment on

the river side of the wall. Water velocity between the weir wall and the cooling water intake

structure is approximately abeut4 ft/sec (1.2 m/sec).

I

July 2010 A.2-1 NUREG-1437, Supplement 41
NLS2010037 CNS-Z

Attachment 2

Page 2 of 4

In w*Rt•r, about 25 to 30 pe"rcnt of mai;n c•RdRoensr dirharge wateFr r;rcu.lat-s thhrouh an ico

contF,! tunnel at the frot of the irtak-o strcutur and n d...hagei• OR n front of the tra•,h rack

prevent icng ater flows boncath a curtain wall at about 1 .1 ftsoc (0.3 mn/soc). Water onters

the five inaebays. fourF of which provide circulatingI wator and are 22 feet (6.7 mn) wide and ono

of which proVides SeorOco water and is 22.5 feot (6.8 mq) wide. The inominR!g water then flows

through t•-rh racks, 348 inch (1 .0 cm) Ve;tiGal bars separated 3 inchos (7.6 cm) On center, at up

to 0.7 ft'scc (20 cm/sec). Water for the facility is drawn through five intake bays. Four of these

bays provide circulating water to the generating unit while the other is used for service water.

Each circulating water intake bay splits into two screen bays, while the service water intake bay

narrows to a smaller screen bay. These bays are 9.7 feet (3 m) in length by 5.6 feet (1.7 m)

wide, providing space for 4.2 feet (1.3 m) wide dual flow screens. Each bay is fitted with

modified dual flow traveling screens designed with fish collection baskets. The modified dual

flow screens operate at 90 degrees to the water flow. Four circulating water pumps provide the

circulating water for the facility. Each pump can draw 159,000 qpm (10 m3

/sec). The pump

design water level is at El. 875.0 ft, with a minimum submergence level at El. 865.0 ft. There are

four service water pumps providing a combined flow of 32,000 qpm (2 m3

/sec). Velocities in the

intake structure are 1.1 ft/sec (0.3 m/sec) under the curtain wall, 0.7 ft/sec (20 cm/sec) at the

trash racks, and approximately 2.0 ft/sec (0.6 m/sec) at the traveling water screens. These

velocities were calculated at low water levels (El. 874.5 ft) and maximum circulating water pump

flow (159,000 qpm (10 m3

/sec) per pump). Fish and debris are currently collected on both the

ascending and descending sides of the dual-flow screen, which allows only filtered water to

pass downstream to the pumps. Fish and debris are removed by a hi-gh pressure screen wash

system and conveyed back to the river. Modified dual-flow traveling screens were installed in

2006 to address debris carry-over problems encountered with the original flow-through traveling

screens. (NPPD 2008a)

T-he ccGUlating water intake bays, each separate into tWO screen bays and the rbeRine wvater

intake bay narrows before water encounters the traveling srGeens, which are oriented atrightangleS to the flow. Water filters twice through nine 118 by 114 in. (.3 cmR by 1.3 cM) smooth top

mosn mRoGINiA- G1u1Ai HNow !raveling screens keigilt Tor cIrcUiat!ng water ana one Tor SoRýico water). ýThe uIpward Pass is in the ferot and the downward pass is behind the screens, that rotate

continuously at 8.2 ft'minR (2.5 Fn!min). The intake water Yelocit' at the srGeens is about 2 ftisec (0.6 ml~ec).

Each circulating water screen has 1/8 by 1/2 in. (0.3 cm by 1.3 cm) smooth top mesh. The

service water screen has 0.2-in. (5 mm) perforated plastic mesh. Each screen has a high and

low speed, but is normally rotated continuously at the slow 8.2 ft/min (2.5m/min) speed to

prevent excess debris build up. A high pressure screen backwash system providing 3,000 qpm

(0.19 m3 /sec) at 30-60 psig (207-414 kPa) is used to remove fish and debris from the screens.

Water for the screenwash is drawn from the service water pumps. Fish and debris flushed from

the screens are returned to the river via an 18 in. (0.46 m) steel pipe. This steel pipe discharges

downstream from the intake. The existing screen wash system does not have the capacity to

provide the required flow to support both a low pressure fish protection spray system and the

high pressure debris removal system nor is there a separate fish return trough and conveyance

system to return fish back to the river. (NPPD 2008a) Figure 2.1.6-1, Figure 2.1.6-2, and Figure

2.1.6-3 show the CNS intake structures. After the 4.2 ft (1.28 m) wide traveling screen paRnels

rotate over the Upper cog ard begi• mrYviRg dowR, a high p-resure (30 60 psig, 200 100 kPa)

screen wash of 3000 gallons per minute (gpm) (0.19 mn3!sec) supplied by the ser.'ice wate

PUMPS remo.ves fish and debris, whiGh return together to the river through an 18 in (0.1 m)

diameter steel pipe that dis;charges downstream. from the intake. Although the screens are fted

wfith fish baskets, the system has reither a low pressure spfay system tRo more gnrtly rem•ove

NUREG-1437, Supplement 41 A-2-2 July 2010
NLS2010037 CNS-Z

Attachment 2

Page 3 of 4

fish fromR the screens nor a fish return trough to conVey fish and other aquatic organismsG back to

the rivo. separately from. potentially dam.aging debri4s. Debris loads are approximately ab•eut-1 0

cubic yards per month (8 m3/month).

In winter, some of the main condenser discharge (about 25 to 30 percent) recirculates through

an ice control tunnel at the front of the intake structure and discharges in front of the trash rack

to prevent icing.

GNS41NPPD plans to install "dual flow conver.ion screen a fish handling and return systems to

mitigate the effects of impingement. "during its current operatiGnal term. This system will hae

loW preSsure (5 to 10 psi, 35 70 kPa) fish washing sprays On both the a.cending and

descendng s6c re.n... a fish return troug that .s separate trom the de-ri' trough. A r..OVo..

basket Will cillct fish and ether aquatic organisms washed from the s-ec•,4, and the fishtrough Will return them to the river. The final design and implementation of the fish handling

system are dependent upon the requirements of the final Phase 11 316(b) Clean Water Act

amended regulations. Figure 2.1.6 1, F=Ogue 2.1.6-2, aRd Figure 2.1.6 3 show the NCS 1 intake

et-uektI-e&. [See Attachment 3, Changes 2, 4, 5, 6, 7, 8, 9, 10, and 11]

After water passes through the traveling screens, the two screen bays of each intake bay rejOin

behind the screens. The four circulating water pumps, oRe per bay, dFraw water frm the bays

and provide up to 150,000 gpm (10 m3(0 se) each. The four seircu water puRps in the fifth bay

provide ad cmbired flew of 32,000 gpmn de3serw). (2 Water from the circulating water pumps

travels to and circulates through the condenser, where it cools steam from the turbines.

Because of the scouring from the suspended sediment, CiNo S f1ypialolig ad is not need

required to chlorinate the circulating water to control biological film fouling, although it has the

capacity to chlorinate or brominate if needed. NPPRD is studying the effectiveness of those

t.ks [See Attachment 3, Change 3] Water temperature increases approximately abeut

17.80F (101C) as it passes through the condenser tubes. From the condenser, circulating

cooling water fl.ws through concrete tunnels to a seal well structure and then to the dischargecanal, whore it travels about 1,000 foot (3, 0 m) to discharge to the river at a slight angle. Water

velocity at the discharge is about 1 ftis,, (0.3 in/see) at average river flow and about 5.6 ft'sec

(1.7 m/se6e) during low flows. The travel time fromn the intake structure to the dicharge is ahbo ut

20 minutes at high river flowv and 10 to 12 minutes at low flew. From the seal well and gate

control structure, the water is directed into a discharge canal that is approximately 1,000 ft (305

m) Iongq: it then enters the river at a slight an-gle. The velocity of discharge is about 1 fps (0.03

m3/sec) during average water levels of 879.4 ft and 35,000 cfs (991 m3

/sec ) river flow, and

increases to about 2.5 fps as the river water surface elevation is reduced to 874.5 ft and flows

near 11,000 cfs (311 m3/sec) which is the nominal control low maintained by the USACE below

the confluence of the Platte River. Travel times in the pump house-condenser-canal system will

be approximately 20 minutes at high flow and 10 to 12 minutes at lower river flows. Stone

rip-rap is used to prevent scours in the vicinity of the dischar-ge structure.

Cooling water flow demand varies with eleGtFeallead plant power and ambient river water

temperature. At full load during summer, the expected circulating water system flow is highest:

about 636,000 gpm (40 m3/sec). Lower circulating water flow is !ewe: required under ethef

lower river temperature conditions. In compari.on, the lowest river flow . at NS 1 is about 3,000

06. Un.der the worst conditions, the circulating water system flow would be about 7- percent of

Missouri River flow. Stone riprap at the discharge structure prevents the discharge from eroding

the river bottom. The annual mean river flow is 38,251 cfs (1,083 m3

/sec) (1930-2001) at the

United States Geological Survey (USGS) gauging station at Nebraska City, Nebraska,

apDroximatelv 30 river miles north of CNS (NPPD 2008a). The CNS maximum circulatina water

July 2010 A.2-3 NUREG-1437, Supplement 41
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Attachment 2

Page 4 of 4

withdrawal represents less than 4 percent of the average annual Missouri River flow. While the

percentage of river flow withdrawn by CNS may be higher during winter, the withdrawal is

significantly less than in summer, and occurs at a time when impacts due to entrainment of fish

eggs and larval fish are non-existent or minimal.

NUREG-1437, Supplement 41 A.2-4 July 2010
NLS2010037 CNS-Z

Attachment 3

Page 1 of 4

Attachment 3

Changes to the License Renewal Application Environmental Report

As a result of reviewing the draft Supplement 41 to the Generic Environmental Impact

Statement, the Nebraska Public Power District identified certain corrections/enhancements to

the License Renewal Application Environmental Report. They are presented in underline/

strikeout format.

(1) Page 2-10, 1t paragraph is revised to read:

"During the winter months, a minimum regulated flow of 3-OO 4,320 cfs is

maintained req'4fed at Nebraska City for sanitar- purposes; however, the actual

winter flow in recent years has been maintained at 6,000 cfs or more."

Reference: Correction based on USACE Master Manual.

(2) Page 3-4, second paragraph is revised to read:

"However, CNS is planning to augment its existing intake structure design with a

dual floW conversion G..e.. fish handling and return systems during the current

epe.atiE"ial tem,, to mitigate the effects of fish impingement. The system currently

Doing cOnsiacred 16 Mne tsrac~F Wreen LJIA Inc. 1=16R HaREHIig aGreeR wtn R i

AdVanced S.I.M.P.L.E. PrFce.s. This possible modificatien to the intake Structure

would in-vo,'V the installation of inside and eutsid. fish •p•ays which operate

between 5 10 psi and a separate fish return trough. AS raw water WOUld pass

through the exisi.ng fish baskets, floating and -usp-•n•d debris Ia•r9ge than the

mesh open•ig of the exiting dual flew screens would be retained e, the

upstream side of the m.esh and juvenile m.arine life would be captured in the hvdraulically stabilized fish rnever' basket. The recovered fish wo-ul-d then be

discharged on the desc~ending side with aid fromn the inside and outside fis

.spry. into a fish trough located above the debris trough. [Br1ackett The CNS

implementation date and the final design of the fish handling system are

dependent upon the content of the final 316(b) Clean Water Act requirements."

Reference: Clarification. It is expected that the final design will be at least as robust as currently

described.

(3) Page 3-4, last paragraph, Page 3-5, 1 st paragraph is revised to read:

"Chlorination is typically not required because of the inherent scouring action of

the sandy river water. However, a connection is provided for such a system in the

event should it's be found necessary potentially needed in the future. The

chlorination system connection is located on the common inlet to Screen Wash

Pump A and B from the service water system. [NPPD 2008, Section XI-6.3].

Bacteria that occur naturally in the Missouri River may contribute to the growth of

biological film fouling of the main condenser tubes. The .tation is pro.eeding With

a study to determine if r•oItine chemical injection (chlorine, bromine, etc.) Will be

effeG*iVe in eliminating the micro-biologiGal film On the inRterir walls of the

condenser tubes."

Reference: NPPD has completed the chlorination study and has determined that application of

up to twice per year can be effective in optimizing thermal performance.

July 2010 A.3-1 NUREG-1437, Supplement 41
NLS2010037 CNS-Z

Attachment 3

Page 2 of 4

(4) Page 4-10, 1st paragraph is revised to read:

"However as discussed in Section 3.2.2, CNS has already installed dual flow

conversion screens that are equipped with fish baskets and is planning on

installing a fish handling and return system to miti-gate the effects of fish

imPin.ementconsi.ti.g of insid. and outsid. fish sprays and a scparate fi.h

rotu.R trough pr'ir" to the nd of the .urr.nt operational ter•.m The CNS

implementation date and the final desiqn of the fish handling system are

dependent upon the content of the final 316(b) Clean Water Act requirements."

Reference: Clarification. It is expected that the final design will be at least as robust as currently

described.

(5) Page 4-11, 4th paragraph is revised to read:

"However, as discussed in Section 3.2.2, CNS is planning to install a fish

handling and return system to mitigate the effects of fish impinqementee'.i.ti..- -

of inside and outside fish sprays and separate fish rFturn trG•gh prior to the e•d

of the c'urrnt op9rational term. The CNS implementation date and the final

design of the fish handling system are dependent upon the content of the final

316(b) Clean Water Act requirements."

Reference: Clarification. It is expected that the final design will be at least as robust as currently

described.

(6) Page 4-21, 1t paragraph is revised to read:

"However as discussed in Section 3.2.2, CNS is planning to install a fish handling

and return system to mitigate the effects of fish impingementccnsisting of inside

and outside fish sprays and a separate fish return trough prier to the end ofth

GuF•,.t operational term. The CNS implementation date and the final design of

the fish handling system are dependent upon the content of the final 316(b)

Clean Water Act requirements."

Reference: Clarification. It is expected that the final design will be at least as robust as currently

described.

(7) Page 4-23, 1 st paragraph is revised to read:

"However as discussed in Section 3.2.2, CNS is planning to install a fish handling

and return system c.nsisting of inside and outside fish sprays and a separate

fi4h return trough prio• to the end of the urrent operatiGRal term,. This change to

the CWIS design would most likely be considered Best Technology Available for

minimizing impingement impacts. The CNS implementation date and the final

design of the fish handling system are dependent upon the content of the final

316(b) Clean Water Act reguirements."

Reference: Clarification. It is expected that the final design will be at least as robust as currently

described.

(8) Page 4-28, 4 th paragraph is revised to read:

"Although NDEQ had already determined that the cooling water intake impacts

were probably minimal at CNS, NPPD is planning to install a fish handling and

NUREG-1437, Supplement 41 A.3-2 July 2010
NLS2010037 CNS-Z

Attachment 3

Page 3 of 4

return system con.i*ting Of ifniidG and outside fish and ,praY. a separte fih

rctu.R trough during the currc.t operational t." m. This change to the existing

design of the CWIS (Ristroph screens) would most likely be considered Best

Technology Available for minimizing impingement impacts. The CNS

implementation date and the final desigqn of the fish handling system are

dependent upon the content of the final 316(b) Clean Water Act requirements."

Reference: Clarification. It is expected that the final design will be at least as robust as currently

described.

(9) Page 4-28, last paragraph, and 4-29, 1 st paragraph is revised to read:

"NPPD is planning to install a fish handling and return system at CNS, consisting

of inside and outside fish sprays and a separate fish return trough to the existing

design of the CWIS (Ristroph screens). This change to the CWIS would most

likely be considered Best Technology Available as it relates to minimizing

impingement impacts. The CNS implementation date and the final design of the

fish handlinq system are dependent upon the content of the final 316(b) Clean

Water Act requirements. In addition, even though current impingement impacts

are minimal, impacts during the license renewal period would be even smaller

due to this CWIS design change. Thereforeln summary, NPPD concludes the

impact due to impingement of fish and shellfish in the Missouri River is SMALL

and mitigation measures are not warranted."

Reference: Clarification. It is expected that the final design will be at least as robust as currently

described.

(10) Page 4-4-93, 3 rd paragraph is revised to read:

"NPPD is planning to install a fish handling and return system consisting of inside

and outside fish sprays and a separate fish return trough to the existing design of

the CWIS (Ristroph screens). This change to the CWIS would most likely be

considered Best Technology Available as it relates to minimizing impingement

impacts. The CNS implementation date and the final design of the fish handlinq

system are dependent upon the content of the final 316(b) Clean Water Act

requirements. Thereforeln summary, NPPD concludes the cumulative impact

due to impingement of fish and shellfish in the Missouri River is SMALL and

mitigation measures are not warranted."

Reference: Clarification. It is expected that the final design will be at least as robust as currently

described.

(11) Page 6-2, "Impinge of fish and shellfish [10 CFR 51.53(c)(3)(ii)(B)]" is revised to read:

"SMALL. Missouri River studies and previous agency determinations identify

factors (i.e., river and tributary dams, channelization and other habitat

management, invasive aquatic species) other than impingement as being the

primary cause of direct and cumulative impacts to the fish populations. CNS is

also planning to install a fish handling and return system consist!ng of inside and

outside fish sprays and a separate fish return trough to the existing OVVlS design

(RiGtr•ph screens) which would most likely be considered Best Technology

Available. The CNS implementation date and the final design of the fish handling

system are dependent upon the content of the final 316(b) Clean Water Act

July 2010 A.3-3 NUREG-1437, Supplement 41
NLS2010037 CNS-Z

Attachment 3

Page 4 of 4

requirements. Therefer-eln summary, NPPD concludes the impact from plant

operations due to impingement of fish and shellfish in the Missouri River is

SMALL. Further consideration of mitigation measures is not warranted."

Reference: Clarification. It is expected that the final design will be at least as robust as currently

described.

(12) Page 9-4, Table 9.2-1, delete entry 7, "CNS Radioactive Waste Transport Permit No.

0218-26-08-X."

Reference: NPPD is no longer authorized to ship radwaste under this permit.

(13) Page 9-5, Table 9.2-1, revise entry 1, "CNS Radioactive Waste License for Delivery No.

T-NE002-L08 expiration date from "December 31, 2008" to "January 3, 2011."

Reference: Letter from M. Singleton (Tennessee Department of Environment and Conservation)

to J. Kuttler (NPPD), dated November 24, 2009, "Radioactive Waste License-for-Delivery."

(14) Page 9-5, Table 9.2-1, revise entry 2, "Generator Site Access Permit No. 0111000042

expiration date from "January 3, 2009" to "January 3, 2011."

Reference: Letter from D. Finerfrock (Utah Department of Environmental Quality) to J. Kuttler

(NPPD), dated November 24, 2009, "Generator Site Access Permit Number 0111000042."

NUREG-1437, Supplement 41 A.3-4 July 2010
APPENDIX B.

NATIONAL ENVIRONMENTAL POLICY ACT ISSUES FOR

LICENSE RENEWAL OF NUCLEAR POWER PLANTS

B. NATIONAL ENVIRONMENTAL POLICY ACT ISSUES FOR LICENSE

RENEWAL OF NUCLEAR POWER PLANTS

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

B, Subpart A, to Title 10 of the Code of Federal Regulations (CFR) Part 51. Data supporting this

table are contained in NUREG-1437, Generic Environmental Impact Statement for License

Renewal of Nuclear Plants. Throughout this report, "Generic" issues are also referred to as

Category I issues, and "Site-specific" issues are also referred to as Category 2 issues.

Issue Type of Issue Finding

Surface Water Quality, Hydrology, and Use

Impacts of

refurbishment on

surface water quality

Impacts of

refurbishment on

surface water use

Altered current

patterns at intake and

discharge structures

Altered salinity

gradients

Altered thermal

stratification of lakes

Temperature effects

on sediment transport

capacity

Scouring caused by

discharged cooling

water

Eutrophication

Discharge of chlorine

or other biocides

Discharge of sanitary

wastes and minor

chemical spills

Generic

Generic

Generic

Generic

Generic

Generic

Generic

Generic

Generic

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.

SMALL. Water use during refurbishment will not increase

appreciably or will be reduced during plant outage.

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.

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.

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.

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.

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.

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.

SMALL. Effects are not a concern among regulatory and resource

agencies, and are not expected to be a problem during the license

renewal term.

SMALL. Effects are readily controlled through National Pollutant

Discharge Elimination System (NPDES) permit and periodic

modifications, if needed, and are not expected to be a problem

during the license renewal term.

Discharge of other

metals in wastewater

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

at operating nuclear power plants with cooling-tower-based heat

dissipation systems and have been satisfactorily mitigated at

other plants. They are not expected to be a problem during the

license renewal term.

July 2010 B-1 NUREG-1437, Supplement 41
Appendix B

Issue Type of Issue Finding

Water use conflicts Generic SMALL. These conflicts have not been found to be a problem at

(plants with operating nuclear power plants with once-through heat dissipation

once-through cooling systems.

systems)

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

(plants with cooling nuclear power plants with cooling ponds and at plants with cooling

ponds or cooling towers. Impacts on instream and riparian communities near these

towers using makeup plants could be of moderate significance in some situations. See

water from a small § 51.53(c)(3)(ii)(A).

river with low flow)

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 Generic SMALL. Accumulation of contaminants has been a concern at a

contaminants in few nuclear power plants but has been satisfactorily mitigated by

sediments or biota 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 Generic SMALL. Entrainment of phytoplankton and zooplankton has not

phytoplankton and been found to be a problem at operating nuclear power plants and

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

to migrating fish operating nuclear power plants and are not expected to be a

problem during the license renewal term.

Distribution of aquatic Generic SMALL. Thermal discharge may have localized effects but is not

organisms expected to affect the larger geographical distribution of aquatic

organisms.

Premature emergence Generic SMALL. Premature emergence has been foundto be a localized

of aquatic insects effect at some operating nuclear power plants but has not been a

problem and is not expected to be a problem during the license

renewal term.

Gas supersaturation

(gas bubble disease)

Low dissolved oxygen

in the discharge

Generic

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.

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.

NUREG-1437, Supplement 41 B-2 July 2010
Appendix B

Issue Type of Issue Finding

Losses from predation, Generic SMALL. These types of losses have not been found to be a

parasitism, and problem at operating nuclear power plants and are not expected disease among to be a problem during the license renewal term.

organisms exposed to

sublethal stresses

Stimulation of Generic SMALL. Stimulation of nuisance organisms has been satisfactorily

nuisance organisms mitigated at the single nuclear power plant with a once-through (e.g., shipworms) 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 Site-specific SMALL, MODERATE, OR LARGE. The impacts of entrainment

shellfish in early life are small at many plants but may be moderate or even large at a

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

and shellfish 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 someplants. See § 51.53(c)(3)(ii)(B).

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

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

shellfish in early life at operating nuclear power plants with this type of cooling system

stages and is not expected to be a problem during the license renewal

term.

Impingement of fish Generic SMALL. The impingement has not been found to be a problem at

and shellfish 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.

Ground Water Use and Quality

Impacts of Generic SMALL. Extensive dewaterina durina the orioinal construction on

refurbishment on

ground water use and

quality

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.

July 2010 B-3 NUREG-1437, Supplement 41
Appendix B

Issue Type of Issue Finding

Ground water use Generic SMALL Plants usino less than 100 aDm are not exoected to

conflicts (potable

and service water;

plants that use

<100 gallons per

minute (gpm)

Ground water use

conflicts (potable and

service water, and

dewatering plants that

use >100 gpm

Ground water use

conflicts (plants using

cooling towers

withdrawing makeup

water from a small

river)

Ground water use

conflicts (Ranney

wells)

Ground water quality

degradation (Ranney

wells)

Ground water quality

degradation (saltwater

intrusion)

Ground water quality

degradation (cooling

ponds in salt marshes)

Ground water quality

degradation (cooling

ponds at inland sites)

cause any ground water use conflicts.

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).

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

from surface water withdrawals from small water bodies during

low flow conditions which may affect aquifer recharge, especially

if other ground water or upstream surface water users come

online before the time of license renewal. See § 51.53(c)(3)(ii)(A).

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).

Generic

Generic

Generic

SMALL. Ground water quality at river sites may be degraded by

induced infiltration of poor-quality river water into an aquifer that

supplies large quantities of reactor cooling water. However, the

lower quality infiltrating water would not preclude the current uses

of ground water and is not expected to be a problem during the

license renewal term.

SMALL. Nuclear power plants do not contribute significantly to

saltwater intrusion.

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.

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

ponds may degrade ground water quality. For plants located

inland, the quality of the ground water in the vicinity of the ponds

must be shown to be adequate to allow continuation of current

uses. See § 51 .53(c)(3)(ii)(D).

Terrestrial Ecology

Refurbishment impacts

Cooling tower impacts

on crops and

ornamental vegetation

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).

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.

NUREG-1437, Supplement 41 B-4 July 2010
Appendix B

Issue Type of Issue Finding

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

on native plants 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 Generic SMALL. These collisions have not been found to be a problem at

cooling towers operating nuclear power plants and are not expected to be a

problem during the license renewal term.

Cooling pond impacts Generic SMALL. Impacts of cooling ponds on terrestrial ecological

on terrestrial resources resources are considered to be of small significance at all sites.

Power line right of way Generic SMALL. The impacts of ROW maintenance on wildlife are

(ROW) management expected to be of small significance at all sites.

(cutting and herbicide

application)

Bird collisions with Generic SMALL. Impacts are expected to be of small significance at all

power lines sites.

Impacts of Generic SMALL. No significant impacts of electromagnetic fields on

electromagnetic fields terrestrial flora and fauna have been identified. Such effects are

on flora and fauna not expected to be a problem during the license renewal term.

Floodplains and Generic SMALL. Periodic vegetation control is necessary in forested

wetland on power line wetlands underneath power lines and can be achieved with

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

endangered species and continued operation are not expected to adversely affect

threatened or endangered species. However, consultation with

appropriate agencies would be needed at the time of license

renewal to determine whether or not threatened or endangered

species are present and whether or not they would be adversely

affected. See § 51.53(c)(3)(ii)(E).

Air Quality

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

refurbishment refurbishment associated with license renewal are expected to be

(non-attainment and small. However, vehicle exhaust emissions could be cause for

maintenance areas) concern at locations in or near nonattainment or maintenance

areas. The significance of the potential impact cannot be

determined without considering the compliance status of each site

and the number of workers expected to be employed during the

outage. See § 51.53(c)(3)(ii)(F).

Air quality effects of Generic SMALL. Production of ozone and oxides of nitrogen is

transmission lines insignificant and does not contribute measurably to ambient levels

of these gases.

Land Use

Onsite land use

Power line ROW

Generic

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.

SMALL. Ongoing use of power line ROWs would continue with no change in restrictions. The effects of these restrictions are of

small significance.

July 2010 B-5 NUREG-1437, Supplement 41
Appendix B

Issue Type of Issue Finding

Human Health

Radiation exposures to Generic SMALL. During refurbishment, the gaseous effluents would result

the public during in doses that are similar to those from current operation.

refurbishment Applicable regulatory dose limits to the public are not expected to

be exceeded.

Occupational radiation Generic SMALL. Occupational doses from refurbishment are expected to

exposures during be within the range of annual average collective doses

refurbishment 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 Generic SMALL. Occupational health impacts are expected to be

organisms controlled by continued application of accepted industrial hygiene

(occupational health) practices to minimize exposure to workers.

Microbiological Site-specific SMALL, MODERATE, OR LARGE. These organisms are not

organisms (public expected to be a problem at most operating plants except

health)(plants using possibly at plants using cooling ponds, lakes, or canals that

lakes or canals, or discharge to small rivers. Without site-specific data, it is not

cooling towers or possible to predict the effects generically. See § 51.53(c)(3)(ii)(G).

cooling ponds that

discharge to a small

river)

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 Site-specific SMALL, MODERATE, OR LARGE. Electrical shock resulting from - acute effects (electric direct access to energized conductors or from induced charges in

shock) 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 Uncategorized UNCERTAIN. Biological and physical studies of 60-hertz (Hz) - chronic effects 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 Generic SMALL. Radiation doses to the public will continue at current

public (license renewal levels associated with normal operations.

term)

Occupational radiation Generic SMALL. Projected maximum occupational doses during the

exposures (license license renewal term are within the range of doses experienced

renewal term) during normal operations and normal maintenance outages, and

would be well below regulatory limits.

Socioeconomic Impacts

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

to be of small significance at plants located in a medium or high

population area and not in an area where growth control

measures that limit housing development are in effect. Moderate

or large housing impacts of the workforce associated with

refurbishment may be associated with plants located in sparsely

populated areas or in areas with growth control measures that

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

NUREG-1437, Supplement 41 B-6 July 2010
Appendix B

Issue Type of Issue Finding

Public services: public Generic SMALL. Impacts to public safety, social services, and tourism and

safety, social services, recreation are expected to be of small significance at all sites.

and tourism and

recreation

Public services: public Site-specific SMALL OR MODERATE. An increased problem with water

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

education impacts of small significance but larger impacts are possible

(refurbishment) depending on site- and project-specific factors. See

§ 51.53(c)(3)(ii)(l).

Public services: Generic SMALL. Only impacts of small significance are expected.

education (license

renewal term)

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

(refurbishment) significance at plants in low population areas. See

§ 51.53(c)(3)(ii)(I).

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

(license renewal term) use may be associated with population and tax revenue changes resulting from license renewal. See § 51.53(c)(3)(ii)(I).

Public services: Site-specific SMALL, MODERATE, OR LARGE. Transportation impacts (level

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

archaeological and continued operation are expected to have no more than small

resources adverse impacts on historic and archaeological resources.

However, the National Historic Preservation Act requires the

Federal agency to consult with the State Historic Preservation

Officer to determine whether or not there are properties present that require protection. See § 51.53(c)(3)(ii)(K).

Aesthetic impacts Generic SMALL. No significant impacts are expected during

(refurbishment) refurbishment.

Aesthetic impacts Generic SMALL. No significant impacts are expected during the license

(license renewal term) renewal term.

Aesthetic impacts of Generic SMALL. No significant impacts are expected during the license

transmission lines renewal term.

(license renewal term)

Postulated Accidents

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

impacts of design-basis accidents are of small significance for all

plants.

Severe accidents Site-specific SMALL. The probability weighted consequences of atmospheric releases, fallout onto open bodies of water, releases to ground

water, and societal and economic impacts from severe accidents

are small for all plants. However, alternatives to mitigate severe

accidents must be considered for all plants that have not

considered such alternatives. See § 51.53(c)(3)(ii)(L).

July 2010 B-7 NUREG-1437, Supplement 41
Appendix B

Issue Type of Issue Finding

Uranium Fuel Cycle and Waste Management

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

- impacts (individual considered by the Commission in Table S-3 of this part. Based on

effects from other than information in the GElS, impacts on individuals from radioactive

the disposal of spent gaseous and liquid releases including radon-222 and

fuel and high level technetium-99 are small.

waste)

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

impacts (collective

effects)

population from the fuel cycle, high level waste, and spent fuel

disposal excepted, is calculated to be about 14,800 person rem,

or 12 cancer fatalities, for each additional 20-year power reactor

operating term. Much of this, especially the contribution of radon

releases from mines and tailing piles, consists of tiny doses

summed over large populations. This same dose calculation can

theoretically be extended to include many tiny doses over

additional thousands of years as well as doses outside the United

States. The result of such a calculation would be thousands of

cancer fatalities from the fuel cycle, but this result assumes that

even tiny doses have some statistical adverse health effect which

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

thousand years), and that these doses projected over thousands

of years are meaningful; however, these assumptions are

questionable. In particular, science cannot rule out the possibility

that there will be no cancer fatalities from these tiny doses. For

perspective, the doses are very small fractions of regulatory limits,

and even smaller fractions of natural background exposure to the

same populations.

Nevertheless, despite all the uncertainty, some judgment as to the

regulatory NEPA implications of these matters should be made

and it makes no sense to repeat the same judgment in every

case. Even taking the uncertainties into account, the Commission

concludes that these impacts are acceptable in that these impacts

would not be sufficiently large to require the NEPA conclusion, for

any plant, that the option of extended operation under

10 CFR Part 54 should be eliminated. Accordingly, while the

Commission has not assigned a single level of significance for the

collective effects of the fuel cycle, this issue is considered

Category 1 (Generic).

I NUREG-1437, Supplement 41 B-8 July 2010
Appendix B

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 it is assumed that limits are developed along the lines

of the 1995 National Academy of Sciences (NAS) report,

"Technical Bases for Yucca Mountain Standards," and that in

accordance with the Commission's Waste Confidence Decision,

10 CFR 51.23, a repository can and likely will be developed at

some site which will comply with such limits, peak doses to

virtually all individuals will be 100 millirem per year or less.

However, while the Commission has reasonable confidence that

these assumptions will prove correct, there is considerable

uncertainty since the limits are yet to be developed, no repository

application has been completed or reviewed, and uncertainty is

inherent in the models used to evaluate possible pathways to the

human environment. The NAS report indicated that 100 millirem

per year should be considered as a starting point for limits for

individual doses, but notes that some measure of consensus

exists among national and international bodies that the limits

should be a fraction of the 100 millirem per year. The lifetime

individual risk from 100 millirem annual dose limit is about 3 x

10-3.

Estimating cumulative doses to populations over thousands of

years is more problematic. The likelihood and consequences of

events that could seriously compromise the integrity of a deep

geologic repository were evaluated by the Department of Energy

in the "Final Environmental Impact Statement: Management of

Commercially Generated Radioactive Waste," October 1980. The

evaluation estimated the 70-year whole-body dose commitment to

the maximum individual and to the regional population resulting

from several modes of breaching a reference repository in the

year of closure, after 1,000 years, after 100,000 years, and after

100,000,000 years. Subsequently, the NRC and other federal

agencies have expended considerable effort to develop models

for the design and for the licensing of a high level waste

repository, especially for the candidate repository at Yucca

Mountain. More meaningful estimates of doses to population may

be possible in the future as more is understood about the

performance of the proposed Yucca Mountain repository. Such

estimates would involve very great uncertainty, especially with

respect to cumulative population doses over thousands of years.

The standard proposed by the NAS is a limit on maximum

individual dose. The relationship of potential new regulatory

requirements, based on the NAS report, and cumulative

population impacts has not been determined, although the report

articulates the view that protection of individuals will adequately

protect the population for a repository at Yucca Mountain.

However, the EPA's generic repository standards in

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

magnitude of cumulative risk to population that could result from

the licensing of a Yucca Mountain repository, assuming the

ultimate standards will be within the range of standards now under

consideration. The standards in 40 CFR Part 191 protect the

population by imposing the amount of radioactive material

released over 10,000 years. The cumulative release limits are

based on the EPA's population impact goal of 1,000 premature

cancer deaths worldwide for a 100,000 metric ton (MT) repository.

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).

July 2010 B-9 NUREG-1437, Supplement 41
Appendix B

Issue Type of Issue Finding

Nonradiological Generic SMALL. The nonradiological impacts of the uranium fuel cycle

impacts of the uranium resulting from the renewal of an operating license for any plant

fuel cycle are found to be small.

Low-level waste

storage and disposal

Generic

Mixed waste storage

and disposal

Onsite spent fuel

Nonradiological waste

Transportation

Generic

Generic

Generic

Generic

SMALL. The comprehensive regulatory controls that are in place

and the low public doses being achieved at reactors ensure that

the radiological impacts to the environment will remain small

during the term of a renewed license. The maximum additional

onsite land that may be required for

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

associated impacts will be small.

Nonradiological impacts on air and water will be negligible. The

radiological and nonradiological environmental impacts of

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

licensed sites are small. In addition, the Commission concludes

that there is reasonable assurance that sufficient low-level waste

disposal capacity will be made available when needed for facilities

to be decommissioned consistent with NRC decommissioning

requirements.

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.

SMALL. The expected increase in the volume of spent fuel from

an additional 20 years of operation can be safely accommodated

on site with small environmental effects through dry or pool

storage at all plants if a permanent repository or monitored

retrievable storage is not available.

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.

SMALL. The impacts of transporting spent fuel enriched up to

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

current levels approved by NRC up to 62,000 megawatt days per

metric-ton uranium Wd/MTU)and the cumulative impacts of

transporting high-level waste to a single repository, such as Yucca

Mountain, Nevada are found to be consistent with the impact

values contained in 10 CFR 51.52(c), Summary Table S-4 -

Environmental Impact of Transportation of Fuel and Waste to and

from One Light-Water-Cooled Nuclear Power Reactor. If fuel

enrichment or burnup conditions are not met, the applicant must

submit an assessment of the implications for the environmental

impact values reported in § 51.52.

NUREG-1437, Supplement 41 B-10 July 2010
Appendix B

Issue Type of Issue Finding

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 Generic SMALL. Decommissioning would have some short-term

impacts socioeconomic impacts. The impacts would not be increased by

delaying decommissioning until the end of a 20-year relicense

period, but they might be decreased by population and economic

growth.

Environmental Justice

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

environmental justice will be addressed in plant-specific reviews.

July 2010 B-1 1 NUREG-1437, Supplement 41

APPENDIX C.

APPLICABLE REGULATIONS, LAWS, AND AGREEMENTS

C. APPLICABLE REGULATIONS, LAWS, AND AGREEMENTS

The Atomic Energy Act (42 USC § 2021) authorizes the U.S. Nuclear Regulatory Commission

(NRC) to enter into agreement with any State to assume regulatory authority for certain

activities. For example, through the Agreement State Program, Nebraska assumed regulatory

responsibility over certain byproduct, source, and small quantities of special nuclear material.

The Nebraska Agreement State Program is administered by the Radiation Control Program (the

program) in the Department of Health. The Program Manager reports to the Section

Administrator for Consumer Health Services, who reports to the Division Director for Public

Health Assurance, who in turn reports to the Director of Regulation and Licensure.

In addition to implementing some Federal programs, State legislatures develop their own laws.

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

and ground water. State legislation may address solid waste management programs, locally

rare or endangered species, and historic and cultural resources.

The Clean Water Act (CWA) allows for primary enforcement and administration through State

agencies, provided the State program is at least as stringent as the Federal program. The State

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

Pollutant Discharge Elimination System (NPDES) program from the Environmental Protection

Agency (EPA) to the State. The primary mechanism to control water pollution is the requirement

for direct dischargers to obtain an NPDES permit, or in the case of States where the authority

has been delegated from the EPA, a State Pollutant Discharge Elimination System (SPDES)

permit, pursuant to the CWA. In Nebraska, the Nebraska Department of Environmental Quality

(NDEQ) issues and enforces NPDES permits.

C.1. Federal Environmental Requirements

Cooper Nuclear Station (CNS) is subject to Federal requirements regarding their environmental

program. Those requirements are briefly described below. See Section 1.9 for CNS's

compliance status with these requirements.

Table C-1 provides a list of the principal Federal environmental regulations and laws that are

applicable to the review of the environmental resources that could be affected by this project

that may affect license renewal applications for nuclear power plants.

July 2010 C-1 NUREG-1437, Supplement 41
Appendix C

Table C-1. Federal Environmental Requirements

Law/Regulation Requirements

10 CFR Part 51. Code of

Federal Regulations (CFR),

Title 10, Energy, Part 51

10 CFR Part 54

10 CFR Part 50

Current Operating License and License Renewal

"Environmental Protection Regulations for Domestic Licensing and Related

Regulatory Functions." This part contains environmental protection regulations

applicable to the NRC's domestic licensing and related regulatory functions.

"Requirements for Renewal of Operating Licenses for Nuclear Power Plants." This

part focuses on managing adverse effects of aging; rather than identification of all

aging mechanisms. The rule is intended to ensure that important systems,

structures, and components will continue to perform their intended function in the

period of extended operation.

Regulations promulgated by the NRC pursuant to the Atomic Energy Act of 1954, as

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

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

This part also gives notice to all persons who knowingly provide to any licensee,

applicant, contractor, or subcontractor, components, equipment, materials, or other

goods or services, that relate to a licensee's or applicant's activities subject to this

part, that they may be individually subject to NRC enforcement action for violation of

§ 50.5.

Air Quality Protection

Clean Air Act (CAA) The CAA is a comprehensive Federal law that regulates air emissions. Under the

(42 U.S.C. § 7401 et seq.) CAA, Federal actions cannot thwart State and local efforts to remedy long-standing

air quality problems that threaten public health issues associated with the six criteria

air pollutants (i.e., ozone, nitrogen dioxide, sulfur dioxide, particulate matter, carbon

-monoxide, and lead).

Water Resources Protection

Section 404 of the Clean Section 404 of the CWA established a program to regulate the discharge of

Water Act (CWA) dredged and fill material into waters of the United States, including wetlands. The

(33 U.S.C. § 1344) U.S. Army Corps of Engineers (USACE) and the EPA jointly administer this

program. Under the 404 program, no discharge of dredged or fill material is allowed

if a practicable alternative exists that is less damaging to the aquatic environment or

if the nation's waters would be significantly degraded. A Federal permit is required

to discharge dredged or fill material into wetlands and waters of the United States.

Comprehensive Section 101 of CERCLA requires a permit to cover consumptive water use over

Environmental Response, 20,000 gallons per day (over a 30-day average) of surface and ground water.

Compensation, and Liability

Act (CERCLA)

(42 U.S.C. § 9601 et seq)

Wild and Scenic River Act Created the National Wild and Scenic Rivers System, established to protect the

(16 U.S.C. §1271 et seq.) environmental values of free flowing streams from degradation by impacting

activities including water resources projects.

Floodplain Executive Order Both executive orders require Federal agencies to consider the impacts of their

(No. 11988. May 24, 1977, actions on floodplains and wetlands through existing review procedures such as the

42 Federal Register (FR) National Environmental Policy Act of 1969 (NEPA).

26951) and Wetlands

Executive Order (No. 11990.

May 24, 1977, 42 FR 26961)

NUREG-1437, Supplement 41 C-2 July 2010
Appendix C

Law/Regulation Requirements

Waste Management and Pollution Prevention

Resource Conservation and Before a material can be classified as a hazardous waste, it must first be a solid

Recovery Act (RCRA) waste as defined under the RCRA. Hazardous waste is classified under Subtitle C

(42 USC § 6901 et seq.) of the RCRA. Parts 261 and 262 of Title 40 CFR contain all applicable generators of

hazardous waste regulations. Part 261.5 (a) and (e) contain requirements for

conditionally exempt small quantity generators (CESQGs). Part 262.34(d) contains

requirements for small quantity generators (SQGs). Parts 262 and 261.5(e) contain

requirements for large quantity generators (LQGs)

Pollution Prevention Act Formally established a national policy to prevent or reduce pollution at its source

(42 U.S.C. § 13101 et seq.) whenever feasible. The Act provides funds for State and local pollution prevention

programs through a grant program to promote the use of pollution prevention

techniques by business.

Endangered Species

Endangered Species Act Forbids any government agency, corporation, or citizen from taking (harming or

(ESA) (16 U.S.C. § 1531 et killing) endangered animals without an Endangered Species Permit.

seq.)

Fish and Wildlife Coordination To minimize adverse impacts of proposed actions on fish and wildlife resources and

Act (16 U.S.C. § 661 et seq.) habitat, requires that Federal agencies consult government agencies regarding

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

also requires that justifiable means and measures be used in modifying plans to

protect fish and wildlife in these waters.

Historic Preservation

National Historic Preservation Directs Federal agencies to consider the impact of their actions on historic

Act (NHPA) (16 U.S.C. § 470 properties. The NHPA also encourages State and local preservation societies.

et seq.)

Farmland

Farmland and Protection Requires that Federal programs, as practicable, shall be administered in a manner

Policy Act (7 U.S.C. § 4201 et compatible with State and local government and private programs and policies to

seq.) protect farmland.

July 2010 C-3 NUREG-1437, Supplement 41

APPENDIX D.

CONSULTATION CORRESPONDENCE

D. CONSULTATION CORRESPONDENCES

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

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

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

prior to taking action that may affect threatened and endangered species, essential fish habitat,

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

documentation.

Table D-1 provides a list of the consultation documents sent between the U.S. Nuclear

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

these agencies based on the National Environmental Policy Act of 1969 (NEPA) requirements.

Table D-1. Consultation Correspondences

Author Recipient Date of Letter/E-mail

U.S. Nuclear Regulatory Commission

(D. Pelton)

U.S. Nuclear Regulatory Commission

(D. Pelton)

U.S. Nuclear Regulatory Commission

(D. Pelton)

U.S. Nuclear Regulatory Commission

(D. Pelton)

U.S. Nuclear Regulatory Commission

(D. Pelton)

U.S. Nuclear Regulatory Commission

(D. Pelton)

Nebraska State Historical Society

(J. Dolberg)

U.S. Nuclear Regulatory Commission

(D. Pelton)

U.S. Nuclear Regulatory Commission

(D. Pelton)

U.S. Nuclear Regulatory Commission

(D. Pelton)

Nebraska Department of Natural

Resources (J.Angell)

Environmental Protection Agency

Region 7 (L. Shepard)

Nebraska Games and Parks

Commission (R. Simpson)

Fish and Wildlife Service

(J. DeWeese)

Nebraska State Historic Society

(M. Smith)

Advisory Council on Historic Preservation

(D. Klima)

Environmental Services Division,

Environmental Protection Agency Region 7

(J. Cothern)

Department of Health and Human

Services, Regulation and Licensure, Public

Health Assurance (J. Schmitt)

U. S. Fish and Wildlife Service, Ecological

Services - Nebraska Field Office

(J. Cochnar)

Missouri State Historic Society

(M. Miles)

U.S. Nuclear Regulatory Commission

(D. Pelton)

Nebraska Department of Natural

Resources (A. Bleed)

U.S. Army Corps of Engineers, Omaha

District (D. Press)

Sac and Fox Tribe of the Mississippi in

Iowa (A. Pushetonequa)(a)

U.S. Nuclear Regulatory Commission

(D. Pelton)

U.S. Nuclear Regulatory Commission

(E. Sayoc)

U.S. Nuclear Regulatory Commission

(R. Bulavinetz)

Nebraska Public Power District

(J. Citta)

January 16, 2009

(ML090080197)

January 26, 2009

(ML090080683)

January 27, 2009

(ML090230446)

January 28, 2009

(ML090210249)

January 29, 2009

(ML090070507)

January 29, 2009

(ML090210750)

February 02, 2009

(ML090650061)

February 04, 2009

(ML090260380)

February 04, 2009

(ML090160476)

February 04, 2009

(ML090080045)

March 09, 2009

April 16, 2009

(ML091070269)

May 08, 2009

(ML0914001 10)

June 08, 2009

(ML091830055)

July 2010 D-1 NUREG-1437, Supplement 41 1
Appendix D

Author

U.S. Fish and Wildlife Service

(R. Harms)

Nebraska State Historic Society

(R. Puschendorf)

U.S. Department of Interior

(R. Stewart)

U.S. Environmental Protection

Agency (R. Hammerschmidt)

Recipient

U.S. Nuclear Regulatory Commission

(B. Brady)

U.S. Nuclear Regulatory Commission

(B. Pham)

U.S. Nuclear Regulatory Commission

(Chief. Rules and Directives Branch)

U.S. Nuclear Regulatory Commission

(M. Lesar)

Date of Letter/E-mail

March 19, 2010

(ML101440172)

March 19, 2010

(ML101440132)

April 27, 2010

(ML101440133)

May 03, 2010

(ML101270268)

I NUREG-1437, Supplement 41 D-2 July 2010
Appendix D

D.1. Consultation Correspondence

The following pages contain copies of the letters listed in Table D-1.

July 2010 D-3 NUREG-1437, Supplement 41
Appendix D

january 16, 2009

Mr. Michael J. Smith

State Historic Preservation Officer

Nebraska State Historical Society

P.O. Box 82554

Lincoln, NE 68501

SUBJECT: COOPER NUCLEAR STATION LICENSE RENEWAL APPLICATION REVIEW

(HP NO. 0801-050-01, DESCRIPTION, NPPO. COOPER NUCLEAR STATION)

Dear Mr. Smith:

The U.S. Nuclear Regulatory Commission (NRC or the staff) is reviewing an application to

renew the operating license for Cooper Nuclear Station (CNS). which is located in Nemaha

County, Nebraska, on the wNest bank of the Missouri River at river mile 'RM) 532.5. The Village

of Brownville, NE is located approxima-,ely 2.25 miles northwest of the site. CNS is operated by

the Nebraska Public Power District (NPPD). The application for renewal was submitted by

NIPPD by letter dated September 24, 2008, pursuant. to Title 10 of the Code of Federai

Reguiatouis Part 54 (10 CFR Part 54).

The NRC has established that, as part of the staffs review of any nuclear power plant license

renewal action, a Supplemental Environmental Impact Statement (SEIS) to its "Generic

Environmental Impact Statement for License Renewal of Nuclear Plants", NUREG-1437, will be

prepared under the provisions of 10 CFR Part 51, the NRC's regulation that implements the

National EnvironmentaiPolicy Act of 1969 (NEPA). In accordance with 36 CFR 800.8(c), the

SEIS will include analyses of potential impacts to historic and cultural resources.

In the context of the National Historic Preservation Act of 1966, as amended, the NRC staff has

determined that the area of potential effect (APE) for a license renewal action is the area at the

power plant site and its immediate environs that may be impacted by post-license renewal landdisturbing operations or possible refurbishment activities associated with the proposed action.

The APE may extend beyond the immediate environs in those instances where post- license

renewal land-disturbing operations or projected refurbishment activities specifically related to

license renewal may potentially have an effect on known or proposed historic sites. This

determination is made irrespective of ownership or control of the lands of interest.

On February 25, 2009, :he NRC will conduct two public license renewal and environmental

scoping meetings. The first session will be held at the Brownville Concert Hall at 126 Alantic

St-, Brownville, NE 68321, telephone (402) 825-3331, and willconvene at 1:30 p.m. and will

continue until 4:30 p.m., as necessary. The second session will be held at the Auburn Senior

Center at 1101 J St., Auburn, NE 68305, telephone (402) 274-3420, and will convene at 7ý00

p.m., with a repeat of the overview portions of the meeting and will continue until 10:00 p m., as

necessary. You and your staff are invited to attend. Your office will receive a copy of the draft

SEIS along with a request for comments. The staff expects to publish the draft SEIS in

December 2009.

NUREG-1437, Supplement 41 D-4 July 2010
Appendix D

Loan01d

1 btd

H csý,1

-SUMC BOL~ar'e6

00.5-1 2 3 4

Or_'I PNiles

Cooper Nuclear Station Site Map - F Mile Radius

July 2010 D-5 NUREG-1437, Supplement 41 1
Appendix D

I Trnmission Lines

Cooper Nuclear Station Transmission Lines

I NUREG-1437, Supplement 41 D-6 July 2010
Appendix D

January 26, 2009

Mr. Don L. Klima, Director

Advisory Council on Historic Preservation

Office of Federal Agency Programs

1100 Pennsylvania Ave., NW, Suite 803

Washington, DC 20004

SUBJECT: COOPER NUCLEAR STATION LICENSE RENEWAL APPLICATION REVIEW

Dear Mr. Klima:

The U.S. Nuclear Regulatory Commission (NRC or the staff) is reviewing an application to

renew the operating license for Cooper Nuclear Station (CNS) which is located near Brownville,

Nebraska. It is operated by the Nebraska Public Power District (NPPD). The application for

renewal was submitted by NPPD by letter dated September 24, 2008, pursuant to Title 10 of the

Code of Federal Regulations Part 54 (10 CFR Part 54).

The NRC has established that: as part of the staffs review of any nuclear power plant license

renewal action, a site-specific Supplemental Environmental Impact Statement (SEIS) to its

'Generic Environmental Impact Statement for License Renewal of Nuclear Plants'.

NLIREG-I 4:37. will be prepared under the provisions of 10 CFR Part 51, the NRC's regulation

that implements the National Environmental Policy Act of 1969 (NEPA). In accordance with

36 CFR 800.8(c), the SEIS will include analyses of potential impacts to historic and cultural

resources.

On February 25, 2009, the NRC will conduct two public license renewal and environmental

scoping meetings. The first session will be held at the Brownville Concert Hall at 126 Atlantic

St., Brownville, NE 68321, telephone (402) 825-3331, and will convene at 1:30 p.m. and will

continue until 4:30 p.m., as necessary. The second session will be held at the Auburn Senior

Center at 1101 J St., Auburn, NE 68305, telephone (402) 274-3420, and will convene at

7:00 p.m., with a repeat of the overview portions of the meeting and will continue until

'10:00 p.m., as necessary. You and your staff are invited to attend. In addition, during the week

of March 30. 2009, the NRC staff plans to conduct a site audit at CNS. Your office will receive a

copy of the draft SEIS along with a request for comments. The anticipated publication date for

the draft SEIS is December 2009.

July 2010 D-7 NUREG-1437, Supplement 41
Appendix D

D. Klima -2-

If you have any questions or require additional information, please contact the License Renewal

Project Managers. Tarn Tran telephone, (301) 4"15-3617, email: tamrtranc.-Dnrcqov or Emmanuel

Sayoc, telephone (301) 415-1924. email: emranuel.sayoc)nrc..iov.

Sincerely,

\RAI

David L. Pelton, Chief

Projects Branch 1

Division of License Renewal

Office of Nuclear Reactor Regulation

Docket No. 50-298

cc wlo encd: See next page

NUREG-1437, Supplement 41 D-8 July 2010
Appendix D

January 27, 2009

Mr. Joseph Cothern

Environmental Review Coordinator

Environmental Services Division

USEPA Region 7

901 North 5h Street

Kansas City, KS 66101

SUBJECT: COOPER NUCLEAR STATION LICENSE RENEWAL APPLICATION

REVIEW

Dear Mr. Cothern:

The U.S. Nuclear Regulatory Commission (NRC or the staff) is reviewing an application

subnlitted by Nebraska Public Power District, for the renewal of the operating license for Cooper

Nuclear Station (CNS) Unit 1, which is located in Nemaha County, Nebraska. on the west bank

of the Missouri River at river mile 532.5. The Village of Brownville, NE is located approximately

2.25 miles northwest of the site, and Lincoln, NE. is located approximately 60 miles west

northwest of the site. As part of the review of the license renewal application (LRA), the NRC is

preparing a Supplemental Environmental Impact Statement (SEIS) under the provisions of Title

"10 of the Code of Federal Regulations Part 51 (10 CFR Part 51), the NRC's regulation that

implements the National Environmental Policy Act of 1969.

CNS is requesting the renewal of its operating license for a period of 20 years beyond the

expiration of the current license term, renewing the license until January 18, 2034. The

proposed action would include the use and continued maintenance of existing plant facilities

and transmission lines, CNS does not plan to construct or alter any facilities associated with the

plant during the period of extended operation.

The NRC staff plans to hold two identical public meetings coveiing the license renewal and

environmental scoping process on February 25, 2009. The first session will be held at the

Brownville Concert Hall at 126 Atlantic Street, Brownville, NE 68321, telephone (402) 825-3331,

and will convene at 1:30 p.m. and will continue until 4:30 p.m., as necessary. The second

session will be held at the Auburn Senior Center at 1101 J Street, Auburn, NE 68305, telephone

(402) 274 3420, and will convene at 7:00 p.m., with a repeat of the overview portions of the

meeting and will continue until 10:00 p.m., as necessary. In addition, during the week of

March 30, 2009, the NRC plans to conduct a site audit. You and your staff are invited to attend

both the site audit and the public meetings. Your office will receive a copy of the draft SEIS

along with a request for comments. The anticipated publication date for the draft SEIS is

December 2009.

July 2010 D-9 NUREG-1437, Supplement 41
Appendix D

J. Cothern -2-

If you have any questions concerning the NRC staff s review of this LRA, please contact NRC's

Project Managers, Tam Tran, by telephone, 1-800-368-5642. extension 3'617, or by e-mail at

tam.:ran,@nrcxiov, or Emmanuel Sayoc, by telephone. 1-800-368-5642, extension 1924, or by

e-mail at ernmanuel.say'ocT,.hnrc.qov.

Sincerely.

IRA I

David L. Pelton. Chief

Projects Branch 1

Division of License Renewal

Office of Nuclear Reactor Regulation

Docket No. 50-298

cc w/encls: See next page

NUREG-1437, Supplement 41 D-1I0 July 2010
Appendix D

January 28. 2009

rMls. Julia Schmitt, Manager

Radiation Control Program

Department of Health and Human Services

Regulation and Licensure

Public Health Assurance

301 Centennial Mall, South

P.O. Box 95007

Lincoln, NE 68509-5007

SUBJECT: COOPER NUCLEAR STATION LICENSE RENEWAL APPLICATION

REVIEW

Dear Ms. Schmitt:

The U.S. Nuclear Regulatory Commission (NRC or the staff) is reviewing an application

submitted by Nebraska Public Power District (NPPD), for the renewal of the operating license

for Cooper Nuclear Station (CNS). which is located in Nemaha County, Nebraska (NE), on the

west bank of the Missouri River at river mile (RM) 532.5. The Village of Brownville, NE is

located approximately 2.25 miles northwest of the site. and Lincoln, Nebraska, is located

approximately 60 miles west northwest of the site. As part of the review of the license renewal

application (LRA), the NRC is preparing a Supplemental Environmental Impact Statement

(SEIS) under the provisions of Title 10 of the Code of Federal Regulations Part 51 (10 CFR Part

51), the NRC's regulation that implements the National Environmental Policy Act (NEPA) of

1969.

CNS is requesting the renewal of its operating license for a period of 20 years beyond the

expiration of the current license term, renewing the license until January 18, 2034. The

proposed action would include the use and continued maintenance of existing plant facilities

and transmission lines: CNS does not plan to construct or alter any facilities associated with the

plant during the period of extended operation.

The NRC staff plans to hold two identical public meetings covering the license renewal and

environmental scoping process on February 25, 2009. The first meeting will be held at the

Brownville Concert Hall at 126 Atlantic St., Brownville, NE 68321, telephone (402) 825-3331.

The meeting will convene at 1:30 p.m. and will continue until 4:30 p.m., as necessary. The

second meeting will be held at the Auburn Senior Center at 1101 J St., Auburn, NE 68305.

telephone (402) 274 3420. The meeting will convene at 7:00 p.m., with a repeat of the overview

portions of the meeting and will continue until 10:00 p.m., as necessary. In addition, during the

week of March 30, 2009, the NRC plans to conduct a site audit. You and your staff are invited

to attend both the site audit and the public meetings. Your office will receive a copy of the draft

SEIS along with a request for comments. The anticipated publication date for the draft SEIS is

December 2009.

July 2010 D-11 NUREG-1437, Supplement 41
Appendix D

J. Schmitt -2-

If you have any questions concerning the NRC staffs review of this license renewal aoplication,

DIlease contact NRC's Project Managers, Tarn Tran, bytelephone,1-800-368-5642, extension

3617, or by email mo the NRC at -am.:ran ,rfrc.aov, or Emmanuel Sayoc, by telephone.

1-800-368-5642. extension 1924, or ty email to the NRC at en-rn.anuel.sav, oc'r-rc.Qo.

Sincerely,

IRA I

David L. Pelton. Chief

Projects Branch 1

Division of License Renewal

Office of Nuclear Reactor Regulation

Docket No. 50-298

cc w),,o encl: See next page

NUREG-1437, Supplement 41 D-1 2 July 2010
Appendix D

January 29. 2009

Mr. John Cochnar

U. S. Fish and Wildlife Service

Ecological Services - Nebraska Field Office

203 West Second Street

Grand Island, NE 68801

SUBJECT: REQUEST FOR LIST OF PROTECTED SPECIES WITHIN THE AREA UNDER

EVALUATION FOR THE COOPER NUCLEAR STATION, UNIT I LICENSE

RENEWAL APPLICATION REVIEW

Dear Mr. Cochriar:

The U.S. Nuclear Regulatory Commission (NRC or- the staff) is reviewing an application

submitted by the Nebraska Public Power District (NPPD) for the renewal of the operating

license for Cooper Nuclear Station (CNS) Unit I. CNS is located rn Nernala County, Nebraska

(NE), on the west bank of the Missouri River at river mile (RM) 532-5. The Village of Brownville,

NE is located approximately 2.25 miles northwest of the site and Lincoln. NE, is located

approximately 60 miles west northwest of the site. As part of the review of the license renewal

application (LRA), the NRC is preparing a Supplemental Environmental Impact Statement

(SEIS) under the provisions of Title '10 of the Code of Federal Regulations Part 51 (10 CFR Part

51), the NRC's regulation that implements the National Environmental Policy Act (NEPA) of

1969. The SEIS includes an analysis of pertinent environmental issues, including endangered

or threatened species and impacts to fish and wildlife. This letter is being submitted under the

provisions of the Endangered Species Act of 1973, as amended, and the Fish and Wildlife

Coordination Act of 1934, as amended.

The proposed action would include the use and continued maintenance of existing plant

facilities and transmission lines. The site surroundings are predominantly agricultural with zero

population within a one-half mile radius of the plant. Brownville. NE. is the nearest developed

community, at a distance of approximately 2.25 miles from the site, with a 2005 population of

approximately 137. The largest town with industry within 10 miles is Auburn, Nebraska, located

to the west, with a 2005 population of approximately 3,076. Maryville, Missouri, located

approximately 40 miles east of the plant, is the largest community within 50 miles and had a

2005 population of approximately 10,567.

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

is also the major activity for the rest of the area within a 50-mile radius as well. The site is

located on a constructional plain bordering the west bank of the Missouri River. It is situated on

the first bottomland of the broad, nearly level, flood plain, which is approximately six miles wide

at the site. The U.S, Army Corp of Engineer (USACE) has stabilized the channel by use of pile

dikes and bank protection. Earthen levees run parallel with the Missouri River, on both sides of

the river.

July 2010 D-13 NUREG-1437, Supplement 41
Appendix D

J- Cochnar - 2-

The station site grade level of 903 feet above mean sea level (AMSL) has been raised 13 feet

above the natural grade level of 890 feet AMSL, in order to bring final grade one foot above the

existing 902 feet AMSL levee constructed by the USACE. The site slopes generally east, with

surface drainage toward the Missouri River.

The CNS property includes 239 acres on the east side of the Missouri River in Atchison County,

Missouri, the most northwestern county in Missouri, bounded on the west by the Missouri River.

The eastern bank of the Missouri River is chiefly a densely forested land similar to the unfarmable bluffs that run parallel to the Missouri River. To the west there are bluffs that peak at

" 1100 feet. but average 1,000 feet along the stretch of river from Brownville to Nemaha. Beyond

the bluffs, the land is a gently rolling flood plain.

There are several Native American lands within a 50-mile radius of CNS. These include the

Sac and Fox Reservation. Iowa Reservation, and Kickapoo Reservation. There are also several

local and county parks, golf courses, forest lands, wildlife areas, and other public recreation

lands within a 50-mile radius of CNS.

Flow of the Missouri River at CNS is largely controlled by the Gavins Point Dam located about

200 miles upstream in Yankton, South Dakota. The flow is highly channelized with swift flows

and heavy sediment transport. Wing dams are located on the Missouri side of the river near

CNS to force the flow into a central channel.

The USACE constructed and operates six of the seven mainstem dams on the Missouri River:

the U.S. Bureau of Reclamation operates the seventh, Canyon Ferry Dam, east of Helena.

Montana. When the USACE constructed five of the Missouri River mainstem dams in the '1950s

and 1960s after passage of the Pick-Sloan Plan, goals for dam and reservoir operations were to

reduce flood damages, enhance navigation, generate hydroelectric power, and store water for

irrigation.

Missouri River reservoirs and river segments presently contain populations of exotic fishes,

including cisco, several salmon and trout species, and several Asian carp species. Some of

these species have contributed to the development of economically important recreational

fisheries.

CNS cooling is classified as a circulating water system that uses water taken from the Missouri

River. Water passes through trash racks and then through traveling screens. A major portion of

the flow is directed to the circulating water pumps, which deliver water to the main condenser.

A smaller portion of the Missouri River water is used by the service water pumps. The

discharge from the condenser and from the service water system is returned via the discharge

channel to the river. The circulating water intake structure (CWIS) is located on the west

shoreline. In front of the CWIS is a guide wall and submerged weir constructed of steel sheet

NUREG-1437, Supplement 41 D-14 July 2010
Appendix D

J. Cochnar - 3-

piling that runs parallel to and at distance of 14.25 feet (ft) from the face of the intake. The

purpose of the guide wall and weir is to reduce the sediment input to the CWIS. It accomplishes

this by forcing bed load and other material contained in the river to flow around and past the

CWIS.

Four circulating water pumps provide the circulating water for the facility. Each pump can draw

159t000 gpm. The pump design water level is at El. 875.0 ft, with a minimum submergence

level at El. 8135.0 ft. There are four service water pumps providing a combined flow of 32,000

gpm. Velocities in the intake structure are 1 .1 ft.,sec under the curtain wall, 0.7 ft/sec at the

trash racks, and approximately 2.0 ft/sec at the traveling water screens. These velocities were

calculated at low water levels (El. 874.5 ft) and maximum circulating water pump flow (1 59000

gpm per pump). The flow is highly channelized with swift flows and heavy sediment transport.

Turning vanes and a low sheetpile wall are located in front of the intake bays. Wing dams are

located on the Missouri side of the river to force the flow into a central channel. During the

winter, ice is very common on the river. To prevent ice damage, ice deflector barges are

installed during the winter months. To prevent the formation of frazzle ice, some of the main

condenser discharge water (25-30 percent) is re-circulated through the ice control tunnel and

released in front of the trash rack within the CWIS while the remaining water is discharged

about 1,300 ft downstream of the intake via a discharge canal.

The chlorination system connection is located on the common inlet to Screen Wash Pump A

and B from the service water system. Bacteria that occur naturally in the Missouri River may

contribute to the growth of biological film fouling of the main condenser tubes. The station is

proceeding with a study to determine if routine chemical injection (chlorine, bromine, etc.) will be

effective in eliminating the microbiological film on the interior walls of the condenser tubes.

Water leaves the pump house and circulates through the condenser, where it is collected from

the condenser section through a large manifold. It then travels through concrete tunnels to the

seal well structure and the discharge canal. At the rated circulating water flow of 631,000 gpm

through the condenser and at design power on the turbine generator, the temperature rise

through the condenser is approximately I7.8'F. From the seal well and gate control structure,

the water is directed into a discharge canal that is approximately 1.000 ft long- it then enters the

river at a slight angle. The velocity of discharge is about 1 fps during average water levels of

879.4 ft AMSL and 35,000 cfs flow, and increases to about 2.5 fps as the water surface

elevation is reduced to 874.5 ft AMSL and flows near 11,000 cfs.

The transmission lines which were constructed to connect CNS to the grid for purposes of

power distribution includes (1) NPPD line TL3501 (345 kV energized in August 1969) 63.6 miles

in length from CNS to the Mark T. Moore substation near Hallam, Nebraska, (2) NPPD line

TL3502 (345 kV energized in July 1970) 82.6 miles in length from the Mark T. Moore substation

to the Grand Island substation, and (3) Omaha Public Power District (OPPD) Line "60," which

was already planned when CNS was constructed, (4) NPPD line TL3504 was energized as a

345 kV line in July 1970 and is 0.64 miles in length from CNS to the center of the Missouri

River.

July 2010 D-15 NUREG-1437, Supplement 41
Appendix D

J. Cochnar -4-

The transmission line "K-Towers" aTe supported by two wooden poles that are 26 feet apart.

Therefore. the farming activity adjacent to and under the towers and lines continues essentially

unimpeded with the only land removed from service, being that upon which transmission poles

physically rest. No cultivated land along the transmission route has been removed from service

as a result of rights-of-way, and access for repairs and maintenance is requested on anl

individual basis from each property owner. For the remainder of the transmission line route,

which passes over non-cultivated land, the right-of-way (ROW) is cleared only of woody plants

that have a growth pattern that would cause them to grow into or fall onto the line conductors.

Thereafter, control of these species is maintained; however, all of the natural grasses and low

growing bushy, woody plants are allowed to grow.

There are no densely forested areas on the transmission route, and the land beneath the

transmission lines is allowed to return to its natural state. Steel towers are used for the lines

crossina the Missouri River and in the immediate vicinity of the station. Based on NPPD

clearance practices, the required minimum ground clearance is 29.3 feet.

Provided for your information is the CNS Site Layout (Enclosure 1) and Transmission Line Map

f.Enclosure 2). To support the SEIS preparation process and to ensure compliance with Section

7 of the Endangered Species Act. the NRC requests information on Federally-listed, proposed,

and candidate species and critical habitat that may be in the vicinity of CNS and its associated

transmission line rights-of-way. In addition, please provide any information you consider

appropriate under the provisions of the Fish and Wildlife Coordination Act.

The NRC staff plans to hold two public license renewal and environmental scoping meetings on

February 25, 2009. There will be two sessions, an afternoon and evening session, to

accommodate interested parties. The first session will be held at the Brownville Concert Hall at

126 Atlantic St., Brownville, NE 68321, telephone (402) 825-3331, and will convene at 1:30 p.m.

and will continue until 4:30 p.m., as necessary. The second session will be held at the Auburn

Senior Center at 1101 J St.. Auburn, NE 68305, telephone (402) 274-3420. and will convene at

7:00 p.m., with a repeat of the overview portions of the meeting and will continue until 10:00

p.m., as necessary. In addition, during the week of March 30, the NRC plans to conduct a site

audit. You and your staff are invited to attend both the public meetings and the site audit. Your

office will receive a copy of the draft SEIS along with a request for comments. The anticipated

publication date for the draft SEIS is December 2009.

NUREG-1437, Supplement 41 D-16 July 2010
Appendix D

January 29, 2009

Mr. Mark Miles

State Historic Preservation Officer

Department of Natural Resources

P.O. Box 176

Jefferson City; MO 65102

SUBJECT: COOPER NUCLEAR STATION LICENSE RENEWAL APPLICATION REVIEW

(NEBRASKA PUBLIC POWER DISTRICT - COOPER NUCLEAR STATION

SHPO LOG NUMBER 004-AT-08)

Dear Mr. Miles:

The U.S. Nuclear Regulatory Commission (NRC or the staff) is reviewing an application to

renew the operating license for Cooper Nuclear Station (CNS), which is located in Nemaha

County, Nebraska (NE); on the west bank of the Missouri River at river mile 532.5. The Village

of Brownville, NE is located approximately 2.25 miles northwest of the site. CNS is operated by

the Nebraska Public Power District (NPPD). The application for renewal was submitted by

NPPD by letter dated September 24. 2008. pursuant to Title 10 of the Code of Federal

Regulations Part 54 (10 CFR Part 54).

The NRC has established that, as part of the staffs review of any nuclear power plant license

renewal action, a Supplemental Environmental Impact Statement (SEIS) to its "Generic

Environmental Impact Statement for License Renewal of Nuclear Plants". NUREG-1437, will be

prepared under the provisions of 10 CFR Part 51, the NRC's regulation that implements the

National Environmental Policy Act of 1969 (NEPA). In accordance with 36 CFR 800.8(c), the

SEIS will include analyses of potential impacts to historic and cultural resources.

In the context of the National Historic Preservation Act of 1966, as amended, the NRC staff has

determined that the area of potential effect (APE) for a license renewal action is the area at the

power plant site and its immediate environs that may be impacted by post-license renewal landdisturbing operations or projected refurbishment activities associated with the proposed action.

The APE may extend beyond the immediate environs in those instances where post-license

renewal land-disturbing operations or projected refurbishment activities specifically related to

license renewal may potentialty have an effect on known or proposed historic sites. This

determination is made irrespective of ownership or control of the lands of interest.

On February 25, 2009, the NRC will conduct two public license renewal and environmental

scoping meetings. The first session will be held at the Brownville Concert Hall at 126 Atlantic

St.. Brownville, NE 68321, telephone (402) 825-3331, and will convene at 1:30 p.m. and will

continue until 4:30 p.m., as necessary. The second session will be held at the Auburn Senior

Center at 1101 J St., Auburn, NE 68305, telephone (402) 274-3420, and will convene at 7:00

p.m., with a repeat of the overview portions of the meeting and will continue until 10:00 p.m., as

necessary. You and your staff are invited to attend. Your office will receive a copy of the draft

SEIS along with a request for comments. The staff expects to publish the draft SEIS in

December 2009.

July 2010 D-17 NUREG-1437, Supplement 41
Appendix D

M. Miles -2-

If you have any questions concerning the NRC staffs review of this license renewal application,

please contact NRC's Project Managers, Tam Tran, by telephone, 1-800-368-5642, extension

3617, or by email to the NRC at tam.tran(&nrc.qov, or Emmanuel Sayoc, by telephone,

1-800-368-5642, extension 1924. or by email to the NRC at emmanuel.sayocdnrc.gov.

Sincerely,

IRA!

David Pelton, Branch Chief

Projects Branch 1

Division of License Renewal

Office of Nuclear Reactor Regulation

Docket No. 50-298

cc: See next page

NUREG-1437, Supplement 41 D-1 8 July 2010
Appendix D

NEBRASKA STATE HISTORICAL SOCIETY

1,q0 R STREET, P.oRqX 32554, LINCOLN. NE 6850tt-255i4

(402) 471-3274 ra (402.) 71-300t -14.9433-6747 WWiw3w kbA~bitnfy,4ir Michael J. Smith, Director/CEO

February 2, 2009

Mr. David L. Pelion, Chief

Division of License Renewal

U.S. Nuclear Rogulatory Commission

Washington, D.C. 20555-0001

RE: Cooper Nuclear Station license renewal HIP# 0801-050-001

Dear Mr. Pelton:

Thank you for submitting the referenced project for our review and comment. Our comment on

this project and its potential to affect historic properties is required by Section 106 of the

National Historic Preservation Act of 1966, as amended, and implementing regulations 36 CFR

Part 800. Before we are able to adequately review the proposed Area of Potential Effect (APE)

for this project for its potential to affect historic properties, we require the following information:

a A map clearly defining the boundaries of the APE

Please submit this information to: Bob Puschendorf, Nebraska State Historic Preservation

Office, P.O. Box 82554, 1420 P Street, Lincoln, NE 68501-2554.

Sincerely,

Review and Compliance Coordinator

Nebraska State Historc Preservation Office

Cc: Tam Tran, NRC

Emmanuel Sayoc, NRC

Steward B. Minahan, Chief Nuclear Officer, Cooper Nuclear Station

July 2010 D-19 NUREG-1437, Supplement 41
Appendix D

February 04, 2009

Ms. Ann Salomon Bleed. Director

Nebraska Deoartment of Natural Resources

301 Centennial Mall South

P.O. Box 94676

Lincoln, NE 68509-4676

SUBJECT: REQUEST FOR LIST OF PROTECTED SPECIES WITHIN THE AREA UNDER

EVALUATION FOR THE COOPER NUCLEAR STATION. UNIT 1 LICENSE

RENEWAL APPLICATION REVIEW

Dear Ms. Bleed:

The U.S. Nuclear Regulatory Commission (NRC or the staff) is reviewing an application

submitted by the Nebraska Public Power District (NPPD) for the renewal of the operating

licerise for Cooper Nuclear Station (CNS) Unit 1. Cooper Nuclear Station (CNS), located in

Nemaha County, Nebraska (NE), on the west bank of the Missouri River at river mile fRM)

532.5. The Village of Brownville, NE is located approximately 2.25 miles northwest of the site.

and Lincoln, N-, is located approximately 650 miles west northwest of the site. As part of the

review of the license renewal application (LRA), the NRC is preDaring a Suoplemental

Environmental Impact Statement (SEIS) under the provisions of Title 10 of t"he Code of Federal

Reguiations Part 51 (10 CFR Part 51), the NRC's regulation that implements the National

Environmental Policy Act (NEPA) of 1969. The SEIS includes an analysis of pertinent

environmental issues, including endangered or threatened species and impacts to fish and

wildlife. This letter is being submitted under the provisions of the Endangered Species Act of

1973, as amended, and the Fish and Wildlife Coordination Act of 1934, as amended.

The site surroundings are predominantly agricultural with zero population within a one-half mile

radius of the plant. Brownville, NE, is the nearest developed community, at a distance of

approximately 2.25 miles from the site, and a 2005 population of approximately 137. The

largest town with industry within 10 miles is Auburn, NE, located to the west, with a 2005

population of approximately 3,076. Maryville, Missouri, located approximately 40 miles east of

the plant, is the largest community within 50 miles and had a 2005 population of approximately

10,567.

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

is the major activity for the rest of the area within a 50-mile radius as well. The site is located on

a constructional plain bordering the west bank of the Missouri River. It is situated on the first

bottomland of the broad, nearly level, flood plain, which is approximately six miles wide at the

site. The U.S. Am'y Corps of Engineers (USACE) has stabilized the channel by use of pile

dikes and bank protection. Earthen levees run parallel with the Missouri River, on both sides of

the river.

NUREG-1437, Supplement 41 D-20 July 2010
Appendix D

A. Bleed -2-

The station site grade level of 903 feet above rnean sea level (AMSL) has been raised '13 feet

above the natural grade level of 890 feet AMSL. in order to bring final grade one foot above the

existing 902 feet AMSL levee constructed by the USACE. The site slopes generally east, with

surface drainage toward the Missouri River.

The CNS property includes 239 acres on the east side of the Missouri River in Atchison County,

Missouri, the most northwestern county in Missouri, bounded on the west by the Missouri River.

The eastern bank of the Missouri River is chiefly a densely forested land similar to the unfarmable bluff s that run parallel to the Missouri River. To the west there are bluffs that peak at

1,100 feet. but average 1,000 feet along the stretch of river from Brownville to Nemaha Beyond

the bluffs, the land is a gently rolling flood plain.

There are several Native American lands within a 50-mile radius of CNS. These include the

Sac and Fox Reservation, Iowa Reservation, and Kickapoo Reservation. There are also several

local and county parks, golf courses, forest lands, wildlife areas, and other public recreation

lands within a 50-mile radius of CNS.

Flow of the MAissouri River at CNS is largely controlled by the Gavins Point Dam located about

200 miles upstream in Yankton, South Dakota. The flow is highly channelized with swift flows

and heavy sediment transport. Wing dams are located on the Missouri side of the river near

CNS to force the flow into a central channel.

The USACE constructed and operates six of the seven mainstem dams on the Missouri River:

the U.S. Bureau of Reclamation operates the seventh, Canyon Ferry Dam, east of Helena,

Montana. When the USACE constructed five of the Missouri River mainstem dams in the 1950s

and '1960s after passage of the Pick-Sloan Plan. goals for dam and reservoir operations were to

reduce flood damages, enhance navigation, generate hydroelectric power, and store water for

irrigation.

Missouri River reservoirs and river segments presently contain populations of exotic fishes,

including cisco, several salmon and trout species, and several Asian carp species. Some of

these species have contributed to the development of economically important recreational

fisheries.

CNS cooling is classified as a circulating water system that uses water taken from the Missouri

River. Water passes through trash racks and then through traveling screens. A major portion of

the flow is directed to the circulating water pumps, which deliver water to the main condenser. A

smaller portion of the Missouri River water is used by the service water pumps. The discharge

from the condenser and from the service water system is returned via the discharge channel to

the river. The circulating water intake structure (CWIS) is located on the west shoreline. In front

July 2010 D-21 NUREG-1437, Supplement 41
Appendix D

A. Bleed -3-

of the CWIS is a guide wall and submerged weir constructed of steel sheet piling that runs

parallel to and at distance of '14.25 feet (ft) from the face of the intake.

Four circulating water pumps provide the circulating water for the facility. Each pump can draw

159,000 gpm. The pump design water level is at El. 875.0 ft, with a minimum submergence

level at El. 865.0 ft. There are four service water pumps providing a combined flow of 32,000

gpm. Velocities in the intake structure are 1 .1 ftisec under the curtain wall, 0-7 ft/sec at the

trash racks, and approximately 2.0 ft/sec at the traveling water screens. These velocities were

calculated at low water levels (El. 874.5 ft) and maximum circulating water pump flow (159.000

gpm per pump). The flow is highly channelized with swift flows and heavy sediment transport.

To minimize the effects of sedimentation on the intake, turning vanes and a low sheetpile wall

are located in front of the intake bays. Wing dams are located on the Missouri side of the river to

force the flow into a central channel. During the winter, ice is very common on the river. To

prevent ice damage, ice deflector barges are installed during the winter months. To prevent the

formation of frazzle ice, some of the main condenser discharge water (25-30 percent) is recirculated through the ice control tunnel and released in front of the trash rack within the OWIS

while the remaining water is discharged about 1,300 ft downstream of the intake via a discharge

canal.

The chlorination system connection is located on the common inlet to Screen Wash Pump A

and B from the service water system. Bacteria that occur naturally in the Missouri River may

contribute to the growth of biological film fouling of the main condenser tubes. The station is

proceeding with a study to determine if routine chemical injection (chlorine, bromine, etc.) will be

effective, in eliminating the microbiological film on the interior walls of the condenser tubes.

Water leaves the pump house and circulates through the condenser, where it is collected from

the condenser section through a large manifold. It then travels through concrete tunnels to the

seal well structure and the discharge canal. At the rated circulating water flow of 631 ;000 gpm

through the condenser and at design power on the turbine generator, the temperature rise

through the condenser is approximately 17.8°F. From the seal well and gate control structure,

the water is directed into a discharge canal that is approximately 1,000 ft long; it then enters the

river at a slight angle. The velocity of discharge is about 1 fps during average water levels of

879.4 ft AMSL and 35.000 cfs flow, and increases to about 2.5 fps as the water surface

elevation is reduced to 874.5 ft AMSL and flows near 11 000 cfs.

The transmission lines which were constructed to connect CNS to the grid for purposes of

power distribution includes (1) NPPD line TL3501 (345 kV energized in August 1969) 63.6 miles

in length from CNS to the Mark T. Moore substation near Hallam, Nebraska, (2) NPPD line

TL3502 (345 kV energized in July '1970) 82.6 miles in length from the Mark T. Moore substation

to the Grand Island substation, (3) Omaha Public Power District (OPPD) Line "60," which was

already planned when CNS was constructed, and (4) NPPD line TL3504 was energized as a

345 kV line in July 1970 and is 0.64 miles in length from CNS to the center of the Missouri

River.

NUREG-1437, Supplement 41 D-22 July 2010
Appendix D

A. Bleed -4-

The transmission line "K-Towers" are supported by two wooden poles that are 26 feet apart.

Therefore, the farming activity adjacent to and under the towers and lines continues essentially

unimpeded with the only land removed from service being that upon which transmission poles

physically rest. No cultivated land along the transmission route has been removed from service

as a result of rights-of-way, and access for repairs and maintenance is requested on an

individual basis from each property owner. For the remainder of the transmission line route,

which passes over non-cultivated land, the right-of-way (ROW) is cleared only of woody plants

that have a growth pattern that would cause them to grow into or fall onto the line conductors.

Thereafter, control of these species is maintained: however, all of the natural grasses and low

growing bushy, woody plants are allowed to grow.

There are no densely forested areas on the transmission route, and the land beneath the

transmission lines is allowed to return to its natural state. Steel towers are used for the lines

crossing the Missouri River and in the immediate vicinity of the station. Based on NPPD

clearance practices, the required minimum ground clearance is 29.3 feet.

Provided for your information is the CNS Site Layout (Enclosure 'I) and Transmission Line Map

(Enclosure 2). To support the SEIS preparation process and to ensure compliance with Section

7 of the Endangered Species Act, the NRC requests information on State-listed, proposed, and

candidate species and critical habitat that may be in the vicinity of CNS and its associated

transmission line rights-of-way. In addition, please provide any information you consider

appropriate under the provisions of the Fish and Wildlife Coordination Act.

The NRC staff plans to hold two public license renewal and environmental scoping meetings on

February 25, 2009. There will be two sessions, an afternoon and evening session, to

accommodate interested parties. The first session will be held at the Brownville Concert Hall at

126 Atlantic St., Brownville, NE 68321l telephone (402) 825-3331, and will convene at 1230 p.m.

and will continue until 4:30 p.m., as necessary. The second session will be held at the Auburn

Senior Center at 1 101 J St.. Auburn. NE 68305, telephone (402) 274 3420, and will convene at

7:00 p.m., with a repeat of the overview portions of the meeting and will continue until 10:00

p.m., as necessary. In addition, during the week of March 30, 2009, the NRC plans to conduct

a site audit. YOU and your staff are invited to attend both the public meetings and the site audit.

Your office will receive a copy of the draft SEIS along with a request for comments.

July 2010 D-23 NUREG-1437, Supplement 41
Appendix D

February 04, 2009

Colonel David C. Press, Commander

U.S. Army Corps of Engineers

Omaha District

106 South 15th Street

Omaha, NE 68,102-16-18

SUBJECT: COOPER NUCLEAR STATION LICENSE RENEWAL APPLICATION

REVIEW

Dear Colonel Press:

The U.S. Nuclear Regulatory Commission (NRC(- or the staff) is reviewing an appiication

submitted by Nebraska Public Power District (NPPD), for the renewal of the operating license

for Cooper Nuclear Station (CNS). which is located in Nemaha County, Nebraska (NE), on the

west bank of thle Missouri River at river mile 532.5. The Villacle of Brownville, NE is located

approximately 2.25 miles northwest of the site. and Lincoln, NE is located approximately G0

miles west northwest of the site. As part of the review of the license renewal application (LRA),

the NRC is preparing a Supplemental Environmental Impact Statement (SEIS) under the

provisions of Title '10 of the Code of Federal Regulations Part 51 (10 CFR Part 51), the NRC's

regulation that implements the National Environmental Policy Act (NEPA) of '1969.

CNS is requesting the renewal of its operating license for a period of 20 years beyond the

expiration of the current license term, renewing the license until January '18, 2034. The

proposed action would include the use and continued maintenance of existing plant facilities

and transmission lines; CNS does not plan to construct or alter any facilities associated with the

plant during the period of extended operation.

The NRC staff plans to hold two identical public meetings covering the license renewal and

environmental scoping process on February 25, 2009. The first session will be to be held at the

Brownville Concert Hall at 126 Atlantic St.. Brownville, NE 68321 telephone 402-825-3331, and

will convene at 1:30 p.m. and will continue until 4:30 p.m., as necessary. The second session

will be held at the Auburn Senior Center at 1 "101 J St., Auburn, NE 68305, telephone

402-274 3420, and will convene at 7:00 p.m., with a repeat of the overview portions of tile

meeting and will continue until 10:00 p.m., as necessary. In addition, during the week of

March 30, 2009 the NRC plans to conduct a site audit. You and your staff are invited to attend

both the site audit and the public meetings. Your office will receive a copy of the draft SEIS

along with a request for comments. The anticipated publication date for the draft SEIS is

December 2009.

NUREG-1437, Supplement 41 D-24 July 2010
Appendix D

D, Press -2-

If you have any questions concerning the NRC staff's review of this license renewal application,

please contact NRC's Project Managers. Tarn Tran, by telephone, 1-800-368-5642. extension

3617, or by email to the NRC at tarntran(d-,,nrc.qov. or Emmanuel Sayoc, by telephone,

1-800-368-5642. extension 1924, or by email to the NRC at emranuel.sayoc)nrc..qov.

Sincerely,

IRA!

David L Pelton, Chief

Projects Branch 1

Division of License Renewal

Office of Nuclear Reactor Regulation

Docket No. 50-298

cc wio encl.: See next page

July 2010 D-25 NUREG-1437, Supplement 41
Appendix D

February 04, 2009

Adrian Pushetonequa, Chairman

Sac and Fox Tribe of the Mississippi in Iowa

349 Meskwaki Road

Tama, IA 52339-9629

SUBJECT: REQUEST FOR SCOPING COMMENTS CONCERNING THE COOPER

NUCLEAR STATION, UNIT 1 LICENSE RENEWAL APPLICATION REVIEW

Dear Mr. Pushetonequa:

The U.S. Nuclear Regulatory Commission (NRC or the staff) has recently received an

application from Nebraska Public Power District for the renewal of the operating license for the

Cooper Nuclear Station (CNS) Unit 1. located in Nemaha County, Nebraska. The NRC is in the

initial stages of developing a Supplemental Environmental Impact Statement to the Generic

Environmental Impact Statement (GEIS), which will document the impacts associated with the

license renewal of the CNS Unit 1. We would like your assistance in our review by providing

input to the NRC's environmental review scoping process. The NRC's process includes an

opportunity for public and inter-governmental participation in the environmental review. We

want to ensure that you are aware of our efforts pursuant to Title 10 of the Code of Federal

Regulations Part 51. Section 51.28(b). In addition, as outlined in 36 CFR 800.8(c), the NRC

plans to coordinate compliance with Section 106 of the National Historic Preservation Act of

1966 through the requirements of the National Environmental Policy Act of 1969.

Under NRC regulations, the original operating license for a nuclear power plant is issued for up

to 40 years. The license may be renewed for up to an additional 20 years if NRC requirements

are met. The current operating license for CNS Unit 1 will expire in January 18, 2014. Provided

for your information is the CNS Unit 1 Site Layout (Enclosure 1) and Transmission Line Map

(Enclosure 2). Additionally, attached you will find a compact disk containing copies of the

license renewal application and the GELS.

The GElS considered the environmental impacts of renewing nuclear power plant operating

licenses for a 20-year period on all currently operating sites. In the GElS the NRC staff

identified 92 environmental issues and developed generic conclusions related to environmental

impacts for 69 of these issues that apply to all plants or to plants with specific design or site

characteristics. For the remaining 23 issues, plant-specific analyses will be documented in a

supplement to the GELS.

A Supplemental Environmental Impact Statement will be prepared for CNS Unit 1 to document

the staff's review of environmental impacts related to terrestrial ecology, aquatic ecology,

hydrology, cultural resources, and socioeconomic issues (among others), and will contain a

recommendation regarding the environmental acceptability of the license renewal action.

NUREG-1437, Supplement 41 D-26 July 2010
Appendix D

-2-

Please submit any comments that you may have to offer on the scope of the environmental

review by March 27, 2009. Written comments should be submitted by mail to the Chief, Rules

and Directives Branch, Division of Administrative Services, Mail Stop T-6D59, U.S. Nuclear

Regulatory Commission, Washington D.C. 20555-0001. Electronic comments may be

submitted to the NRC by e-mail at CooperEIS(dnrc.gov. At the conclusion of the scoping

process, the NRC staff will prepare a summary of the significant issues identified and the

conclusions reached, and mail a copy to you.

To accommodate interested members of the public, the NRC will hold two public scoping

meetings for the CNS Unit 1 license renewal supplement to the GEIS on February 25, 2008.

The first session will be held in the afternoon at the Brownville Concert Hall at 126 Atlantic

Street, Brownville, NE 68321, telephone (402) 825-3331. The second session, covering the

same subjects will be held in the evening at the Auburn Senior Center at 1101 J Street, Auburn,

NE 68305, telephone (402) 274 3420. Additionally, the NRC staff will host informal discussions

one hour before the start of each session. You and your staff are invited to attend the public

meetings.

The CNS Unit 1 license renewal application and the GElS are available on the internet at

httppolwwlw.nrc.gov/reactorsioperatin/gIicensinq'renewallapplications/coooer.html. in addition,

the Auburn Memorial Library, 1810 Courthouse Avenue, Auburn, NE 68305, telephone

(402) 274-4023, has agreed to make the license renewal application and the GElS available for

public inspection.

The staff expects to publish the draft Supplemental Environmental Impact Statement in

December 2009. A copy of the document will be sent to you for your review and comment. The

NRC will hold another set of public meetings in the site vicinity to solicit comments on the draft

Supplemental Environmental Impact Statement. After consideration of public comments

received, the NRC will prepare a final Supplemental Environmental Impact Statement, which is

scheduled to be issued in July 2010.

The NRC is sending this letter to the tribal contacts for the following Federally-recognized tribes:

Prairie Band of Potawatomi Indians, Iowa Tribe of Kansas and Nebraska, Iowa Tribe of

Oklahoma, Kickapoo Tribe in Kansas, Otoe-Missouria Tribe of Indians, Omaha Tribe of

Nebraska, Sac and Fox Nation of Missouri, Sac and Fox Nation of Oklahoma, and the Sac and

Fox Tribe of Mississippi in Iowa.

If you need additional information regarding the license renewal review process, please contact

Tam Tran, by telephone, '1-800-368-5642, extension 3617, or by e-mail at tam tranc)nrc..qov. or

July 2010 D-27 NUREG-1437, Supplement 41
Appendix D

-3-

Emmanuel Sayoc, by telephone, 1-800-368-5642, extension 1924, or by e-mail at

emmanuelsayocP~nrc.qov.

Sincerely,

IRA!

David L. Pelton, Chief

Projects Branch 1

Division of License Renewal

Office of Nuclear Reactor Regulation

Docket No. 50-298

Enclosures:

I. Site Layout

2. Transmission Line Map

cc w/encls: See next page

NUREG-1437, Supplement 41 D-28 July 2010
Appendix D

Cooper Nuclear Station Site Map - 6 Mile Radius

ENCLOSURE 1

July 2010 D-29 NUREG-1437, Supplement 41
Appendix D

I Transmission Lines I

Lncln '.E 1

CNS

Cooper Nuclear Station Transmission Lines

ENCLOSURE 2

NUREG-1437, Supplement 41 D-30 July 2010
Appendix D

Emmanuel Sayoc

From: CooperEIS Resource

Sent: Thursday. April 16, 2009 1:39 PM

To: Ernnmanual Sayoc

Subject: FW: Scoping Comments for Relicensing of Cooper Nuclear Staticn, Brownville. NE

---- Original Message .....

From: Shepard.Larry@epamail.epa.gov (mailto:Shepard.Larry@epamail.epa.gov]

Sent: Friday, March 27, 2009 4:59 PM

To: CooperEIS Resource

Cc: Cothem.Joe@epamail.epa.gov; Hooper.CharlesA@epamaiI.epa.gov; Dunn.John@epamail.epa.gov:

Lancaster. Kis@epamail.epa-gov

Subject: Scoping Comments for Relicensing of Cooper Nuclear Station, Brownville, NE

RE: Notice of Intent to Prepare an Environmental Impact Statement and

Conduct Scoping Process for Cooper Nuclear Station; Federal Register

Volume 74, No. 15, January 26,2009, page 4476.

Thank you for the opportunity to provide scoping comments on the

proposed relicensing of Cooper Nuclear Station (CNS), in support of the

U.S. Nuclear Regulatory Commission's (NRC) preparation of an

Environmental Impact Statement (EIS). EPA reviewed this project in

accordance with the National Environmental Policy Act (NEPA) and Section

309 of the Clean Air Act. We request that, in the future, the NRC

provide an adequate period of time after conducting site audits for the

submission of scoping comments by state or federal agencies. In this

instance, scoping comments are to be submitted prior to the NRC site

audit for this project.

Pleased consider the following comments during the EIS development

process.

Radiation - Given the uncertainty involved with licensing the Yucca

Mountain Nevada facility and the extremely long time-frames needed to

secure Congressional approval and complete site preparation for any

possible alternative permanent site for the disposal of spent nuclear

fuel, all utilities planning on extending operation of existing

nuclear units should consider contingencies for tong-term storage of

waste on-site.

Water Quality - The current CNS site has an existing infrastructure,

which includes intake and discharge structures, The source of water

for the plant is the Missouri River. Potential impacts to plant

operation associated with available river flow, particularly during

periods of sustained low flow, should be thoroughly described in the

draft EIS. The draft EIS should articulate the assurance of a

Jong-term water supply (i.e., greater than 20 years) for the

operation of the reactor, This analysis should address contingencies

created by changing regional climate and potential future changes in

the operation of the river by the Army Corps of Engineers (i.e., flow

July 2010 D-31 NUREG-1437, Supplement 41
Appendix D

releases), The current facility Is covered by a National Pollutant

Discharge Elimination System (NPDES) permit issued by the Nebraska

Department of Environmental Quality (NDEQ). New studies and analyses

performed in support of the most recent permit application (e.g.,

thermal and chemical discharges) should be included in the draft EIS.

The draft EIS should also completely discuss issues associated with

entrainment arnd impingement of aquatic organisms (i.e., Section 316b

of the Clean Water Act) and include alternatives to the present

intake design. From a review of the Environmental Report, it is

apparent that there is a great deal of information available

regarding the impact of plant operation on the river ecosystemHowever, we generally caution that these studies are 30 years old and

the draft EIS should clearly articulate whether these data are

representative of current river condition and ecological impact. We

would expect the NRC to provide both its reasoning and data

supporting that additional and more recent research is not required

to adequately document current impacts.

The draft EIS should thoroughly characterize past contamination

associated with the operation of CNS, particularly source and fate of

tritium in the system, and document current condition of surface

water and groundwater upstream and downstream from the site.

Environmental Management System - The Council on Environmental

Quality (CEO) published "Aligning NEPA processes with Environmental

management Systems-A Guide for NEPA and EMS Practitioners- to improve

NEPA implementation and environmental sustainability goals in NEPA

and Executive Order 13423. The NEPA document should discuss EMS as

appropriate.

Larry Shepard

NEPA Team/Interstate Waters

US EPA Region 7

913-551-7441

NUREG-1437, Supplement 41 D-32 July 2010
Appendix D

Richard Bulavinetz

From: Simpson, rachel [rachel.simpson@nebraska.govi

Sent: Friday, May 08, 2009 4:11 PM

To: Richard Bulavinetz

Subject: RE: Cooper Nuclear Station (CNS) - T & E: & List of Species of Concern

Attaohrriontt: NNHP - species by county list for selected Nebraska counties-xis

Dear Mr. Bulavinetz.

Thank you for your inquiry regarding information our program has on species which potentially occur in the

following counties: Nemaha County. Johnson County, Gage County, Lancaster County, Saline County,

Fillmore County, York County, Hamilton County, and Merrick County.

Attached is the information you requested. Please don't hesitate to contact me if you have any questions about

the interpretation of the data or would like additional information.

Sincerely,

Rachel

Rachel Simpson

Data Manager

Nebraska Natural Heritage Program

Nebraska Game and Parks Commission

2200 N. 33rd St.

Lincoln, NE 68503

rachel,.impsontnebraska.Qov

402-471-5427

From: Schneider, Rick

Sent: Thursday, April 30, 2009 2:56 PM

To: Simpson, rachel

Cc: Richard. bulavwnetz(_nrc.go

Subject: FW: Cooper Nuclear Station (CNS) - T & E; & List of Species of Concern

Rachel,

Could you send Richard a list of species, by county (see list below), for which we have records in the

database. For each species, list the federal and state status, Legacy status, and species in need of

conservation status. Also, could you include on the list those state or federally listed species which may occur

in the county, even though we currently have no records. Richard is with a federal agency so there will be no

charge for the data request.

Let me know if you have questions or you could contact Richard.

Thanks.

Rick Schneider

CoordinatortEcologist

NuljrasKa Natural Heritage Program

Nebraska Game and Parks Commission

2200 N. 33rd St.

Lincoln, NE 05503

Rick-SchneiderPmnebraska.gov

July 2010 D-33 NUREG-1437, Supplement 41
Appendix D

402-471-5569 Please note new email address

From: Richard Bulavinetz [Richard. Bulavinetz@nrc.gov]

Sent: Thursday, April 30, 2009 2:40 PM

To: Schneider, Rick

Subject: Cooper Nuclear Station (CNS) - T & E; & List of Species of Concern

Rick:

Per our conversation 2 mins ago - here is my e-mail address,

The counties is question are:

Nemaha County, Johnson County. Gage County, Lancaster County. Saline County, Fillmore County, York

County, Hamilton County,.and Merrick County

Thanks for your help.

Rich

Richard E. Bulavinetz

Aquatic Ecologist

Nuclear Regulatory Commission

Rockville, MD 20852

301-415-3607

301-415-2002 (fax)

richard.bulavinetz(dnrc.qov<maillo:richard.bulavinetz(,nrc.,ov>

< ' i/, < < /< < .) > < '.)m < .") >

2

NUREG-1437, Supplement 41 D-34 July 2010
Appendix D

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NUREG-1437, Supplement 41 D-35 July 2010
Appendix D

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NUREG-1437, Supplement 41 D-36

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July 2010
Appendix D

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July 2010 D-37 NUREG-1437, Supplement 41
Appendix D

Brady, Bennett

From: RobertHarms@fws.gov Sent: Friday, March 19, 2010 5:19 PM

To: Brady, Bennett; Bulavinetz, Richard

Cc: jlcitta@nppd.com; JohnCochnar@tws.gov Subject: Concurrence Cooper Nuclear Station

Attachments: CNS concurrence.pdf

Importance: High

Ms. Brady/Mr. Bulavinetz:

Please make reference to your February 18, 2010, letter requesting that the U.S. Fish and Wildlife Service

(Service) concur with a determination of affect made by the Nuclear Regulatory Commission that continued

operation of the Cooper Nuclear Station for an additional 20 years may affect, but is not likely to adversely

affect the federally endangered pallid sturgeon. The Service has completed its review of the Biological

Assessment included within the Environmental Impact Statement for the proposed project and has determined

that it is satisfaictory. The Service previously provided its concurrence in a letter dated August 26, 2009, which

would conclude section 7 consultation on this matter. It is attached for your use.

(See attached file: CNS concurrence.pdJ)

Bob

Robert R. Harms

Fish and Wildlife Biologist

U.S. Fish and Wildlife Service

203 West Second Street

Grand Island, Nebraska 68801

Phone: 308-382-6468, Extension 17

Fax: 308-384-8835

robert harms(a-,fws., ov

NUREG-1437, Supplement 41 D-38 July 2010
Appendix D

United States Department of the Interior

FISH AND WILDLIFE SERVICE

Ecological Scrvices

Nebraska Fidd Oficc

203 West S•coad Suect

Gmnd Island, Ndeska 68801

August 26, 2009

Mr, Joe Citta

Corporate Environmental Manager

Nebraska Public Power District

1414 15"' Street

Columbus, NE 68801

RE: Cooper Nuclear Station License Renewal, Nebraska Public Power District

Dear Mr. Citta:

This is in response to your August 25, 2009, letter with an enclosed Memorandum of

Understanding and Restrictive Covenant for Conservation. Both enclosures have been

signed and executed and demonstrate the Nebraska Public Power District (NPPD) and

Nuclear Regulatory Commission (NRC) intention to offset adverse affects to federally

listed species resulting from the proposed Cooper Nuclear Station License Renewal.

After reviewing your August 25 letter, the U.S. Fish and Wildlife Service (Service) has

concluded that it concurs with the NPPD and NRC determination that the proposed

relicensing action is not likely to adversely affect federally listed species or result in the

destruction or adverse modification of federally designated critical habitat.

Please note that the Service may reinitiate consultation if new species become listed or

are proposed to be listed, critical habitat is proposed or designated, or new information

about federally listed species becomes available that previously was not considered

during this consultation. The NPPD and NRC should reinitiate consultation with the

Service if the current relicensing project is modified through a change in scope and/or if

new information becomes available about the project that previously was not considered.

July 2010 D-39 NUREG-1437, Supplement 41
Appendix D

The Service appreciates the opportunity to work cooperatively with the NPPD and NRC

in assuming a shared responsibility for protecting federal trust fish and wildlife resources

in Nebraska, If you have any questions or require technical assistance, please do not

hesitatc to contact Mr. Robert Harms within our office at (308)382-6468, extension 17.

Sincerely,

Nebraska Field Supervisor

cc: NGPC; Lincoln, NE (Attn: Frank Albrecht)

Nebraska Land Trust; Lincoln, NE (Attn: Dave Sands)

NUREG-1437, Supplement 41 D-40 July 20.1.0
Appendix D

UNITED STATES

NUCLEAR REGULATORY COMMISSION

WASHINGTON, O.C. 20555-0001

February 18, 2010 A 0 2010

Mr. Michael Smith, Director

Nebraska State Historical Society

P.O. Box 82554

1500 R Street

Lincoln, NE 68501

SUBJECT: COOPER NUCLEAR STATION LICENSE RENEWAL APPLICATION REVIEW

(HP NO. 0801-050-01, DESCRIPTION, NPPD, COOPER NUCLEAR STATION)

Dear Mr. Smith:

The U.S. Nuclear Regulatory Commission (NRC) staff is reviewing an application to renew the

operating license for Cooper Nuclear Station, Unit 1 (CNS-1), which is located In Nemaha

County, Nebraska (NE) on the west side of the Missouri River at river mile 532.5. The Village of

Brownville. NE is located about 2.25 miles northwest of the site. CNS-1 is operated by the

Nebraska Public Power District (NPPD). As part of its review of the proposed action, the NRC

staff has prepared a site-specific Supplemental Environmental Impact Statement (SEIS) to its

"Generic: Environmental Impact Statement for License Renewal of Nuclear Plants," NUREG-

.1437.' The SEIS includes analyses of relevant environmental issues, including potential impacts

to historic, archeological andcultural properties from extended operation and possible

refurbishment activities associated with license renewal. In accordance with our letter to the

Nebraska State and.Historical Society (NSHS) dated JanUary .16, 2009, a copy of the draft

supplement is enclosed. Pursuant to 36 CFR § 800.8(c), we are requesting your comments on

the draft supplement and on our preliminary conclusions regarding historic properties.

As stated in our January 16, 2009 letter, the NRC staff has determined that the area of potential

effect (APE) for a license renewal action is the area at the power plant site and its immediate

environs that may be impacted by post-license renewal land disturbing operation or projected

refurbishment activities associated with the proposed action. The staff views the APE for the

Cooper Nuclear Station, Unit 1, license renewal as including the Cooper Nuclear Station site and

the immediate environs.

The NRC staff has conducted an environmental audit at the site and has reviewed historic and

archaeological records. The NRC staff also contacted 15 federally recognized Native American

Tribes identified as having potential interest in the proposed undertaking. To date, no comments

have been received.

In the context of the National Environmental Policy Act of 1969, under which the draft

supplemental environmental impact statement was prepared, the NRC staff's preliminary

determination, based on review of NSHS files, archaeological surveys, assessments, and other

information, is thatthe potential.impacts of license renewal on historic and archaeological

resources is small.' Under the provisions of the National Historic Preservation Act of 1966, the

NRC-staff's preliminary determination is that no historic properties will be affected by the

proposed action. Further, NPPD has instituted a stop work order within its Cultural Resources

Protection Plan to ensure that proper notification is taken to protectany historic and

archaeological resources should they be discovered. --t"•f

HP'* #. vUi U/V ''

County

Resp. MIDote ti

July 2010 D-41 NUREG-1437, Supplement 41
Appendix D

M. Smith -2-

Please note that the period for public comment expires on May 5, 2010. If your office requires

additional time, or if there are any other questions regarding this correspondence, please have

your representative contact the Environmental Project Manager, Ms. Bennett Brady, at 301-415-

2981.

Sincerely,

Bo Pham, Chief

Projects Branch 1

Division of License Renewal

Office of Nuclear Reactor Regulation

Docket No.: 50-298

Enclosures: As stated

NUREG-1437, Supplement 41 D-42 July 2010
Appendix D

t410

q'~. -

G

4 -c

United States Department of the Interior

OFFICE OF THE SECRETARY

Office of Environmental Policy and Compliance

Denver Federal Center, Building 67, Room 118

Post Office Box 25007 (D-108)

Denver, Colorado 80225-0007

TAKE PRIDE' INAMERICA

April 27, 2010

9043.1

ER 101174

Chief, Rules and Directive iBranch,

Division of Administrative Services, Mail Stop T-6D59

U.S Nuclear Regulatory Commission

Washington, D.C. 20555-0001

Dear Sir or Madam:

The Department of the Interior has reviewed the Draft Generic Environmental Impact -Statement

(EIS), NUREG-1437, Supplement 41, for License Renewal of Nuclear Plants, Cooper Nuclear

Station, Unit I, Nemaha County, Nebraska and has no comments on the document.

Sincerely,

Robert F. Stewart

Regional Environmental Officer

July 2010 D-43 NUREG-1437, Supplement 41
Appendix D

%= ,o UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

÷ PR° REGION 7

901 NORTH 5TH STREET

KANSAS CITY, KANSAS 66101

MAY 0 3 2010

Michael T. Lesar, Chief

Rulemaking and Directives Branch

Division of Administrative Services

Office of Administration TWB-05-BO01 M

U.S. Nuclear Regulatory Commission

Washington, D.C. 20555-0001

Dear Mr. Lesar:

RE: NRC Docket ID: NRC-2008-0617, Review of the Generic Environmental Impact

Statement for License Renewal of Nuclear Plants, NUREG- 1437, Supplement 41,

Regarding Cooper Nuclear Station, Unit 1, Dm-aft Report for Comment

The I J.S. Envi ronmental Protection Agency (EPA) has reviewed the Nuclear Regulatory

Commission's (NRC) Generic Environmental Impact Statement (GElS), Supplement 41, for the

Cooper Nuclear Station, Unit I (Draft Report). Our review is provided pursuant to the National

Environmental Policy Act (NEPA) 42 U.S.C. 4231, Council on Environmental Quality (CEQ)

regulations 40 C.F.R. Parts 1500-1508, and Section 309 of the Clean Air Act (CAA). The GELS,

Supplement 41, was assigned the Council on Environmental Quality (CEQ) number 20100053.

The NRC is proposing to renew the license of the Cooper Nuclear Station (CNS) for an

additional 20 years beyond the expiration date of the facility's current 40-year license which is

January 18, 2014. CNS is owned and operated by Nebraska Public Power District (NPPD). The

facility is located in Nemaha County, Nebraska, on the west bank of the Missouri River at River

Mile 532.5, approximately 60 miles southeast of the city of Lincoln. The 1,359 acre site includes

239 acres on the opposite bank of the Missouri River in Atchison County, Missouri. CNS

structures occupy approximately 55 acres of the total site area. NPPD leases 715 acres in

Nebraska and 234 acres in Missouri for agricultural activities such as farming and livestock. The

55 acres of facility structures include a control/reactor/turbine complex serving a General

Electric boiling water reactor with a generating capacity of 830 megawatts electric, a low-level

radwaste building, off-gas filter building, elevated release point, diesel generator building,

miscellaneous circulating water system structures, independent spent fuel storage installation

(ISFSI), switchyard and other infrastructure. The facility uses the Missouri River for cooling

water in a single-pass cooling water system. CNS utilizes two wells for potable water supply

and three additional wells for service purposes. Wells are finished in alluvial aquifer which is

under immediate influence of the Missouri River. CNS monitors groundwater through sampling

of 14 monitoring wells. CNS does not routinely monitor surface water. CNS discharges process

water to the Missouri River through a discharge canal. It is our understanding that the licensee

NUREG-1437, Supplement 41 D-44 July 2010
Appendix D

does not intend to undertake any facility refurbishment activities as pail of its license renewal

although NPPD is constructing an ISFSI to serve CNS through the renewal term.

Based on our overall review and the level of our comments, EPA has rated the draft

Supplemental Environmental Impact Statement (SEIS) for this project EC-2 (Environmental

Concerns-Insufficient Information). EPA's detailed comments on aspects of the draft SEIS and a

copy of EPA's rating descriptions are provided as enclosures to this letter. This EC-2 rating is

based on the uncertainty of potential impacts to ground and surface waters from radiological

contamination, the effects of future changes to the river environment on CNS operation and the

evaluation of alternatives to CNS license renewal. Specific to the draft SEIS, the curtailed

presentation of radiological data limits the ability of the reader to ascertain its strength. In

addition, the presentation of values regarding many parameters lacks any benchmark against

which the reader could determine significance or trend information which would allow the reader

to understand whether emissions were steady, increasing or decreasing over 36 years of

operation. Further, conclusions reached in the GETS whiclh affect alternative assessment and

selection in the SEIS should be brought forward in some more appropriate form in the SEIS.

As reflected in our enclosed issue-specific comments, we request that the NRC include,

as part of its license renewal for CNS, a requirement to collect data on the aquatic community of

the Missouri River hi the vicinity of CNS which would provide contemporary ecological

information of the area of the river receiving ihmnediate impact from facility operation,

particularly cooling water withdrawals. As stated in our comments during the scoping process

and referenced in the draft SEIS, currently available data regarding the immediate aquatic

environment of CNS is over 30 years old. With continued operation of CNS to 2034, the

conclusions reached by the licensee in its Environmental Report and the NRC in its SElS

regarding "any new and significant information on environmental issues," in the context of the

GElS and 40 CFR 51, Subpart A, Appendix 13, treatment of Category I issues, relying solely on

data collected during initial licensing will become unsupportable. The draft SEIS recognizes the

dynamic, unstable nature of the lower Missouri River. As the federal government continues to

expend significant resources on the recovery of species and restoration of historic river structure

and function, the need for current data on the river in the vicinity of CNS and on possible

impacts related to continued CNS operation and its final disposition is critical to the

comprehensive review required by N EPA.

We appreciate the opportunity to provide comments regarding this project. If you have

any questions or concerns regar'ding this letter, please contact Mr. Joe Cothern, NEPIA Team

Leader, at (913) 551-7148, cotherii.ioefii)epa.gov, or Larry Shepard, at (913) 551-7441,

shepard.larry@epa.gov.

Ronald lrnammerschmidt, Ph.D.

Director

Environmental Services Division

JIuly 2010 D-45 NUREG-1437, Supplement 41
Appendix D

Issue-specific Comments

Purpose and Need

We recognize that the draft SEIS relies upon the GEIS for its project purpose and need statement

and that this statement is generic to all NRC license renewal decisions. However, we believe it

is important to comment on this feature of the draft SEIS as it appears to influence the

thoroughness of the document's evaluation of alternatives. Both the GEIS and the draft SEIS

appear to confuse project 'purpose and need' with the proposed action itself (i.e., issuance of a

renewed license) and, thereby, hinders the full consideration of all reasonable alternatives in this

draft SETS. In a NEPA context, the Qroject purpose and need is to "provide an option that allows

for power generation capability beyond the term of a current nuclear power plant operating

license to meet future system generating needs, which may be determined by State, utility, and,

where authorized, Federal decision-makers" (Section 1.2, Chapter I). The expiration of the

CNS' current operating license and existing and future energy demands in the region is the

'need' to which NRC is "responding [to] in proposing the alternatives including the proposed

action" (40 CFR 1502.13). 'rhe NRC's proposed action is "issuing a renewed license for Cooper

Nuclear Station, Unit I"; however, this is but one alternative to addressing this 'need.' A fuller

statement of project purpose and need is, in our estimation, an important distinction to providing

a full, open review of all possible alternatives to meeting project purpose and need. 'rhis

approach to purpose and need fully implements CEQ requirements regarding NRC's

responsibility to "rigorously explore and objectively evaluate all reasonable alternatives",

"devote substantial treatment to each alternative considered in detail", "include reasonable

alternatives not within the jurisdiction of the lead agency" and "include the alternative of no

action" (40 CFR 1502.14(a), (b), (c) and (d)).

The intent of 40 CFR 1502.14 is difficult to achieve when project purpose and need is so directly

linked to the singular decision whether to reissue an operating license. Any alternative which

does not meet project purpose and need does not appear to be a reasonable or viable alternative

by any measure. Inclusion of a 'no action' alternative within the SEIS is required under CEQ

regulations at 40 CFR 1502.14(d). The draft SEIS states that the *no action' alternative does not

meet the project's purpose and need (Section 8.5). Further, if purpose and need are tied to the

proposed action, none of the alternatives to license renewal will meet project purpose and need

and this contradiction appears to affect the rigor of the evaluation of these alternatives later in the

draft SEIS (40 CFR 1502.14(a) and (b)). The draft SEIS links, throughout the document, the

broad project purpose and need to the NRC's determination whether safety issues or

environmental impacts should preclude license renewal. In simple summation, the NRC will

renew the current license, unless its' analysis reveals significant safety or environmental issues

that would preclude it. That appears to create the impression that the licensing decision is the

project purpose. It would seem that the project purpose and need statement should not preclude

selection of any of the alternatives, including the 'no action' alternative, regardless of the

outcome of the NRC evaluation of the licensee's application for renewal. Regardless of the

outcome of NRC's license renewal decision, the RTS process should inform and support

deliberations by other decision-makers (e.g., "State regulators and utility officials," page xviii,

Executive Summary) on how to meet this energy demand by any means, including continuing

NUREG-1437, Supplement 41 D-46 July 2'010
Appendix D

operation of CNS-1, new generation sources (e.g., supereritical coal-fired, natural gas-fircd, a

combination), existing sources operating outside this region, conservation measures responding

to reduced capacity or a combination of these alternatives. In essence, selection of an alternative

other than license renewal as the preferred alternative is not precluded by NRC's regulatory

responsibilities and is fully consistent with 40 CFR 1502.14(c) which provides for the inclusion

of "reasonable alternatives not within the jurisdiction of the lead agency." The SEIS should

clarify whether the purpose of the project is to meet the energy demands of the region currently

met by CNS operation or only a license renewal decision.

Affected Environment and Environmental Impacts of Operation

Radiological Environmental Monitoring Program (REMP) Data

The draft SEIS characterizes its conclusions regarding radiation exposures to humans and

contamination of the environment from radiation releases on a limited amount of REMP data

(e.g,, 2003 through 2007) without explanation. Section 2.1.2 characterizes multiple forms of

radioactive waste streams from CNS using data from 2003 through 2007 or only data from 2007.

In Section 4.8. ., the draft SEIS generally summarizes "the calculated hypothetical maximum

dose to an individual located at the CNS-I site boundary firom radioactive liquid and gaseous

effluents released during 2007.? The draft SEIS offers no explanation why that single year of

data was relied upon to make the assessment. Similarly, in Section 4.9.7.4, the draft SEIS

qualitatively summarizes REMP environmental data for only 2007 for several media to assess

exposures from subsistence consumption of fish and wildlife. Again, there is no explanation

offered for why only one year of data is utilized in making these determinations nor does the

draft SEIS present a quantitative summnary of available data. The SEIS should provide a

rationale for relying on this more limited data set after almost 40 years of operation. Regarding

both the assessment of radiation exposures to humans and contamination of ground and surface

water, the SEIS should characterize REMP data rather than merely reference a data set and the

NRC's judgment of their significance (i.e., "reasonable", "no unusual trends"). Recognizing that

CNS' REMP has a 'indicator-control' design, a presentation of trend and comparison to control

or environmental benchmark, where available, utilizing a more robust data set than just one or

several years would provide support to the NRC's determinations of significance in the SEIS. rThe SEIS would be improved if the document provided some information on 'control' location

and the basis for determining these sites were beyond the influence of CNS emissions and

discharges. Public review of radiological data within the SEIS would also be strengthened with a

more complete and thorough organization of that data for each waste stream, including noncontact cooling water (Outfall 001). Currently, the draft SEIS relies completely on the NRC's

qualitative expressions that there arc "no unusual trends", "no measurable impact" and "small

significance" without the benefit of presenting any characterization of the data supporting these

conclusions, their completeness and their representativeness of the larger operational data set.

Ground Water

The SEIS does not address the potential for radiological contamination of alluvial groundwater

and, therefore, the Missouri River from atmospheric washout in the immediate area of CNS.

There is no description of background or historic groundwater contamination or trends in

J uly 2010 D-47 NUREG-1437, Supplement 41
Appendix D

groundwatcr radiological contamination during the current license period as would be expected

fioom the facility's REMP which was initiated in 1971. In Section 2.1.7.1, the SETS makes

statements regarding a large number of monitoring wells installed to "measure the concentration

of tritium in ground water" and documented "instances of liquid radiological releases."' The SEIS

also states that "none of the releases is a current source of ground water contamination", but

provides no basis for this statement. The document also indicates that sampling and analysis

results from the ground water monitoring program will be included in the final SEIS. The

absence of this information in the draft SETS interferes with our ability to evaluate radiological

impacts to ground water and, potentially, the Missouri River. The SEIS would be improved if it

included: the rationale behind the installation of the monitoring wells on-site and their locations,

particularly the 11 installed to measure tritium contamination, the rationale behind the 3

remaining wells installed as part of CNS' INFSI Project, comparisons of the radiological

character of site ground water in comparison with off-site reference or background, an

explanation of benchmarks for both human health and aquatic life exposures and a

characterization of ground water trends with regard to radiological contamination. Further, the

SEIS should specify possible sources of radiological contamination and response actions by the

licensee based on the presence of radiological contamination in thcse wells. Public review of

these data would be-strengthened if there was more information regarding what radiological

levels are 'expected' by NRC at this facility, what levels might raise concern for the NRC and

what measures CNS intends to take or has taken to address sources of contaminution to ground

water.

Surface Water

Section 4.4 of the drati SEIS does not adequately characterize CNS' use of surface water in

comparison to available river flows. The SlI.S would be improved if it characterized the

percentage of flow utilized by CNS under low and high flow river conditions under 'wet' and

drought periods in the basin. Given the direct hydrologic link between ground water and the

river, computations of relative facility water consumption should combine ground water and

surface water withdrawals. An assessment of comparative volumes of river flow use by CNS

during varying conditions (e.g., seasonal, climatic) would better characterize both the potential

impact of operation on the river and the facility's dependence upon river flow. Section 2.1.6

mentions that "the circulating water system flow would be about 47 percent of Missouri River

flow" under critical low flow conditions. The fact sheet supporting the State of Nebraska's

NPDES permit for CNS states that 625 MGD is withdrawn from the river at the intakes. TIe

Missouri River basin appears to be ending a recent long-term drought period during which the

navigation season was shortened several times. In the recent past, low winter flows and

continuing river bed degradation in some reaches have caused utilities drawing water from the

lower river to take extreme engineering measures to ensure a continuing flow of water to their

systems. Congress has recently ordered the Army Corps of Engineers to study those purposes for which the current Missouri River system is operated as well as to develop a formal plan to

recover native species and the river ecosystem. It is reasonable to consider these actions as they

might affect CNS operation during a license renewal period which extends to 2034. In addition,

climatic changes to the region could result in changes in the availability and timing of river flows

for facility operation. Treatment of these complex relationships in Section 4.4 is not robust

enough to aid in the decision-making value ol'the SEIS.

NUREG-1437, Supplement 41 D-48 July 22010
Appendix D

Given the potential impacts of thermal discharges from any single-pass cooling system, Section

4.5.3 should provide much more information regarding CNS's NPDES compliance record since

1974 with regard to its temperature limits, recent warming trends in ambient river water and

tributary flows and the impact of warmer receiving water on facility temperature compliance and

a characterization of the relative volume of cooling water discharge to river flow at high and low

river flows. Assimilation of heat by receiving waters without adverse effect to aquatic organisms

has been a significant issue for any energy production facility and is becoming more problematic

for some facilities with recent trends of increasingly warmer receiving waters (i.e., less

assimilative capacity for heat). This issue warrants more detailed treatment in the SEIS. NRC

should consider adding more detailed information regarding the facility's temperature allocation,

modeling and mixing zone calculations as an appendix to the document.

Section 2.1.7.2 states that CNS operations do not affect water quality in the Missouri River based

on a cursory description of data from the Army Corps of Engineers' Water Control Manual and

listings of impairment by the State of Nebraska. Theme is no characterization of available

monitoring data for the Missouri River in the vicinity of CNS. The draft SEiS states that NPPD

does not monitor surface waters as part of its environmental program. In fact, there is limited

ambient water quality data for the Missouri River. The SEIS should avoid making statements

regarding the impacts of facility operation on the river based on limited and uncharacterized

data. Finally, the Stale of Nebraska has designated the river for more beneficial uses than is

stated in this section.

Section 2.1.7.3 is incomplete as it does not discuss the two compliance schedules contained

within CNS' NPDES permit for its cooling water intake structure (Clean Water Act, Section

316(b)) and water quality-bascd limits for total residual chlorine. The SEIS should also clarify

which outfalls discharge to surface water and which outfalls are chlorinated or brominated.

Aquatic Life

Although we continue to have concerns about the age of the data relied upon to characterize the

impacts of entrainment and impingement on river biota (Section 4.5.2.3, page 4-6), we generally

agree with the conclusions of the analysis preformed by NRC staff in this section. However,

Section 4.5.2 would be greatly improved if the analysis included impingement data from other

facilities utilizing the same or other technology and source water (i.e., large river) against which

to compare CNS data. It is difficult to determine if the amount of fish impinged at CNS

constitutes a comparatively large or small amount of biomass. Alternatively, data regarding

entrainment at CNS appears to be very limited and inconclusive making the conclusions

expressed in Section 4.5.2 regarding entrainment much more speculative and qualitative. As

addressed in the cover letter to these comments, the basis for asserting that CNS operation has a

small impact on aquatic life in the Missouri River would be better supported if NPPD provided

more contemporary data regarding river biota in the immediate environment of the facility in an

indicator-control design similar to theREMP and better characterized risks to biota from

entrainment.

As with our previous comments regarding the presentation of REMP data, the draft SEIS limits

its characterization of radiological contamination in the environment, in many instances, to one

July 2010 D-49 NUREG-1437, Supplement 41
Appendix D

year's worth of data. The document briefly mentions, in Section 4.9.7.4, monitoring milk,

vegetation, surface water, drinking water, groundwater, fish and sediment, but characterizes data

from only 2007. Relying on conclusions of significance apparently drawn from one year

provides little basis for the NRC concluding that "the routine operation at CNS-l has had no

significant or measurable radiological impact on the environment." The SEIS reader has only

the assurances of NRC staff that these data are representative of ambient conditions to conclude

that a proper evaluation of environmental impact has indeed occurred.

Storinwater and Wastewater Treatment

The draft SEIS does not address possible tritium contamination within the wastewater collection

and treatment system. Downwash from facility venting operations and worker sanitary

contributions are common sources of radiological contamination of nuclear facility liquid

effluent. CNS discharges collected site stormwater into ground water through drainage wells.

The draft SETS does not characterize stormwater radiological contamination which reflects

downwash from site structures. ''he SEiS should summarize REMP data and characterize

radiological contamination resulting from air deposition and resulting surface runoff which is

discharged into drainage wells. Similarly. sanitaty wastewater effluent is land-applied on-site,

but there is no characterization of possible radiological ground water contamination associated

with this waste stream.

There is no discussion within the draft SEIS regarding potential wastewater lagoon sludge

contamination with radionuclides or the means by which the sludge is disposed. The SETS

should characterize this environmental medium and also describe how and where the sludge is

disposed.

Spent Fuel Storage anti Independent Spent Fuel Storage Installation

Although collective offsite radiological impacts of spent fuel storage are addressed under other

NEPA documentation, the SEIS should describe the current status of the CNS's new Independent

Spent Fuel Storage Installation (ISFSI) and projected capacity over the term of the license

renewal period that extends to 2034. This information does not pertain to radiological risk

assessment and would not be adequately addressed in the 1996 GEIS and Addendum. Given the

current status of the Department of Energy's application for license for the Yucca Mountain site,

this information is germane to a discussion of short-terni use and long-term productivity and an

irreversible commitment of resources (40 CFR 1502.15). The need for continued storage, onsite, of spent fuel might extend well beyond the operating life of the facility itself. The status of

each licensed facility with regard to storage of spent fuel varies and each SEIS should

characterize that status and project change to that status over the lifetime of the renewed license,

Environmental Justice

The SEIS should describe socioeconomic factors associated with CNS affecting the Sac and Fox

and Iowa Reservation populations which are within the facility's ROL These factors are

noticeably absent from the SEIS' assessment of community-based impacts.

NUREG-1437, Supplement 41 D-50 July 2010
Appendix D

The discussion of risks from subsistence consumption of fish and wildlife in Section 4.9.7.4

relies on data from 2007 and concludes that risk is minimal without the benefit of any summary

data fr'om the facility's REMP. With regard to multiple pathways of exposure., the draft SEIS

concludes that "the routine operation at CNS-I has had no significant or measurable radiological

impact on the enviromnent (page 4-33)." Given that the REMP began in 197 1, it is unclear why

this analysis is performed on a single year's worth of REMP data. This statement would be

better supported with the characterization of more REMP data than from only 2007.

Environmental Impact of Alternatives

The SEIS carries forward, for detailed evaluation, in addition to the proposed action, three

alternatives and the 'no action' alternative, although the SEIS states that the 'no action.'

alternative does not meet project purpose and need. Fifteen other alternatives were considered,

but dismissed before detailed evaluation. The three alternatives evaluated are: supereritical coalfired generation; natural gas combined-cycle generation; and a combination of natural gas

combined-cycle generation, conservation capacity increases and wind power.

Super Critical Coal-Fired Generation

The cumulative air impacts of emissions associated with this alternative in combination with

those of existing coal-burning facilities in eastern Nebraska, western Iowa and northwestern

Missouri should be considered in Section 8.1. The significance of the impacts of this alternative

on air quality and total regional carbon emissions should be evaluated in the context of all other

carbon sources.

Mercury is a significant contaminant of concem associated with coal combustion. Many

watersheds downwind of the CNS site have been listed by Iowa and Missouri for mercury

contamination. Further, mercury contamination is measured in fish tissue in areas far from their

estimated source, primarily ftom air deposition. Section 8.1 does not provide an assessment of

impacts from hazardous air pollutants, specific to this alternative, particularly with regard to

mercury emissions. For this alternative, more information is needed in the SEIS regarding

projected mercury emissions and the status of surface waters in the depositional path with regard

to mercury.

Evaluation of Alternatives

Given the comparatively cursory evaluation of the three alternatives compared to the preferred

action, it is not clear how the Alternatives Summary could conclude that "All other alternatives

capable of meeting the needs currently served by CNS-1 entail potentially greater impacts than

the proposed action of license renewal of CNS- 1." This conclusion is not sufficiently supported

by the alternatives analysis, consistent with thie requirements of 40 CFR 1502.14(a).

Notwithstanding the requirements for "rigorous" and "objective" alternatives analysis at 40 CFR

150.14(a), the NRC's expressed view of its responsibilities to determine whether "there are

findings in the safety review required by the Atomic Energy Act of 1954 (AEA) or findings in

the NEPA environiuental analysis that would lead to the rejection of a license application,.."

(Executive Summary, page xviii) does not appear to necessitate any alternatives analysis.

July 2010 D-51 NUREG-1437, Supplement 41
Appendix D

The summary of impacts contained in Tables 1 and 8-5 does not appear to be a rigorous

evaluation of the five alternatives carried forward in the draft SEIS for detailed review as is

required in 40 CFR 1502.14(a), (b) and (e). In our view, the power of the evaluation required by

NEPA, particularly an evaluation of a reasonable range of alternatives to a proposed action, is in

a detailed and well-documented determination of whether it is good public policy to proceed

with an action instead of an alternative to the proposed action. The discussion of this evaluation

of a range of reasonable alternatives within the Executive Summary and Chapter 9 is not

compelling and separation points critical to a decision to select the preferred alternative over an

alternative are not evident.

As presently described in the draft SEIS, the impacts of the alternatives are characterized

according to rather broad categories, primarily in isolation from each other and the proposed

action. Rather than weighing of the impacts of each alternative, none of these alternatives are

evaluated in direct comparison to the license renewal of the CNS, In effect, the license renewal

of the CNS, or any existing facility, stands separately from all other alternatives and is evaluated

on its merit alone. This intent is reflected, initially, in project purpose and nced. Additionally,

some significant impacts associated with continued operation of any existing facility are not

addressed within the SEIS, but are addressed generically in the GElS or other NEPA

documentation, making a complete comparison of several large scale impacts of continued

operation to the alternatives impossible. No comprehensive assessment or comparison of the

merits of generating power by the existing facility or one of the alternatives is performied in this

documentation. Unless the economic costs and environmental impacts of spent fuel

transportation and disposal and facility decommissioning are somehow incorporated or

summarized in the decision documentation supporting this license renewal decision, an equal

comparison of alternatives to license renewal by the reader is not possible. This issue reflects an

apparent disconnect between the broad treatment of license renewal for all facilities in the GEIS

and facility-specific assessments in the SE1S.

NUREG-1437, Supplement 41 D-52 July 24010
APPENDIX D.2

BIOLOGICAL ASSESSMENT

COOPER NUCLEAR STATION LICENSE

RENEWAL DATE 2009 DOCKET NO. 50-298

U.S. NUCLEAR REGULATORY COMMISSION

ROCKVILLE, MARYLAND

D.2 BIOLOGICAL ASSESSMENT OF THE POTENTIAL EFFECTS ON

FEDERALLY-LISTED ENDANGERED OR THREATENED SPECIES FROM THE

PROPOSED LICENSE RENEWAL FOR COOPER NUCLEAR STATION

.D.2.1 INTRODUCTION AND PURPOSE

The U.S. Nuclear Regulatory Commission (NRC) prepared this biological assessment (BA) to

support the supplemental environmental impact statement (SEIS) for the renewal of the

operating license for Cooper Nuclear Station (CNS), located on the western shore of the

Missouri River near the Village of Brownville, Nemaha County, NE. The current 40-year license

expires in 2014. The proposed license renewal for which this BA has been prepared would

extend the operating license to 2034.

The NRC is required to prepare the SEIS as part of its review of a license renewal application.

The SEIS supplements NUREG-1437, Volumes 1 and 2, Generic Environmental Impact

Statement for License Renewal of Nuclear Plants (GELS), (NRC, 1996), (NRC, 1999)afor the

license renewal of commercial nuclear power plants. The SEIS covers specific issues, such as

the potential impact on endangered and threatened species, that are of concern at CNS and

that NRC could not address generically in the GELS.

Pursuant to Section 7 of the Endangered Species Act (ESA) of 1973, as amended

(16 U.S.C. § 1536(a)-(d)), the NRC staff requested, in a letter dated January 29, 2009

(NRC, 2009), that the U.S. Fish and Wildlife Service (USFWS) provide information on

Federally-listed endangered or threatened species, as well as on proposed or candidate

species, and on any designated critical habitats that may occur in the vicinity of CNS. Under

Section 7, the NRC is responsible for providing information on the potential impact that the

continued operation of CNS could have on the Federally-listed species, the pallid sturgeon.

D.2.2 PROPOSED ACTION

The proposed action considered in the SEIS is the renewal of the CNS operating license for an

additional 20-year term beyond the period of the existing license. If the NRC grants the

operating license renewal, the applicant can operate and maintain the nuclear unit, the cooling

system, and the transmission lines and corridors as they are now until 2034.

D.2.3 SITE DESCRIPTION

CNS is located in Nemaha County, NE, 2.25 miles (mi) (3.6 kilometers (km)) southeast of

Brownville, Nebraska, and approximately 60 mi (96 km) southeast of Lincoln, Nebraska. The

CNS property is bounded on the east by the Missouri River and by non-Nebraska Public Power

District (NPPD) owned property on the north, south, and west. Figure 3-1 shows a map of a

50-mi (80-km) radius around CNS..Figure 3-2 shows the area within a 6-mi (9.6-km) radius of

CNS. NPPD owns and operates the site. The structures for CNS span approximately 55 acres

(ac) (22 hectares (ha)) of the site's total area of approximately 1,359 ac (550 ha), including

239 ac (97 ha) on the opposite bank (east) of the Missouri River in Atchison County, MO. Over

99 percent of the acreage in Nemaha County is used for agriculture and farming. NPPD

a The GEIS was originally issued in 1996. Addendum 1 to the GElS was issued in 1999. Hereafter, all references

to the "GElS" include the GElS and its Addendum 1.

July 2010 D.2-1 NUREG-1437, Supplement 41
Appendix D.2

currently leases 234 ac (947 ha) of the property in Missouri and 715 ac (289 ha) in Nebraska for

agricultural activities, such as farming and livestock.

I Figure 3-1. Location of Cooper Nuclear Station, 50-mile (80-kilometer) Region

(Source: NPPD, 2008b)

NUREG-1437, Supplement 41 D.2-2 July 2010
Appendix D.2

Figure 3-2. Location of Cooper Nuclear Station, 6-miles (10-kilometer) Region

(Source: NPPD, 2008b)

I

July 2010 D.2-3 NUREG-1437, Supplement 41
Appendix D.2

I CNS is a single-unit boiling water reactor plant with a nuclear steam supply system supplied by

General Electric Company and a turbine generator set supplied by Westinghouse Electric

Corporation. CNS achieved commercial operation in 1974 with an initial licensed core thermal

power of 2,381 megawatts-thermal (MWt). In 2008, with NRC approval, the applicant performed

a measurement uncertainty recapture uprate that increased the core thermal power by

1.62 percent to its current level of 2,419 MWt and 830 megawatts-electric (MWe)

I (NPPD, 2008b). Figure 3-3 shows the general layout of the buildings at CNS. The principal

structures at CNS consist of the reactor building, turbine building (including service area

appendages), control building, controlled corridor, radwaste building, augmented radwaste

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

multi-purpose facility, railroad airlock, drywell and suppression chamber, miscellaneous

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

chemistry gas generator building, and office building. Visually dominant features are the

290-foot (ft) (88-meter (m)) tall reactor building, the 325-ft (99-m) tall elevated release point, and

the 328.8-ft (100-m) tall meteorological tower.

NUREG-1437, Supplement 41 D.2-4 July 2010
Appendix D.2

// \\i

Figure 3-3. Cooper Nuclear Station, General Site Layout (Source: NPPD, 2008b)

CNS lies on the western shore of the Missouri River, withdraws river water for its once-through

cooling system, and discharges heated water back to the river. Unless otherwise cited, the NRC

staff drew information about CNS's cooling and auxiliary water systems from NPPD (2006) and

the applicant's environmental report (ER) (NPPD, 2008b), where more in-depth information

appears. In the vicinity of the plant, the Missouri River has a regulated minimum flow of

3,000 cubic feet per second (cfs) (85 cubic meters per second (m3/s)) to the southeast. The

circulating water intake structure is located on the western shore of the river behind a guide wall

and submerged weir meant to reduce the amount of suspended sediment in the cooling water.

The weir attaches to shoreline structures north of the intake and then runs parallel to the face of

the intake at a distance of 14.25 ft (4.3 m). The wall continues past the intake and ends 40 ft

(12 m) downstream of the corner of the intake structure. In a line riverward of the weir wall and

July 2010 D.2-5 NUREG-1437, Supplement 41
Appendix D.2

extending downstream of it, 23 sheet pile vanes (10 ft wide by 6 ft high (3 m wide by 2 m high)),

oriented at a 22 degree angle to the weir, redirect sand and gravel outward from the weir and

the intake structure. After flowing generally south along the weir and vanes, river water must

reverse course and turn northwest to move between the weir and shore and reach the intake

bays. Water velocity between the weir wall and the cooling water intake structure is about 4 feet

per second (ft/s) (1.2 meters per second (m/s)).

In winter, about 25 to 30 percent of the main condenser discharge water recirculates through an

ice control tunnel at the front of the intake structure and discharges in front of the trash rack to

I prevent icing. Water flows beneath a curtain wall at about 1.1 ft/s (0.3 m/s). Water enters the

five intake bays, four of which provide circulating water and are 22 ft (6.7 m) wide and one of

which provides service water and is 22.5 ft (6.8 m) wide. The incoming water then flows through

trash racks, 3/8 inch (1 centimeter (cm)) vertical bars separated 3 inches (7.6 cm) on center, at

up to 0.7 ft/s (20 cm/s).

The circulating water intake bays each separate into two screen bays and the service water

intake bay narrows before water encounters the traveling screens, which are oriented at right

angles to the flow. Water filters twice through 1/8 by 1

1⁄2-inch (.3 by 1.3 cm) smooth-top mesh of

nine modified dual-flow traveling screens (eight for circulating water and one for service water):

on the upward pass in the front and the downward pass behind the screens, installed in 2006,

rotate continuously at 8.2 feet per minute (ft/min) (2.5 meters per minute (m/min)). The intake

water velocity at the screens is about 2 ft/s (0.6 m/s).

After the 4.2-ft (1.28-m) wide traveling screen panels rotate over the upper cog and begin

moving down, a high pressure (30-60 pounds per square inch gage (psig), 200-400 kilopascal

I (kPa)) screen wash of 3,000 gallons per minute (gpm) (0.19 m3/s) supplied by the service water

pumps removes fish and debris, which return together to the river through an 18-inch (0.46-m)

diameter steel pipe that discharges downstream from the intake. Although the screens are fitted

with fish baskets, the system has neither a low-pressure spray system to more gently remove

fish from the screens nor a fish return trough to convey fish and other aquatic organisms back to

the river separately from potentially damaging debris. Debris loads are about 10 cubic yards per

month (yd 3/month) (8 cubic meters per month (m3

/month)).

I CNS plans to install "dual-flow conversion screen fish handling systems" during its current

operational term. This system would have low pressure (5-10 psig, 35-70 kPa) fish washing

sprays on both the ascending and descending screens and a fish return trough that is separate

from the debris trough. A recovery basket would collect fish and other aquatic organisms

washed from the screens, and the fish trough would return them to the river. Figures 3-4

through 3-6 show the CNS intake structures.

NUREG-1437, Supplement 41 D.2-6 July 2010
Appendix D.2

SERVICE

PUMPS CICRCULATIN

WATER PUMP

32 11.5"

-- BRAVELN

SCREENS

J C5;z ~ crzýi r5<1 ~ BAR RACKS

0 00 0=-0 Oý -

G

P8

G

II L 22'- 6" 1 I I

-J3-L L22'

Figure 3-4. Cooper Nuclear Station, Intake Structure Plan (Source: NPPD, 2008b) I

CIRCULATING

WATER PUMP

ICE CONTROL TUNNEL

? 11112 0

Figure 3-5. Cooper Nuclear Station, Intake Structure Section (Source: NPPD, 2008b)

July 2010 D.2-7 NUREG-1437, Supplement 41 i
Appendix D.2

HIGH PRESSURE

SPRAY WASH

DEBRIS RETURN TROUGH

FISH LIFT BUCKET

FLOW

IIII

0I

0:

0

FLOW

z

I Figure 3-6. Cooper Nuclear Station, Typical Dual Flow Screen

(Source: NPPD, 2008b)

After water passes through the traveling screens, the two screen bays of each intake bay rejoin

behind the screens. The four circulating water pumps, one per bay, can draw water from the

bays and can provide up to 159,000 gpm (10 m3

/s) each. The four service water pumps in the

fifth bay can provide a combined flow of 32,000 gpm (2 m3

/s). Water from the circulating water

pumps travels to and circulates through the condenser, where it cools steam from the turbines.

Because of the scouring from the suspended sediment, CNS typically does not need to

NUREG-1437, Supplement 41 D.2-8 July 2010
Appendix D.2

chlorinate the circulating water to control biological film fouling, although it has the capacity to

chlorinate or brominate if needed. NPPD is studying the effectiveness of those options.

Water temperature increases about 17.8 0 F (10°C) as it passes through the condenser tubes.

From the condenser, circulating cooling water flows through concrete tunnels to a seal well

structure and then to the discharge canal, where it travels about 1,000 ft (300 m) to discharge to

the river at a slight angle. Water velocity at the discharge is about 1 ft/s (0.3 m/s) at average

river flow and about 5.6 ft/s (1.7 m/s) during low flow. The travel time from the intake structure to

the discharge is about 20 minutes at high river flow and 10 to 12 minutes at low flow.

Cooling water flow varies with electrical load and ambient river water temperature. At full load

during the summer, the expected circulating water system flow is highest: about 636,000 gpm

(40 m3/s). Circulating water flow is lower under other conditions. In comparison, the lowest river

flow at CNS is about 3,000 cfs (85 m3

/s). Under these worst conditions, the circulating water

system flow would be about 47 percent of the Missouri River flow. Stone rip-rap at the discharge

structure prevents the discharge from eroding the river bottom.

D.2.4 STATUS REVIEW OF PALLID STURGEON

D.2.4.1 Life History

Sturgeon are members of an order of fish (Acipenseriformes) that probably evolved in the

Devonian age. Living members of this order in North America include the paddlefish and eight

sturgeon species. The paddlefish (Polyodon spathula) and three sturgeon species, the lake

sturgeon (Acipenser fulvescens), pallid sturgeon (Scaphirhynchus albus), and the shovelnose

sturgeon (S. platorynchus), live in the Missouri and Mississippi rivers. In the past, commercial

fishermen harvested all three of the sturgeon species in the Missouri and Mississippi rivers.

Today pallid sturgeon are a Federally-listed endangered species, and lake sturgeon are listed

as endangered by Nebraska. The life history information below is from Dryer and Sandvol

(1993) and the USFWS (2007) if not otherwise cited.

Pallid sturgeon have a flattened snout, a long tail, and rows of bony armor plates. The upper

side is convex and the lower side is straight. They have an inferior (bottom-facing) mouth and

eat invertebrates, such as the immature stages of insects, and fish. The body shape is well

adapted for swimming close to the bottom of relatively fast flowing, large rivers. The diet, inferior

mouth, and barbels in front of the mouth are well adapted to feeding on or near the bottom in

highly turbid environments.

The USFWS listed pallid sturgeon as endangered in 1990. The historic abundance of pallid

sturgeon is somewhat vague since biologists did not recognize it as a separate species from

shovelnose sturgeon until 1905, but its historical range probably extended from the middle and

lower Mississippi River in the south up through the Missouri River and lower reaches of the

Platte, Kansas, and Yellowstone rivers in the north and west. The pallid sturgeon is one of the

largest fish species in those rivers. Available information suggests that the pallid sturgeon was

not a common species since the time of European settlement. Today pallid sturgeon are among

the rarest fish of the Missouri and Mississippi River basins, and the present range includes the

States of Montana, North and South Dakota, Nebraska, Iowa, Kansas, Missouri, Illinois,

Kentucky, Arkansas, Mississippi, and Louisiana. The populations are believed to be mostly

older fish that may die off in the foreseeable future.

Fisheries biologists know little about pallid sturgeon reproduction or even preferred spawning

habitats and conditions. Hurleya et al. (2004) tracked sonically-tagged pallid sturgeon in the

July 2010 D.2-9 NUREG-1 437, Supplement 41
Appendix D.2

Mississippi River and found that they exhibited positive selection for the main-channel border,

downstream island tips, between-wing-dam, and wing-dam-tip habitats; they showed negative

selection for main-channel, downstream of wing dams, and upstream of wing dam habitats. The

sturgeon exhibited little habitat selection for temperature or dam discharge. The authors

concluded that habitat enhancement and restoration of habitat diversity might be necessary for

the recovery of pallid sturgeon.

Reports of pallid sturgeon reproduction are rare. The U.S. Geological Survey (USGS) (2007),

Nebraska Game and Parks Commission (NGPC), and the U.S. Army Corps of Engineers

(USACE) confirmed spawning of two female pallid sturgeon in the upstream reaches of the

lower Missouri River in May 2007. The capture of young pallid sturgeon that would verify natural

reproduction are also rare: none were captured between 1978 and a Mississippi River trawl

survey in 1998 through 2000 using equipment designed to capture larval fish in deep, turbulent

water (Hrabik et al., 2007). Hrabik et al. (2007) concluded that those latest captures verified

reproduction, possibly from the lower Missouri River to the upper and lower Mississippi River,

although they also found no evidence of recruitment of pallid sturgeon because they captured

no juveniles after 374 trawl hauls that captured over 21,735 fish in that 1998 through 2000

survey. Wildhaber et al. (2007) suggest that one or more of the following factors may be

responsible for the lack of finding larval pallid sturgeon and of recruitment: lack of successful

spawning, low recruitment, high mortality, ineffective sampling methods, inadequate sampling of

drift and settling locations, or rapid dispersal and washout of sturgeon larvae in the Missouri and

Mississippi rivers. Pallid sturgeon larvae are indistinguishable from those of the congeneric

shovelnose sturgeon, which may also help to explain the paucity of reported collections in the

past. Also, the construction of dams. and other structures with resulting habitat change and the

elimination of shallow areas in the river with little or no flow have probably deprived sturgeon of

critical nursery areas needed for the survival of immature sturgeon (MDC, 2009).

Larval pallid and shovelnose sturgeon become strongly photopositive and migrate upwards

toward the light starting the first day after hatching. As a result, they remain far above the

bottom, even at the water surface, and migrate far downriver (Kynard et al., 2002). Cultured

yearling pallid sturgeon in laboratory studies also migrate downstream during summer and fall,

which suggests a two-stage (larval, then yearling) downriver migration in the first year of life.

Adult sturgeon are also highly migratory and often migrate hundreds of miles in a year.

The young of both shovelnose and pallid sturgeon eat invertebrates, but as pallid sturgeon

grow, they become more piscivorous. Gerrity and Guy (2006) found that the diet of juvenile

pallid sturgeon of age 6 and 7 was mostly fish, compared to the diet of shovelnose sturgeon,

which is mainly aquatic insects. Sturgeon chub (Macrhybopsis gelida) and sicklefin chub (M.

meekl) together comprised 79 percent of the number of identifiable fish in juvenile pallid

sturgeon stomachs. Populations of these two cyprinid minnows have declined throughout much

of the Missouri River due to the construction of dams and man's other alterations of river

habitat, and the State of Nebraska lists sicklefin chub as threatened and sturgeon chub as

endangered. While the population of the piscivorous pallid sturgeon has declined in the Missouri

and Mississippi rivers, the population of its similar, insectivorous congener, shovelnose

sturgeon, has not declined. Gerrity and Guy (2006) concluded that the prevalence of sicklefin

chub and sturgeon chub as a food resource of juvenile pallid sturgeon may help explain the

decline of pallid sturgeon populations and that recovery and management of native cyprinids is

a potentially important step in the recovery of pallid sturgeon.

Male pallid sturgeon are believed to mature at 7 to 9 years after which they spawn at intervals of

2 to 3 years. Females may reach sexual maturity at 7 to 15 years and spawn at intervals up to

NUREG-1437, Supplement 41 D.2-1 0 July 2010
Appendix D.2

10 years. Individuals may reach ages of 60 years or more and reach lengths of 6 ft (2 m). Like

many other fish species, the largest individuals are found farthest north in the species' range

and maximum size decreases with distance south. For example, the maximum weight of pallid

sturgeon in the upper Missouri River in Montana and North Dakota is 86 pounds (Ibs) (39

kilograms (kg)), in the Missouri River in South Dakota and Nebraska 46 lbs (21 kg), and in the

Mississippi River 26 lbs (12 kg). They become much larger than shovelnose sturgeon, which

rarely weigh more than 8 lbs (3.6 kg).

D.2.4.2 Status of Pallid Sturgeon in the Missouri River

While they were successful in the historical Missouri and Mississippi rivers, with the high flow

and turbidity and diverse habitats of floodplains, backwaters, chutes, sloughs, islands, sand and

gravel bars, and both braided and main channels, they are not so well adapted to the Missouri

and Mississippi rivers today with the construction of dams that isolated subpopulations,

channelization, controlled flow, and elimination of habitat diversity. The USFWS (2007)

concludes that man's activities have adversely affected all of the 3,350 mi (5,390 kin) of river

habitat within their range, and habitat alteration and loss may be the biggest threat to their

existence. Other threats may include hybridization with shovelnose sturgeon, commercial

fishing, and exposure to environmental contaminants such as polychlorinated biphenyls (PCBs),

cadmium, mercury, selenium, chlordane, dichlorodiphenyltrichloroethane (DDT),

dichlorodiphenyltrichloroethylene (DDE), and dieldrin, all of which have been found in pallid

sturgeon tissue in the past.

During the early 1990s, theMissouri Department of Conservation (MDC) developed "action

plans" for lake and pallid sturgeon a goal of reestablishing self-sustaining populations so they

can be delisted as endangered species and ultimately provide limited sport fisheries. These

plans stress the restoration of both species through habitat improvement, artificial propagation,

protection, research, management, and education (MDC, 2009). As part of this effort, the MDC's

Blind Pony Fish Hatchery has raised and stocked over 13,000 fingerling pallid sturgeon and

200,000 fingerling lake sturgeon into the Missouri and Mississippi rivers (MDC, 2009). In

addition to these efforts, the USGS (Wildhaber et al., 2007) has developed a conceptual life

history to organize the understanding about the complex life history of Scaphirhynchus sturgeon

and improve understanding of the effects of management actions on the ecological

requirements of pallid and shovelnose sturgeon. The USFWS's Pallid Sturgeon Recovery Plan

(Dryer and Sandvol, 1993) designated six recovery priority management areas (RPMAs) for

implementation of recovery tasks, and CNS is located within RPMA 4.

D.2.4.3 Impact Assessment of Cooper Nuclear Station on Pallid Sturgeon

NPPD (2008a) summarizes interactions between NPPD and both State and Federal agencies

regarding conservation of pallid sturgeon. That summary is outlined below:

In March 2006, before filing a license renewal application with NRC, NPPD voluntarily

participated in meetings with the USFWS, the NGPC, the Nebraska Department of

Environmental Quality (NDEQ), the Nebraska Department of Natural Resources (NDNR), the

Environmental Protection Agency (EPA), and the USACE regarding conservation actions to

improve the habitat of pallid sturgeon. NPPD (2008a) summarizes those meetings. Early in the

discussions, the USFWS and NGPC showed interest in developing existing habitat on a parcel

of property south of CNS at Langdon Bend and later also on CNS property on the Nebraska

side of the Missouri River adjacent to Langdon Bend. They hoped to enhance pallid sturgeon

habitat by building a chute to connect active river channels with the old river area.

July 2010 D.2-11 NUREG-1437, Supplement 41
Appendix D.2

NPPD had problems with this proposal. Implementing the proposal would reduce CNS's mixing

zone, which now extends 5,000 ft south of CNS along the Nebraska side of the Missouri River,

to less than half, less than 2,500 ft. Reducing the mixing zone would reduce CNS's capacity to

generate electricity, particularly during the summer. The proposal also posed other negative

I safety and environmental concerns for CNS. As an alternative, NPPD then offered to contribute

funds toward other new or existing projects on the Missouri River. The USFWS rejected this

funding alternative in favor of increasing the amount of land for habitat development.

To meet the goal of improving habitat for pallid sturgeon, NPPD offered a conservation

easement of about 230 ac (93 ha) of land that it owns on the Missouri side of the Missouri River,

I opposite CNS, for the purposes of habitat development. The USFWS indicated interest in the

proposal, and asked NPPD to also acquire an adjacent property of about 150 ac (51 ha) so that

the entire bend in the river could be developed into better habitat. When the property owner

refused to sell the land, NPPD offered a revised, final proposal to participate in and promote

habitat development along the Missouri River. It proposed to revisit the USFWS's and NGPC's

interest in a suitable conservation easement and Memorandum of Understanding to enable

habitat development on NPPD's approximately 230-ac (93-ha) parcel on the Missouri side of the

river. Furthermore, because NPPD recognized that this parcel alone would not meet the

USFWS's and NGPC's conservation habitat development goals, NPPD indicated its willingness

to make an additional payment of $250,000 to be applied toward another conservation habitat

development project on the Missouri River at the direction of the USFWS and NGPC. At the

time of writing this BA, the involved parties are discussing details of the conservation

agreement.

Plans for and construction of a chute on the parcel may also involve the owners of the

transmission lines and supports that cross the property. NPPD does not own these lines,

although CNS provides power to them.

The probability that CNS will entrain, impinge, or otherwise affect pallid sturgeon eggs or larvae

is low. Hazleton (1979) collected adult and juvenile fish from seven locations in the vicinity of

I CNS from 1970 through 1978 and reported no pallid sturgeon captured. They also conducted

impingement sampling from 1974 through 1978 and reported no pallid sturgeon impinged.

Based on 374 trawl hauls that captured over 21,735 fish in a 1998 through 2000 survey, Hrabik

et al. (2007) concluded pallid sturgeon may reproduce in the lower Missouri River to the upper

and lower Mississippi River, although no fish may survive to recruitment. NPPD's involvement in

the conservation agreement, however, could have a positive impact on the pallid sturgeon

population.

D.2.5 CONCLUSION

Based on this review, the staff concludes that the continued operation of CNS for an additional

20 years may affect, but is not likely to adversely affect, the pallid sturgeon.

D.2.6 REFERENCES

Dryer, M.P. and A.J. Sandvol. 1993. "Recovery plan for the pallid sturgeon Scaphirhynchus

albus," U.S. Fish and Wildlife Service, Bismarck, ND, 55 pp.

Gerrity, P.C. and C. Guy. 2006. "Juvenile pallid sturgeon are piscivorous: A call for conserving

native cyprinids," Transactions of the American Fisheries Society 135:604-609.

NUREG-1437, Supplement 41 D.2-12 July 2010
Appendix D.2

Hazleton Environmental Sciences Corporation (Hazelton). 1979. "The Evaluation of Thermal

Effects in the Missouri River Near Cooper Nuclear Station (Operational Phase), JanuaryDecember 1978, Project No. 8903," report to Nebraska Public Power District, Columbus, NE,

Hazleton Environmental Sciences Corporation, Lincoln, NE, Agencywide Documents Access

and Management System (ADAMS) Accession No. ML092450614.

Hurleya, K.L., R.J. Sheehan, R.C. Heidinger, P.S. Wills, and B. Clevenstine (Hurleya et al.)

2004. "Habitat Use by Middle Mississippi River Pallid Sturgeon," Transactions of the American

Fisheries Society 133:1033-1041.

Hrabik, R.A., D.P. Herzog, D.E. Ostendorf, and M.D. Petersen (Hrabik et al.) 2007. "Larvae

provide first evidence of successful reproduction by pallid sturgeon, Scaphirhynchus albus, in

the Mississippi River," Journal of Applied Ichthyology 23(4):436-443.

Kynard, B., E. Henyey, and M. Horgan (Kynard et al.). 2002. "Ontogenetic behavior, migration,

and social behavior of pallid sturgeon, Scaphirhynchus albus, and shovelnose sturgeon, S.

platorynchus, with notes on the adaptive significance of body color," Environmental Biology of

Fishes 63:389-403.

Missouri Department of Conservation (MDC). 2009. "The Sturgeon of Missouri: Missouri's

Aquatic Dinosaurs," Updated 2009. Available URL: http://mdc.mo.gov/fishisport/sturgeon/info/

(accessed on May 5, 2009).

Nebraska Public Power District (NPPD). 2006. "Proposal for Information Collection, Cooper

Nuclear Station," January 2006, ADAMS Accession No. ML092510103.

Nebraska Public Power District (NPPD). 2008a. Letter from Joe Citta, Nebraska Public Power

District, to Robert Harms, U.S. Fish and Wildlife Service, Subject: "Cooper Nuclear Station

License Renewal-Habitat Development Proposal," September 26, 2008, ADAMS Accession

No. ML092520156.

Nebraska Public Power District (NPPD). 2008b. "Nebraska Public Power District, Cooper

Nuclear Station, License Renewal Application," September 24, 2008, ADAMS Accession No.

ML083030227.

U.S. Fish and Wildlife Service (USFWS). 2007. "Species Profile, Pallid sturgeon,

Scaphirhynchus albus." Available URL: http://www.fws.gov/moriver/PSPROFILE.htm (accessed

on March 16, 2007).

U.S. Geological Service (USGS). 2007. "Sturgeon Research Update: Confirmed Pallid Sturgeon

Spawning in the Missouri River in 2007," USGS Fact Sheet 2007-3053, July 2007.

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

for License Renewal of Nuclear Power Plants, NUREG-1437, Volumes 1 and 2,

Washington, D.C., ADAMS Accession Nos. ML040690705 and ML040690738.

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

for License Renewal of Nuclear Plants, Main Report, NUREG-1437, Volume 1, Addendum 1,

Washington, D.C.

U.S. Nuclear Regulatory Commission (NRC). 2009. Letter from D. Pelton to Mr. John Cochnar,

U.S. Fish and Wildlife Service, Grand Island, NE, Subject: "Request for List of Protected

Species."

Wildhaber, M.L., A.J. DeLonay, D. M. Papoulias, D.L. Galat, R.B. Jacobson, D.G. Simpkins, P.J.

Braaten, C.E. Korschgen, and M.J. Mac (Wildhaber et al.). 2007. "A conceptual life-history

model for pallid and shovelnose sturgeon," U.S. Geological Survey Circular 1315, U.S.

Geological Survey, Reston, VA, 18 pp.

July 2010 D.2-13 NUREG-1437, Supplement 41

APPENDIX E.

CHRONOLOGY OF ENVIRONMENTAL REVIEW

E. CHRONOLOGY OF ENVIRONMENTAL REVIEW

CORRESPONDENCE

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

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

Cooper Nuclear Station (CNS). All documents, with the exception of those containing

proprietary information, are available electronically from the NRC's Public Electronic Reading

Room found on the Internet at the following Web address: http://www.nrc.gov/reading-rm.html.

From this site, the public can gain access to the NRC's Agencywide Document Access and

Management System (ADAMS), which provides text and image files of NRC's public documents

in ADAMS. The ADAMS accession number for each document is included below.

E.1. Environmental Review Correspondence

September 24, 2008

September 24, 2008

November 10, 2008

November 17, 2008

December 19, 2008

December 19, 2008

January 15, 2009

Letter from Nebraska Public Power District (NPPD) forwarding the

application for renewal of the operating license for CNS, requesting an

extension of the operating license for an additional 20 years. (ADAMS

Accession No. ML0803030227)

NPPD's environmental report (ER) submitted as Appendix E for the

application for renewal of the operating license for CNS, requesting an

extension of the operating license for an additional 20 years. (ADAMS

Accession No. ML083030246)

Letter to NPPD, "Receipt and Availability of the License Renewal

Application for the Cooper Nuclear Station." (ADAMS Accession No.

ML0826611007)

Federal Register Notice of Receipt and Availability of Application for

Renewal of Cooper Nuclear Station Facility Operating License No.

DPR-46 for an Additional 20-Year Period (73 FR 67896). (ADAMS

Accession No. ML0826608920)

Letter to NPPD, "Determination of Acceptability and Sufficiency for

Docketing and Opportunity for a Hearing Regarding the Application from

Nebraska Public Power District, for Renewal of the Operating License for

the Cooper Nuclear Station" (TAC Nos. MD9763 and Md9737). (ADAMS

Accession No. ML083330066)

Federal Register Notice of Acceptance for Docketing of the Application

and Notice of Opportunity for Hearing Regarding Renewal of Facility

Operating License No. DPR-46 for an Additional 20-Year Period

Nebraska Public Power District Cooper Nuclear Station (73 FR 5877).

(ADAMS Accession No. ML083540747)

Federal Register Notice of Intent to Prepare an Environmental Impact

Statement and Conduct Scoping Process for Licensee Renewal for

Cooper Nuclear Station (73 FR 13923). (ADAMS Accession No.

ML090150526)

July 2010 E-1 NUREG-1437, Supplement 41
Appendix E

January 16, 2009

January 21, 2009

January 26, 2009

January 26, 2009

January 27, 2009

January 28, 2009

January 29, 2009

January 29, 2009

January 29, 2009

February 2, 2009

February 4, 2009

February 4, 2009

Letter to Michael Smith, Nebraska Historic Preservation Society,

regarding the CNS license renewal application. (ADAMS Accession No.

MIL090080197)

Letter to NPPD transmitting notice of intent to prepare an environmental

impact statement and conduct scoping process for license renewal for

CNS. (ADAMS Accession No. ML083640401)

Letter to Sherry Black, Auburn Memorial Library, regarding maintenance

of reference materials at the Auburn Memorial Library related to the

review of the CNS license renewal application. (ADAMS Accession No.

ML090230582)

Letter to Don Klima, Director, Advisory Council on Historic Preservation,

regarding the CNS license renewal application. (ADAMS Accession No.

ML090080683)

Letter to Mr. Joseph Cothern, U.S. Environmental Protection Agency

(EPA) Region 7, regarding the CNS license renewal application. (ADAMS

Accession No. ML090230446)

Letter to Julia Schmitt, Department of Health and Human Services,

regarding the CNS license renewal application. (ADAMS Accession No.

ML090260380)

Notice of forthcoming meeting to discuss the safety review process and

environmental scoping process for the CNS license renewal application

review. (ADAMS Accession No. ML090160280)

Letter to Mark Miles, State Historic Preservation Officer, Department of

Natural Resources, MO, regarding the CNS license renewal application.

(ADAMS Accession No. ML090210750)

Letter to John Cochnar, U.S. Fish and Wildlife Service (USFWS),

requesting a list of protected species for the CNS license renewal review.

(ADAMS Accession No. ML0901507)

Letter from the Nebraska State Historic Preservation Office requesting a

map of the boundaries of the environmental review of the license renewal

application for CNS. (ADAMS Accession No. ML090650061)

Letter to Adrian Pushetonequa, Sac and Fox Tribe of the Mississippi in

Iowa, inviting participation in scoping process related to the NRC's

environmental review of the license renewal application for CNS.

(ADAMS Accession No.ML090080045)

Letter to Ann Bleed, Nebraska Department of Natural Resources,

requesting a list of protected species for the CNS license renewal review.

(ADAMS Accession No. ML090260380)

NUREG-1437, Supplement 41 E-2 July 2010
Appendix E

February 25, 2009

February 25, 2009

February 25, 2009

February 25, 2009

February 27, 2009

March 9, 2009

March 10, 2009

March 26, 2009

April 3, 2009

April 3, 2008

April 9, 2009

April 9, 2009

April 14, 2009

April 16, 2009

Agenda and slides for the CNS scoping and process public meeting,

February 25, 2009. (ADAMS Accession No. ML090750686)

Transcript of the CNS license renewal public meeting - afternoon

session, February 25, 2009. (ADAMS Accession No. ML090840063)

Transcript of the CNS license renewal public meeting - evening session,

February 25, 2009. (ADAMS Accession No. ML090840062)

Comments from the Richardson County, NE, Emergency Management

Agency regarding the license renewal of CNS. (ADAMS Accession No.

ML090720066)

Letter from the City of Rock Port regarding the license renewal of CNS.

(ADAMS Accession No. ML090720068)

Letter from Nebraska Department of Natural Resources regarding the

request for a list of protected species for license renewal of CNS.

(ADAMS Accession No. ML090650061)

Letter from the Pawnee City Economic Development Corporation

regarding the license renewal of CNS. (ADAMS Accession No.

ML090720067)

Letter from D. F. Brown, State of Missouri, Department of Conservation,

to R. Bulavinetz, NRC, regarding the preparation of the environmental

impact statement. (ADAMS Accession No. ML091030465).

Letter to NPPD regarding the review schedule for the application for the

renewal of the operating license for CNS. (ADAMS Accession No.

ML090220584)

Letter to Stewart B. Minahan, NPPD, regarding environmental site audit

needs for the CNS license renewal application from NPPD. (ADAMS

Accession No. ML090830248)

Letter to NPPD, "Regulatory Audit Plan for Aging Management Program

Regarding Cooper Nuclear Station License Renewal Application."

(ADAMS Accession No. ML090930256)

Letter to NPPD, "Request for Additional Information Regarding Balance of

Plant Issues for Cooper Nuclear Station." (ADAMS Accession No.

ML091060150)

Summary of the CNS Scoping and Process Public Meeting, February 25,

2009. (ADAMS Accession No. ML090910308)

E-mail comments from EPA Region 7, regarding the license renewal of

CNS. (ADAMS Accession No. ML091070269)

July 2010 E-3 NUREG-1437, Supplement 41
Appendix E

April 30, 2009

May 1, 2009

May 1, 2009

May 5, 2009

May 8, 2009

May 18, 2009

May 29, 2009

June 8, 2009

June 8, 2009

July 1,2009

August 26, 2009

December 17, 2009

February 18, 2010

NUREG-1437, SupplE

Summary of the site audit related to the review of the license renewal

application for CNS (TAC Nos. MD9763 and MD9737). (ADAMS

Accession No. ML090970414)

Letter to NPPD, "Request for Additional Information for the Review of the

Cooper Nuclear Station License Renewal Application." (TAC Nos.

MD9763 and MD9737). (ADAMS Accession No. ML091190597)

Letter from NPPD to the USFWS regarding the license renewal of the

CNS. (ADAMS Accession No. ML091830056)

E-mail from the USFWS to R. Bulavinetz, NRC. (ADAMS Accession No.

ML091400116)

E-mail and attachment from the Nebraska Game and Parks Commission.

(ADAMS Accession No. ML0914001 10)

Letter from NPPD, "Response to Request for Additional Information for

License Renewal Application, Cooper Nuclear Station," Docket No.

50-298, DPR-46. (ADAMS Accession No. ML091600712)

Summary report of environmental scoping for the license renewal

application for CNS (TAC Nos. MD9763 and MD9737). (ADAMS

Accession No. ML091200017)

Letter to NPPD, "Request for Additional Information for the Review of the

Cooper Nuclear Station License Renewal Application" (TAC Nos.

MD9763 and MD9737). (ADAMS Accession No. ML091530316)

Letter from the USFWS to NPPD regarding the license renewal of CNS.

(ADAMS Accession No. ML091830055)

Letter from NPPD, "Response to Request for Additional Information for

License Renewal Application - Severe Accident Mitigation Alternatives,

Cooper Nuclear Station," Docket No. 50-298, DPR-46. (ADAMS

Accession No. ML091880319)

Letter from the USFWS to NPPD concerning the license renewal of CNS.

Letter from NPPD, "SAMA Meteorological Anomaly Related to the Cooper

Nuclear Station License Renewal Application." (ADAMS Accession No.

ML093490997)

Letter from B. Pham, NRC/NRRJDLR/RPB1, to S. Minahan, NPPD,

"Notice of Availability of the Draft Plant-Specific Supplement 41 to the

Generic Environmental Impact Statment for License Renewal of Nuclear

Plants Regarding Cooper Nuclear Station, Unit 1." (ADAMS Accession

No. ML100321621)

ment 41 E-4 July 2010
Appendix E

February 18, 2010

February 18, 2010

February 18, 2010

February 18, 2010

March 19, 2010

March 19, 2010

April 7, 2010

April 7, 2010

April 7, 2010

April 27, 2010

May 3, 2010

Federal Register Notice from B. Pham, NRC/NRR/DLR/RPB1, "Notice of

Availability of the Draft Supplement 41 to the Generic Environmental

Impact Statement for License Renewal of Nuclear Plants, The License

Renewal of Cooper Nuclear Station, Unit 1." (ADAMS Accession No.

ML100330057)

Letter from B. Pham, NRC/NRR/DLR/RPB1, to M. Smith, State of

Nebraska Historical Society, "Cooper Nuclear Station License Renewal

Application Review (HP No. 0801-050-01)." (ADAMS Accession No.

ML100351164)

Letter from B. Pham, NRC/NRR/DLR/RPB1, to J. Cochnar, U.S.

Department of Interior, USFWS, "Notice of Availability of the Draft

Plant-Specific Supplement 41 to the Generic Environmental Impact

Statement for License Renewal of Nuclear Plants Regarding Cooper

Nuclear Station." (ADAMS Accession No. ML100430029)

Letter from B. Pham, NRC/NRR/DLRJRPB1, to M. Miles, State of

Missouri, Historic Preservation Office, "Cooper, License Renewal

Application Review (SHPO Log Number: 004-AT-08)." (ADAMS

Accession No. ML100430043)

E-mail form R. Harms, USFWS, to B. Brady, NRC, "Concurrence Cooper

Nuclear Station." (ADAMS Accession No. ML101440172)

Letter from R. Puschendorf, Nebraska State Historic Society, to B. Pham,

"Concurrence Cooper Nuclear Station," (ADAMS Accession No.

ML101440132)

Meeting Briefing Package/Handouts of Slides and Viewgraphs,

NRC/NRR, "Preliminary Site-Specific Results of the License Renewal

Environmental Review for Cooper Nuclear Station." (ADAMS Accession

No. ML101050376)

Meeting Transcript, NRC/OCM, "Transcript of Cooper, License Renewal

Public Meeting, Afternoon Session, April 07, 2010, Pages 1-20." (ADAMS

Accession No. ML101320545)

Meeting Transcript, NRC/OCM, "Transcript of Cooper, License Renewal

Public Meeting: Evening Session, April 07, 2010, Page 1-20." (ADAMS

Accession No. ML101320618)

Letter from R. Steward, U.S. Department of Interior, to Chief, Rules and

Directives Branch, NRC. (ADAMS Accession No. ML101270268)

Letter from R. Hammerschmidt, EPA, to M. T. Lesar, NRC/ADM/DAS,

"Comment of Ronald Hammerschmidt on Behalf of US Environmental

Protection Agency on Review of Generic Environmental Impact

Statement for License Renewal of Cooper Nuclear Plants, Unit 1."

(ADAMS Accession No. ML1 01270268)

July 2010 E-5 NUREG-1437, Supplement 41

APPENDIX F.

U.S. NUCLEAR REGULATORY COMMISSION STAFF

EVALUATION OF SEVERE ACCIDENT MITIGATION

ALTERNATIVES FOR COOPER NUCLEAR STATION IN

SUPPORT OF LICENSE RENEWAL APPLICATION REVIEW

F. U.S. NUCLEAR REGULATORY COMMISSION STAFF EVALUATION

OF SEVERE ACCIDENT MITIGATION ALTERNATIVES FOR COOPER

NUCLEAR STATION IN SUPPORT OF LICENSE RENEWAL

APPLICATION REVIEW

NOTE: On December 7, 2009, Cooper Nuclear Station (CNS) identified an error in their original

severe accident mitigation alternative (SAMA) analysis resulting from the wind data used in their

code. Nebraska Public Power District (NPPD) discovered a problem with the process they used

to numerically average the site-specific meteorological data. NPPD performed a sensitivity

analysis of the population dose risk and offsite economic cost risk using corrected

meteorological data, and found that the population dose and offsite economic cost values for

each of the release categories would be slightly less than reported in the environmental report

(ER), and that the conclusions of the SAMA remain valid (NPPD, 2009c). U.S. Nuclear

Regulatory Commission (NRC) staff reviewed the revised data as part of the analysis below.

F.1. Introduction

NPPD submitted an assessment of SAMAs for the CNS as part of the ER (NPPD, 2008). This

assessment was based on the most recent CNS probabilistic safety assessment (PSA)

available at that time, a plant-specific offsite consequence analysis performed using the

MELCOR Accident Consequence Code System 2 (MACCS2) computer code (NRC, 1998), and

insights from the CNS individual plant examination (IPE) (NPPD, 1993) and individual plant

examination of external events (IPEEE) (NPPD, 1996). In identifying and evaluating potential

SAMAs, NPPD considered SAMA candidates that addressed the major contributors to core

damage frequency (CDF) and large early release frequency (LERF) at CNS, as well as SAMA

candidates for other operating plants which have submitted license renewal applications. NPPD

identified 244 potential SAMA candidates. This list was reduced to 80 unique SAMA candidates

by eliminating SAMAs that are not applicable at CNS due to design differences, have already

been implemented at CNS, or are similar in nature and could be combined with another SAMA

candidate. NPPD assessed the costs and benefits associated with each of the potential SAMAs

and concluded in the ER that several of the candidate SAMAs evaluated are potentially

cost-beneficial.

Based on a review of the SAMA assessment, the NRC issued a request for additional

information (RAI) to NPPD by letter dated June 8, 2009 (NRC, 2009). Key questions concerned:

(1) the impact of unresolved Boiling Water Reactor Owner's Group (BWROG) PSA peer review

findings on the SAMA analysis results; (2) the process used to develop and group source terms

into containment event tree (CET) end states; (3) the rationale for identifying and screening

SAMAs; and (4) the costs and benefits of several specific candidate SAMAs and low cost

alternatives. NPPD submitted additional information by letter dated July 1, 2009 (NPPD, 2009a)

and e-mail dated August 10, 2009 (NPPD, 2009b). In response to the RAIs, NPPD provided

information regarding the findings of the BWROG peer review, a discussion and example of the

process for assigning severe accident source terms to CET sequences, additional rationale on

the process used to identify and screen SAMAs, and additional information regarding several

specific SAMAs. NPPD's responses addressed the NRC staffs concerns.

An assessment of SAMAs for CNS is presented below.

July 2010 F-1 NUREG-1437, Supplement 41
Appendix F

F.2. Estimate of Risk for Cooper Nuclear Station

I NPPD's estimates of offsite risk at CNS are summarized in Section F.2.1. The summary is

followed by the NRC staff's review of NPPD's risk estimates in Section F.2.2.

F.2.1. Nebraska Public Power District's Risk Estimates

Two distinct analyses are combined to form the basis for the risk estimates used in the SAMA

I analysis: (1) the CNS Level 1 and 2 PSA model, which is an updated version of the IPE

(NPPD, 1993); and (2) a supplemental analysis of offsite consequences and economic impacts

(essentially a Level 3 PSA model) developed specifically for the SAMA analysis. The SAMA

analysis is based on the most recent CNS Level 1 and Level 2 PSA models available at the time

of the ER, referred to as the CNS 2007TM model (2007TM, Revision 1). The scope of this CNS

PSA does not include external events.

The CNS CDF is approximately 9.3 x 10.6 per year for internal events as determined from

quantification of the Level 1 PSA model. When determined from the sum of the CET sequences,

or the Level 2 PSA model, the release frequency is approximately 1.2 x 10-5 per year. The latter

value was used as the baseline CDF in the SAMA evaluations (NPPD, 2009a). The CDF is

based on the risk assessment for internally-initiated events, which includes internal flooding.

NPPD did not include the contribution from external events within the CNS risk estimates,

however, it did account for the potential risk reduction benefits associated with external events

by multiplying the estimated benefits for internal events by a factor of 3. For some fire-related

SAMAs, NPPD separately estimated the risk reduction benefits using the fire risk model. This is

discussed further in Sections F.2.2 and F.6.2.

The breakdown of CDF by initiating event is provided in Table F-1. As shown in this table,

events initiated by transients, loss of DC power, loss-of-coolant accidents (LOCAs), and loss of

feedwater are the dominant contributors to the CDF. Station blackout (SBO) and anticipated

transient without scram (ATWS) sequences may occur following multiple initiators and so their

total contributions to CDF were reported separately. Each contributes less than 3 percent to the

total internal events CDF.

The Level 2 CNS PSA model that forms the basis for the SAMA evaluation represents an

updated version of the original IPE Level 2 model. The current Level 2 model uses a single CET

containing both phenomenological and systemic events. The Level 1 core damage sequences

are binned into one of 15 plant damage state (PDS) bins which provide the interface between

the Level 1 analysis and Level 2 CET analysis. The CET probabilistically evaluates the

progression of the damaged core with respect to radiation release into the environment. CET

nodes are evaluated using supporting fault trees and logic rules. The CET end states then are

examined for considerations of timing and magnitude of release and assigned to release

categories.

NUREG-1437, Supplement 41 F-2 July 2010
Appendix F

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

CDF

Initiating Event (per year) % Contribution to CDF

Transients 3.0 x 10- 32

Loss of DC power 2.1 x 10 22

LOCAs 1.4 x 10' 15

Loss of feedwater 1.0x 10-6 11

Loss of offsite power 6.5 x 10-7 7

Loss of service water (SW) 6.0 x 10-7 7

Loss of AC buses 2.6 x 10-7 3

Internal flood 2.6- 10-7 3

Interfacing-systems loss-of-coolant accidents (ISLOCAs) 5.1 x 104 <1

Total CDF (Internal Events) 9.3 x 10- 100

The result of the Level 2 PSA is a set of 12 release categories, also referred to as source term

categories, with their respective frequency and release characteristics. The release categories

and their characteristics are provided in Table E.1-10 of the ER (NPPD, 2008). The categories

were defined based on the timing, duration, and magnitude of the release and whether or not

the containment remains intact or fails. The frequency of each release category was obtained by

summing the frequency of the individual accident progression CET endpoints assigned to each

release category. Source terms were developed for each of the 12 release categories using the

results of Modular Accident Analysis Program, Version 4.0.5 (MAAP 4.0.5) computer code

calculations.

The offsite consequences and economic impact analyses use the MACCS2 code to determine

the offsite risk impacts on the surrounding environment and general public. Inputs for these

analyses include plant-specific and site-specific input values for core radionuclide inventory,

source term and release characteristics, site meteorological data, projected population

distribution (within a 50-mile (mi) (80-kilometer (km)) radius) for the year 2034, emergency

response evacuation modeling, and economic data. The magnitude of the onsite impacts (in

terms of clean-up and decontamination costs and occupational dose) is based on information

provided in NUREG/BR-0184 (NRC, 1997a).

In the ER, NPPD estimated the dose to the population within 50 mi (80 kin) of the CNS site to

be approximately 0.021 person-Sievert (Sv) (2.1 person-roentgen equivalent man (rem)) per

year. The breakdown of the total population dose by containment release mode is summarized

in Table F-2. Containment failures within the early time frame (less than 3.7 hours following

event initiation) dominate the population dose risk at CNS, with failures in the intermediate time

frame (3.7 to 24 hours following event initiation) contributing most of the remaining population

dose risk.

July 2010 F-3 NUREG-1437, Supplement 41
Appendix F

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

Population Dose

Containment Release Mode (Person-Rem(a) Per Year) % Contribution

Early containment failure 1.67 78

Intermediate containment failure 0.47 22

Late containment failure <0.1 <1

Intact containment Negligible negligible

Total 2.14 100

(a) One person-rem = 0.01 person-Sv

F.2.2. Review of Nebraska Public Power District's Risk Estimates

NPPD's determination of offsite risk at CNS is based on the following three major elements of

analysis:

0 the Level 1 and 2 risk models that form the basis for the 1993 IPE submittal

(NPPD, 1993) and the external event analyses of the 1996 IPEEE submittal

(NPPD, 1996)

0 the major modifications to the IPE model that have been incorporated in the

CNS PSA

0 the MACCS2 analyses performed to translate fission product source terms and

release frequencies from the Level 2 PSA model into offsite consequence

measures

Each of these analyses was reviewed to determine the acceptability of the NPPD risk estimates

for the SAMA analysis, as summarized below.

The NRC staffs review of the CNS IPE is described in an NRC report dated February 14, 1996

(NRC, 1996). Based on a review of the IPE submittal and responses to RAIs, the NRC staff

concluded that the IPE submittal met the intent of Generic Letter (GL) 88-20 (NRC, 1988); that

is, the licensee's IPE process is capable of identifying the most likely severe accidents and

severe accident vulnerabilities. Although no vulnerabilities were identified in the IPE, several

improvements to the plant or procedures were identified. These improvements have been either

implemented at the site or addressed in the SAMA evaluation process (NPPD, 2008). These

improvements are discussed in Section F.3.2.

There have been five revisions to the IPE model since the 1993 IPE submittal. A listing of the

major changes in each revision of the PSA was provided by NPPD in the ER and is summarized

in Table F-3. A comparison of the internal events CDF between the 1993 IPE and the 2007TM

Revision 1 PSA model used for the SAMA evaluation indicates a decrease of approximately

88 percent (from 8.0 x 10.5 per year to 9.3 x 10-6 per year). A description of those changes that

resulted in the greatest impact on the internal event CDF is provided in Section E. 1.4 of the ER

(NPPD, 2008). The decrease is mainly attributed to plant and modeling improvements made

between the IPE and the 1996b model update.

NUREG-1437, Supplement 41 F-4 July 2010
Appendix F

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

CDF

PSA Version Summary of Changes from Prior Model (per year)

1993 IPE Submittal (excluding internal flooding) 8.0 x 10-5

1996b - Revised the human reliability analysis to incorporate revisions to 1.3 - 10-5

emergency operating procedures

- Added credit for newly installed torus hard pipe vent

- Corrected conservative thermal hydraulic analysis of safety relief valve

(SRV) flow

- Improved loss of offsite power model

2001a - Incorporated minor improvements stemming from the 9/97 peer review 1.3 x 105

- Updated component failure and unavailability database

- Developed LERF model

2005TM Updated initiating event frequencies to reflect information in 1.1 × 105

NUREG/CR-6890

2006TM Updated model to support the Mitigating System Performance Index 1.4 × 10-5

(MSPI) and maintenance rule update

2007TM - Added internal flooding to the Level 1 model 9.3 - 10-6

(Revision 1) - Incorporated operator action dependencies

- Expanded the treatment of common cause failures

- Developed a more detailed CET and new Level 2 fault trees

- Added new Level 1 system models including severe accident mitigation

strategies such as firewater injection

- Updated PSA model data

- Developed initiator fault trees to calculate some initiating event

frequencies, such as loss of turbine equipment cooling (TEC)

The CDF value from the 1993 CNS IPE (8.0 x 10-5 per year) is near the upper end of the range

of the CDF values reported in the IPEs for other boiling-water reactor (BWR) 3/4 plants.

Figure 11.2 of NUREG-1560 shows that the FPE-based total internal events CDF for BWR 3/4

plants ranges from about 9 x 10.8 per year to 1 x 104 per year, with an average CDF for the

group of 2 x 10.5 per year (NRC, 1997b). It is recognized that other plants have updated the

values for CDF subsequent to the IPE submittals to reflect modeling and hardware changes.

The internal events CDF result for CNS used for the SAMA analysis (9.3 x 10-6 per year) is

comparable to other plants of similar vintage and characteristics.

The NRC staff considered the peer reviews performed for the CNS PSA and the potential

impact of the review findings on the SAMA evaluation. In the ER (NPPD, 2008), NPPD

described the BWROG peer review of the 2007TM Revision I model conducted in May 2008.

The peer review was performed using the Nuclear Energy Institute (NEI) 05-04 process

(NEI, 2007), the American Association of Mechanical Engineers (ASME) PRA Standard

(ASME, 2007), and NRC Regulatory Guide 1.200, Revision 1 (NRC, 2007). The NRC staff

asked NPPD to provide a summary of each of the peer review findings and an assessment of

the impact of resolving each finding on the SAMA identification and analysis results

(NRC, 2009). In response to this request, NPPD provided a table summarizing the peer review

findings in relation to the applicable supporting requirements (SR) and an assessment of the

impact of the resolution of the findings on the PSA results (NPPD, 2009a). The peer review

identified 22 findings against the SR, including 10 classified as not met. The 10 not-met findings

I

July 2010 F-5 NUREG-1437, Supplement 41
Appendix F

included documentation of analysis bases, PSA configuration control, identification of internal

flooding mechanisms, and evaluation of human error dependencies. NPPD's review of the 22

peer review findings resulted in no changes to the PSA model and no impacts on the SAMA

identification and analysis results. The NRC staff considers NPPD's rationale reasonable and

that the final resolution of the peer review findings is not likely to impact the results of the SAMA

analysis.

Because the CNS internal events PSA model has been peer-reviewed and the peer review

findings were all addressed, and NPPD has satisfactorily addressed NRC staff questions

regarding the PSA, the NRC staff concludes that the internal events Level 1 PSA model is of

sufficient quality to support the SAMA evaluation.

As indicated above, the current CNS PSA does not include external events. In the absence of

such an analysis, NPPD used the CNS IPEEE to identify the highest risk accident sequences

and the potential means of reducing the risk posed by those sequences, as discussed below

and in Section F.3.2.

The CNS IPEEE was submitted in October 1996 (NPPD, 1996), in response to Supplement 4 of

GL 88-20 (NRC, 1991). These submittals included a seismic margins analysis, an internal fire

PSA, and evaluations of high winds, external flooding, and other hazards. While no fundamental

weaknesses or vulnerabilities to severe accident risk in regard to the external events were

identified, several opportunities for risk reduction were identified as discussed below. In a letter

dated April 27, 2001, the NRC staff concluded that the submittal met the intent of Supplement 4

to GL 88-20, and that the licensee's IPEEE process is capable of identifying the most likely

severe accidents and severe accident vulnerabilities (NRC, 2001).

The CNS IPEEE used a focused scope Electric Power Research Institute (EPRI) seismic

margins analysis which was completed in conjunction with the Seismic Qualification User's

Group (SQUG) program (SQUG, 1992). This method is qualitative and does not provide

numerical estimates of the CDF contributions from seismic initiators (EPRI, 1991). For this

I assessment, the review level earthquake (RLE) value for CNS was specified by the NRC to be

0.3g. Plant walkdowns were performed in which components and structures were screened for

the RLE based on the EPRI guidelines, and specific high confidence in low probability of failure

(HCLPF) capacities were calculated for components and structures that did not screen out. All

structures and all but six components were screened out, of which five were Unresolved Safety

Issue (USI) A-46 program outliers. Several improvements were identified to address the six

unscreened components and to reduce seismic risk. While some of these improvements have

been implemented, all were addressed as SAMA candidates, as discussed in Section F.3.2.

The NRC review and closure of USI A-46 for CNS is documented in a letter dated

September 30, 1999 (NRC, 1999).

To provide additional insight into the appropriate seismic CDF to use for the SAMA evaluation,

I the NRC staff developed an independent estimate of the seismic CDF for CNS using the

simplified-hybrid approximation method described in a paper by Robert P. Kennedy, entitled

"Overview of Methods for Seismic PRA and Margin Analysis Including Recent Innovations"

(Kennedy, 1999) and using updated 2008 seismic hazard curve data from the U.S. Geological

Survey (USGS, 2008). The NRC staffs independent calculations indicate the seismic CDF for

CNS to be approximately 6 x 10-6 per year depending on the seismic hazard curve and plant

fragility assumptions. Since NPPD did not provide a seismic CDF contribution in the ER, the

NRC staff used this result to assess the appropriateness of the external event multiplier used in

the SAMA evaluation.

NUREG-1437, Supplement 41 F-6 July 2010
Appendix F

The CNS IPEEE fire analysis employed a combination of PSA with the EPRI's fire-induced

vulnerability evaluation (FIVE) methodology (EPRI, 1993). Fire compartments were initially

qualitatively screened out if all compartment boundaries screened out according to Fire

Compartment Interaction Analysis (FCIA) criteria and if the compartment did not contain

Appendix R equipment. Quantitative screening was then performed using fire frequencies based

on the FIVE methodology and the assumption that fire failed all of the equipment in the

compartment. The sequence was then quantified using the internal events PSA model. If the

CDF was greater than 1 x 10-6 per year, the compartment was subjected to more detailed

analysis. In this analysis, the FIVE fire screening methodology was used in the fire modeling

with one exception. The exception involved the partitioning of oil spill fires into large and small

spills based on a recommendation in the "EPRI Fire PRA Implementation Guide" (EPRI, 1994).

The total fire CDF, found by summing the values for all compartments, is 1.9 x 10-5 per year.

The fire compartments having a fire CDF greater than 1 x 10-7 per year and their contributions to

the fire CDF are listed in Table F-4.

In the ER, NPPD identifies a number of conservatisms in the fire analysis, including:

0 The NRC fire events database indicates a trend toward lower frequency and

less severe fires since the IPEEE fire analysis was performed.

* Because of little industry experience with crew actions following a fire, crew

actions were conservatively characterized in the fire model.

0 A fire that damaged a cable was assumed to always induce a conductor failure.

* Manual fire suppression was only credited in the control room and non-essential

switchgear rooms.

* Hardware repair activities were not credited.

The NRC staff inquired about additional measures that NPPD had already taken to reduce fire

risk since the IPEEE (NRC, 2009). NPPD provided a description of the measures taken in the

four dominant fire compartments (3A-switchgear room 1F, 3B-switchgear room 1G, 1OB-control

room and security access control corridor, and 20A-SW pump room). These measures

consisted primarily of improvements to monitoring and controlling the quantity of combustible

materials and pre-staging of outage materials.

July 2010 F-7 NUREG-1437, Supplement 41
Appendix F

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

Core Damage Frequency

Fire Compartment

10B

3B

20A

3A

8-1

9A

2A/2C

8G

8B

8F

14A

14B

7A

4A/4C/4D

8A

98

8H

13B

3C/3D/3E

8E

IF

12D

1B/1G

Fire Compartment Description

Control Room and Security Alarm Station (SAS) Corridor

Switchgear Room 1G

SW Pump Room

Switchgear Room 1 F

Condenser Pit Area

Cable Spreading Room

Reactor Building El. 903'-6" - Control Rod Drive (CRD)

Units - North/South

DC Switchgear Room 1B

Reactor Protection System (RPS) Room 1B

Battery Room 16

Emergency Diesel Generator (EDG) Room 1A

EDG Room 1B

Residual Heat Removal Service Water (RHRSW) Booster

and Service Air Compressor

Reactor Building El. 958'-3" - Fuel Pool Heat

Exchanger/Lube Oil

Auxiliary Relay Room

Cable Expansion Room

DC Switchgear Room 1A

Non-Critical Switchgear Room

Reactor Building El. 932'-6" - REC

Battery Room 1A

Suppression Pool Area

Turbine Building Floor- North El. 903'-6"

Core Spray (CS) and CRD Room

Other Compartments

CDF

(per year)

3.7 x 10.6

2.7 x 10.0

1.7x 10"6

1.1 . 10-6

9.7 x 10-7

8.2 x 107

8.2 x 10.7

7.9 x 10'7

7.3 x 10'7

6.7 x 107

6.1 x 107

6.1 x 10-7

5.6 x 10-7

5.4 x 10-7

3.7 x 10-7

3.4 x 10-7

3.4 x 107

3.3 x 10-7

2.7 x 10-7

1.8x 10-7

1.7 x 10'

1.4 x 10-7

1.0 x 10-7

6.4 x 107

Total Fire CDF 1.9 x 10"

Based on the conservatisms in the analysis and the actions taken by NPPD to reduce fire risk

since the IPEEE, the NRC staff concludes that the fire CDF of 1.9 x 10-5 per year is reasonable

for the SAMA analysis.

The CNS IPEEE analysis of high winds, tornadoes, external floods, and other external events

followed the screening and evaluation approaches specified in Supplement 4 to GL 88-20

(NRC, 1991) and did not identify any sequences or vulnerabilities that exceeded the 1.0 x 10

NUREG-1437, Supplement 41 F-8 July 2010
Appendix F

per year criterion except for the design-basis tornado and a lightning strike to the control

building (NPPD, 1996). Plant improvements were identified to address each of these issues and

included as SAMA candidates, as discussed in Section F.3.2. The NRC staff concluded in the

review of the CNS IPEEE that the tornado missiles contribution to CDF is less than the

screening criteria and that lightning did not pose a significant hazard to the plant (NRC, 2001).

Based on the aforementioned results, including the NRC staff assessment of the CNS seismic

CDF, the external events CDF is approximately two times the internal events CDF (based on a

seismic CDF of 6 x 10-6 per year, a fire CDF of 1.9 x 10-5 per year, and an internal events CDF

of 1.2 x 10.5 per year). Accordingly, the NRC staff concurred with NPPD's conclusion that the

total CDF (from internal and external events) would be approximately three times the internal

events CDF. In the SAMA analysis submitted in the ER, NPPD tripled the benefit that was

derived from the internal events model to account for the combined contribution from internal

and external events. The NRC staff agrees with the licensee's overall conclusion concerning the

multiplier used to represent the impact of external events and concludes that the licensee's use

of a multiplier of 3 to account for external events is reasonable for the purposes of the SAMA

evaluation. This is discussed further in Section F.6.2.

The NRC staff reviewed the general process used by NPPD to translate the results of the Level

1 PSA into containment releases, as well as the results of the Level 2 analysis, as described in

the ER and in response to NRC staff requests for additional information (NPPD, 2008),

(NPPD, 2009a). This model is an updated version of the model used in the IPE and reflects the

CNS configuration and design as of December 2007. Major revisions and updates to the Level 2

model include equipment performance data for failure rates and system unavailability, plant

configuration changes, improved modeling techniques, inclusion of additional PDS bins to

improve the Level 1 and Level 2 PSA interface, and updated accident progression and source

term analyses using a later version of the MAAP computer code. The Level 1 core damage

sequences are binned into one of 15 PDS bins which provide the interface between the Level 1

and Level 2 analysis. The PDS, which are described in Table E.1-8 of the ER (NPPD, 2008),

are defined by a set of functional characteristics for system operation which are important to

accident progression, containment failure, and source term definition. The Level 2 models use a

single CET for each PDS with functional nodes representing both systemic and

phenomenological events. The CET is used to determine the appropriate release category for

each Level 2 sequence. CET nodes are evaluated using supporting fault trees and logic rules.

NPPD characterized the releases for the spectrum of possible radionuclide release scenarios

using a set of 12 release categories based on the timing and magnitude of the release and

whether or not the containment remained intact. The frequency of each release category was

obtained by summing the frequency of the individual accident progression CET endpoints

binned into the release category. The release characteristics for each release category were

developed by grouping the hundreds of source terms generated for internal initiators into the

12 categories based on similar properties. Source term release fractions were developed for

each of the 12 release categories using the results of 46 MAAP 4.0.5 computer code

calculations (NPPD, 2009a). In response to an NRC staff RAI, NPPD identified that for each

CET sequence, a value for each of the release-to-environment mass fractions was obtained

from the representative MAAP calculation (NPPD, 2009a). These mass fractions were then

weighted according to the contribution of that sequence to the sum of the sequences in the end

state bin. The final mass fraction representing the end state bin was the sum of these individual

weighted mass fractions for each species. The release categories, their frequencies, and

release characteristics are presented in Tables E.1-6, E.1-7, E.1-9, and E.1-10 of the ER,

respectively (NPPD, 2008).

July 2010 F-9 NUREG-1437, Supplement 41
Appendix F

The NRC staff noted that the iodine and cesium mass fractions for the low-low intermediate

release category in Table E.1-10 of the ER are substantially less than the corresponding mass

fractions for the low-low early and low-low late release categories and requested NPPD to

provide an explanation for this apparent anomaly (NRC, 2009). In response, NPPD explained

that the dominant sequences for the low-low intermediate release category involve offsite

release via containment venting through an intact suppression pool, resulting in effective fission

product scrubbing (NPPD, 2009a). In contrast, the dominant sequences for the low-low early

and low-low late release categories involve release paths from the primary containment that

bypass the suppression pool, resulting in much less fission product scrubbing than for the

low-low intermediate release category. Consequently, the cesium and iodine mass fractions for

the low-low intermediate release category will be less than that for the low-low early and low-low

late release categories.

The NRC staff requested NPPD provide an explanation of the reasons for the difference in the

total release frequency value of 1.2 x 105 derived from the CET and the Level 1 CDF value of

9.3 x 106 and to provide the rationale for using the total release frequency for the SAMA

analysis (NRC, 2009). In response, NPPD indicated that (NPPD, 2009a):

The total release frequency derived from the CET is larger than the Level 1 CDF

because of the methodology used in the CET for deriving the split fraction

values. The CET contains numerous paths that do not meet the rare event

approximation criterion (e.g., split fractions greater than 5 x 10-2) in the

quantification approach used. For these paths, the sum of the split fractions for

the corresponding failure and success branches is greater than 1 resulting in a

conservatively high total CDF.

Since the SAMA evaluation requires both Level 1 and 2 PSA results, NPPD

chose the higher value from the CET as the basis for quantifying SAMA

benefits.

NPPD concludes that use of the release frequency, rather than the Level 1 CDF, will have a

negligible impact on the results of the SAMA evaluation because the delta risk calculation,

performed to assess SAMA benefits, effectively cancels out the impact of the simplified model

quantification methodology, and because the external event multiplier and uncertainty multiplier

used in the SAMA analysis (discussed in Section F.6.2) have a much greater impact on the

SAMA evaluation results than the small error arising from the model quantification approach.

The NRC staff agrees with this conclusion.

The NRC staff's review of the Level 2 IPE concluded that it addressed the most important

severe accident phenomena normally associated with the Mark I containment type, and

identified no significant problems or errors (NRC, 1996). The changes to the Level 2 model

since the IPE to update the methodology and to address peer review recommendations are

described in Section E.1.4 of the ER. The Level 2 PSA model was included in the May 2008

BWROG peer review mentioned previously. Of the 22 peer review findings, one finding in the

SR not-met category was related to identification of limitations in the LERF analysis that would

impact applications. In response to an NRC staff RAI, NPPD reviewed this finding and

determined that there were no limitations that would impact projected applications that are not

already documented, and concluded that the finding would not impact the results of the SAMA

analysis.

NUREG-1437, Supplement 41 F-1 0 July 2010
Appendix F

Based on the NRC staffs review of the Level 2 methodology, the fact that the Level 2 model

was reviewed in more detail as part of the BWROG peer review and that the peer review

findings do not impact the SAMA analysis, and the responses to the RAIs concerning the

analysis and review process, the NRC staff concludes that the Level 2 PSA provides an

acceptable basis for evaluating the benefits associated with various SAMAs.

As indicated in the ER, the reactor core radionuclide inventory used in the consequence

analysis was derived from ORIGEN2 calculations using a bounding core enrichment and burnup

for CNS. A core power of 2,429 megawatts-thermal (MWt) was assumed to bound the licensed

maximum power of 2,419 MWt for the CNS Measurement Uncertainty Recapture power uprate

approved by the NRC in 2008. The NRC staff requested additional information about the

expected fuel burnup and management for the renewal period (NRC, 2009). NPPD responded

that the bounding core inventory assumed an initial enrichment of 3.908 weight percent

uranium-235 and 1,300 effective full-power days (EFPD) of continuous operation to achieve an

end of cycle core average exposure of 35.8 Gwd/MT (NPPD, 2009a), and that this core

inventory reflects the expected fuel management/burnup for the renewal period.

The NRC staff reviewed the process used by NPPD to extend the containment performance

(Level 2) portion of the PSA to an assessment of offsite consequences (Level 3). This included

consideration of the source terms used to characterize fission product releases for the

applicable containment release categories and the major input assumptions used in the offsite

consequence analyses. Version 1.13.1 of the MACCS2 code was used to estimate offsite

consequences. Plant-specific input to the code includes the source terms for each release

category and the reactor core radionuclide inventory (both discussed above), site-specific

meteorological data, projected population distribution within a 50-mi (80-km)) radius for the year

2034, emergency evacuation modeling, and economic data. This information is provided in

Attachment E to the ER (NPPD, 2008).

NPPD used site-specific meteorological data for the 5 years, 2002 through 2006, as input into

the MACCS2 code. NPPD averaged the data over this interval for this study. The data were

collected from the onsite meteorological monitoring system and regional National Weather

System (NWS) stations. Regional mixing heights were estimated using ground level and

upper-air data collected at NWS station No. 94980 in Valley, NE (approximately 76 mi (120 km)

north-northwest of CNS), and station No. 72553 in Falls City/Brenner, NE (approximately 19 mi

(30 km) south of CNS). Missing data were estimated using data substitution methods. These

methods include substitution of missing data with valid data from the previous hour, or valid data

collected from other elevations on the meteorological tower. The NRC staff notes that previous

SAMA analyses results have shown little variation resulting from year-to-year differences in

meteorological data and concludes that the approach taken for collecting and applying the

meteorological data in the SAMA analysis is reasonable.

The population distribution used by the licensee as input to the MACCS2 analysis was

estimated for the year 2034 based on county-level projections obtained from the University of

Nebraska Bureau of Business Research (UN, 2007), Woods & Poole Economics, Inc. for Iowa

(Woods & Poole, 2006), Eklund et al. for Kansas (Eklund et al., 1999), and the Missouri Census

Data Center (Missouri, 2007). Year 2005 tourist information was used to estimate the transient

population in Iowa, Missouri, and Nebraska (IDED, 2006), (Kaylen, 2006), (NDED, 2006). Year

2004 tourist information was used to estimate the transient population for year 2005 in Kansas

(Global Insight, 2006). These data were used to project county-level populations using a

regression method to extrapolate population projections to 2034. For the counties with

populations in decline, the population value for year 2014 was used, which corresponds to the

July 2010 F-1 1 NUREG-1 437, Supplement 41
Appendix F

I license expiration date for CNS. The NRC staff considers the methods and assumptions for

estimating population reasonable and acceptable for purposes of the SAMA evaluation.

The emergency evacuation model was modeled as a single evacuation zone extending out

10 mi (16 km) from the plant. NPPD assumed that 100 percent of the population would move at

an average speed of approximately 19.5 miles per hour (mph) (8.7 meters per second (m/s))

with a delayed start time of 2 hours (NPPD, 2008). The evacuation speed and time were based

on the average values identified in the Missouri and Nebraska time estimate studies. NPPD

performed sensitivity analyses in which the evacuation delay time was increased to 4 hours, and

the evacuation speed was decreased to 1 m/s. Each of these sensitivity cases resulted in less

than a 1 percent increase in the total population dose. The 100 percent population evacuation

assumption is slightly less conservative than the assumption used in NUREG-1 150 study

(NRC, 1990), which assumed evacuation of 99.5 percent of the population within the emergency

planning zone (EPZ). The NRC staff asked NPPD to address the potential impact on the

population dose if 5 percent of the population fails to evacuate the EPZ (NRC, 2009). In

response, NPPD performed a sensitivity analysis that showed only a slight increase in

population dose (less than 1 percent) would result (NPPD, 2009a). The NRC staff concludes

that the evacuation assumptions and analysis are reasonable and acceptable for the purposes

of the SAMA evaluation.

Much of the site-specific economic data was obtained from the 2002 Census of Agriculture

(USDA, 2002). These included the value of farm and non-farm wealth. Other generic data that

applies to the region as a whole, such as the cost of evacuating and relocating people, land

decontamination, and property decontamination, were obtained from the code manual for

MACCS2 (NRC, 1998). The data from the MACCS2 code manual were inflation-adjusted using

the consumer price index corresponding to the year 2006. Information on regional crops was

obtained from the 2002 Census of Agriculture. Crops for each county were mapped into the

seven MACCS2 crop categories.

The NRC staff concludes that the methodology used by NPPD to estimate the offsite

consequences for CNS provides an acceptable basis from which to proceed with an

assessment of risk reduction potential for candidate SAMAs. Accordingly, the NRC staff based

its assessment of offsite risk on the CDF and offsite doses reported by NPPD.

F.3. Potential Plant Improvements

The process for identifying potential plant improvements, an evaluation of that process, and the

improvements evaluated in detail by NPPD are discussed in this section.

F.3.1. Process for Identifying Potential Plant Improvements

NPPD's process for identifying potential plant improvements (SAMAs) consisted of the following

elements:

* review of the most significant basic events from the current, plant-specific PSA

* review of potential plant improvements identified in the CNS IPE and IPEEE

* review of SAMA candidates identified for license renewal applications for 11

other U.S. General Electric (GE) plants

NUREG-1437, Supplement 41 F-12 July 2010
Appendix F

* review of other NRC and industry documentation discussing potential plant

improvements

Based on this process, an initial set of 244 candidate SAMAs, referred to as Phase I SAMAs,

was identified. In Phase I of the evaluation, NPPD performed a qualitative screening of the initial

list of SAMAs and eliminated SAMAs from further consideration using the following criteria:

* the SAMA modified features are not applicable to CNS

* the SAMA has already been implemented at CNS

* the SAMA is similar in nature and could be combined with another SAMA

candidate

Based on this screening, 164 SAMAs were eliminated leaving 80 for further evaluation. The

remaining SAMAs, referred to as Phase II SAMAs, are listed in Table E.2-2 of the ER

(NPPD, 2008). In Phase II, a detailed evaluation was performed for each of the 80 remaining

SAMA candidates, as discussed in Sections F.4 and F.6 below. To account for the potential

impact of external events, the estimated benefits, based on internal events, were multiplied by a

factor of 3, as previously discussed.

F.3.2. Review of Nebraska Public Power District's Process

NPPD's efforts to identify potential SAMAs focused primarily on areas associated with internal

initiating events. The initial list of SAMAs generally addressed the accident sequences

considered to be important to CDF from functional, initiating event, and risk reduction worth

(RRW) perspectives at CNS, and included selected SAMAs from prior SAMA analyses for other

plants.

NPPD provided a tabular listing of the PSA basic events sorted according to their RRW

(NPPD, 2008). SAMAs impacting these basic events would have the greatest potential for

reducing risk. NPPD used an RRW cutoff of 1.005, which corresponds to about a 0.5 percent

change in CDF given 100-percent reliability of the SAMA. This equates to a benefit of

approximately $5,300 (after the benefits have been multiplied to account for external events).

NPPD also provided and reviewed the LERF-based RRW events down to an RRW of 1.005.

NPPD correlated the top Level 1 and Level 2 events with the SAMAs evaluated in the ER and

showed that all of the significant basic events are addressed by one or more SAMAs

(NPPD, 2008).

The NRC staff asked NPPD to provide the rationale for identifying candidate SAMAs for

LERF-based success events (NRC, 2009). In response to the RAI, NPPD replied that, unlike

SAMAs identified for the purpose of decreasing the risk of failure events, SAMAs identified for

success events are intended to decrease the risk contribution from the cutsets or basic events

related to the success event (NPPD, 2009a). NPPD further noted that SAMAs identified for

success events are also identified for related failure events and provided specific examples of

this relationship. The staff finds NPPD's treatment of success events acceptable.

The NRC staff also asked NPPD to clarify how RRW was calculated for complementary events

and to provide an assessment of the impact on the SAMA identification and evaluation process

if complementary events were not directly coupled in the computation of RRW (NRC, 2009).

July 2010 F-1 3 NUREG-1437, Supplement 41
Appendix F

NPPD responded that complementary events were directly coupled in the calculation of RRW,

provided an example of this direct coupling, and concluded that since this coupling was

performed correctly there is no impact on the SAMA identification and evaluation process

(NPPD, 2009a). The NRC staff agrees that NPPD appropriately accounted for direct coupling of

complementary events in the calculation of RRW.

The NRC staff requested clarification on the screening criteria used for the Phase I SAMAs

because the ER was inconsistent in describing this process (NRC, 2009). NPPD responded that

the criteria for screening Phase I SAMAs based on SAMA modifying features not applicable to

CiNS is broader than this description suggests and includes: (1) SAMAs that have already been

analyzed for CNS and determined to be of low benefit, and (2) SAMAs that have been

previously resolved with NRC based on further evaluation that determined that the modification

was not necessary (NPPD, 2009).

For a number of the Phase II SAMAs listed in the ER, the information provided did not

sufficiently describe the proposed modification. Therefore, the NRC staff asked the applicant to

provide more detailed descriptions of the modifications for several of the Phase II SAMA

candidates (NRC, 2009). In response to the RAI, NPPD provided the requested information on

the modifications for SAMAs 20, 44, 45, 63, 70, 72, 73, 76, 77, and 80 (NPPD, 2009a).

NPPD considered the potential plant improvements described in the IPE and IPEEE in the

identification of plant-specific candidate SAMAs for internal and external events. Although the

IPE did not identify any vulnerabilities, seven potential enhancements to the plant, procedures,

and training at CNS were identified as part of the IPE process. The seven enhancements

include (NPPD, 1993):

* .upgrading the plant-specific emergency operating procedures based on

Revision 4 of the BWROG Emergency Procedure Guidelines

* performing a load study to relax the assumed 4-hour battery lifetime and provide

a procedure to improve battery loading schemes

providing a procedure to bypass the AC solenoid valve on the nitrogen supply

line to the SRVs

* providing a diesel-driven fire water pump or other similar source of low pressure

water independent of AC power

* improving the reliability of the high pressure coolant injection (HPCI) and reactor

core isolation cooling (RCIC) systems

* providing a backup for the SW pumps by modifying the existing system and

making procedural changes

* providing improved drywell spray capability

NPPD noted that the first four of these enhancements have already been implemented at CNS

and the remaining three enhancements are addressed by SAMAs. The fifth enhancement is to

improve the reliability of the HPCI and RCIC systems, as addressed by Phase II SAMA 35, "provide a redundant train or means of ventilation," and SAMA 67, "improve the reliability of the

NUREG-1437, Supplement 41 F-14 July 2010
Appendix F

HPCI and RCIC systems by upgrading their control systems." The sixth enhancement is to

provide a backup for the SW pumps, as addressed by Phase II SAMA 68, "proceduralize the

ability to cross-connect the circulating water pumps and the SW going to the TEC heat

exchangers." The last enhancement, to provide an improved drywell spray capability, was

judged to be already implemented at CNS where the fire water system is used as a backup

source for the drywell spray system. Nevertheless, NPPD further addressed this enhancement

with Phase II SAMA 47, "install a passive drywell spray system to provide a redundant drywell

spray method."

Based on this information, the NRC staff concludes that the set of SAMAs evaluated in the ER,

together with those identified in response to NRC staff RAIs, addresses the major contributors

to internal event CDF.

Several seismic-related improvements were identified in the CNS IPEEE. The specific seismic

interaction issues are as follows (NPPD, 1996):

a potential relay chatter at low seismic levels for 10 relays

0 potential impact of the 480-volt (V) critical switchgear 1 G with an adjacent

concrete beam

0 potential seismic interaction of the solatron/accuvolt line conditioners with a

stairway supported by a masonry wall

0 potential inadequate seismic capacity for the SE and NE quad recirculation fans

0 potential impact of the jet pump instrument rack A with an adjacent rack

0 inadequate anchorage capacity for loose equipment in the control room and lack

of support for the overhead lighting diffusers

* inadequate anchorage for the aux relay room panels

* inadequately braced unistrut trapeze frame in the northeast corner of elevation

903 feet of the reactor building

loose bolt securing on one corner of an interior panel of the SW pump B & D

strainer control panel

All of these were identified as Phase I SAMAs but have already been implemented or previously

resolved under the USI A-46 Program (NRC, 2001). As a result, no Phase II SAMAs were

identified to address these issues. The CNS IPEEE seismic/fire interaction evaluation did

conclude that the CNS water-based fire protection systems were vulnerable to a seismic event.

This vulnerability was addressed by Phase II SAMA 69, "upgrade the seismic capacity of the

diesel fire pump fuel tank and water supply tank." The NRC staff concludes that the opportunity

for seismic-related SAMAs has been adequately explored and that it is unlikely that there are

additional potentially cost-beneficial, seismic-related SAMA candidates.

July 2010 F-15 NUREG-1437, Supplement 41
Appendix F

The CNS IPEEE fire assessment concluded that the four fire compartments (Control Room and

SAS Corridor, Switchgear Rooms 1F and 1G, and SW Pump Room) that did not screen out

based on having a fire CDF of less than 1.0 x 10-6 per year represent vulnerabilities

(NPPD, 1996). Two plant improvements were identified to address these risk contributors:

addition of a feature to allow remote control of the switchyard breakers from the

control room, or to have a preplanned recovery/repair action for control of the

switchyard breakers following a fire, and

0 provide a diverse water supply for the SW system

Both of these were identified as Phase I SAMAs. As indicated in the ER, an evaluation of

improvements for control of the switchyard breakers showed a decrease in CDF of less than

0.5 percent, therefore, this change was not implemented or evaluated as a Phase II SAMA. The

second improvement was evaluated as Phase II SAMA 68, "proceduralize the ability to

cross-connect the circulating water pumps and the SW pumps going to the TEC heat

exchangers." NPPD also identified two additional Phase II SAMAs to reduce the fire CDF in

dominant fire zones without suppression and in the control room: (1) SAMA 63, "add automatic

fire suppression systems to the dominant fire zones," and (2) SAMA 65, "upgrade the ASDS

panel to include additional system controls for the opposite division." The NRC staff concludes

that the opportunity for fire-related SAMAs has been adequately explored and that it is unlikely

that there are additional potentially cost-beneficial, fire-related SAMA candidates.

As stated earlier, other external hazards (e.g., high winds, external floods, transportation and

nearby facility accidents) are below the threshold screening frequency and are not expected to

impact the conclusions of the SAMA analysis. Nevertheless, two plant improvements were

identified to address the risk contribution from tornados and lightning:

* protect the diesel generator exhaust system from tornado-generated missiles

* reduce the potential vulnerability of the control building to a lightning-induced

loss of offsite power that also affects the station batteries

Both were identified as Phase I SAMAs. The first, Phase I SAMA 232, "protect the diesel

exhaust from tornado missiles," has already been implemented at CNS. The NRC inquired

about this SAMA being described as resolved in 1998, while the IPEEE safety evaluation report

(SER) stated that the issue had yet to be addressed. NPPD responded that the matter was

resolved by a letter from NPPD to the NRC in 2001 clarifying that the modification was in fact

completed in 1998. The second improvement was further evaluated and it was determined that

the control building was not vulnerable to a lightning-induced loss of offsite power which might

affect the station batteries.

The NRC staff questioned NPPD about lower cost alternatives to some of the SAMAs evaluated

(NRC, 2009), including:

providing additional space cooling to the RHRSW booster pump rooms, CS

pump rooms, residual heat removal (RHR) pump rooms, SW pump rooms, and

HPCI pump room via the use of portable equipment

NUREG-1437, Supplement 41 F-16 July 2010
Appendix F

* improving alternate shutdown training and equipment

* enhancing DC power availability (provide cables from diesel generators or

another source to directly power battery chargers)

developing guidance/procedures for local, manual control of reactor core

isolation cooling following loss of DC power

* enhancing manual venting of containment using either a local hand wheel or

gas bottle supplies as a possible alternative for containment pressure control

In response to the RAIs, NPPD addressed the suggested lower cost alternatives

(NPPD, 2009a). This is discussed further in Section F.6.2.

The NRC staff notes that the set of SAMAs submitted is not all-inclusive, since additional,

possibly even less expensive, design alternatives can always be postulated. However, the NRC

staff concludes that the benefits of any additional modifications are unlikely to exceed the

benefits of the modifications evaluated and that the alternative improvements would not likely

cost less than the least expensive alternatives evaluated when the subsidiary costs associated

with maintenance, procedures, and training are considered.

The NRC staff concludes that NPPD used a systematic and comprehensive process for

identifying potential plant improvements for CNS, and that the set of SAMAs evaluated in the

ER, together with those evaluated in response to NRC staff inquiries, is reasonably

comprehensive and, therefore, acceptable. This search included reviewing insights from the

plant-specific risk studies and reviewing plant improvements considered in previous SAMA

analyses. While explicit treatment of external events in the SAMA identification process was

limited, it is recognized that the prior implementation of plant modifications for fire risks and the

absence of external event vulnerabilities reasonably justifies primarily examining the internal

events risk results for this purpose.

F.4. Risk Reduction Potential of Plant Improvements

NPPD evaluated the risk-reduction potential of the 80 remaining SAMAs that were applicable to

CNS. The majority of the SAMA evaluations were performed in a bounding fashion-the SAMA

was assumed to completely eliminate the risk associated with the proposed enhancement. On

balance, such calculations overestimate the benefit and are conservative.

NPPD used model requantification to determine the potential benefits. The CDF, population

dose, and offsite economic cost reductions were estimated using the CNS 2007TM model,

Revision 1. The changes made to the model to quantify the impact of SAMAs are detailed in

Section E.2.3 of Attachment E to the ER (NPPD, 2008). Table F-5 lists the assumptions

considered to estimate the risk reduction for each of the evaluated SAMAs, the estimated risk

reduction in terms of percent reduction in CDF and population dose, and the estimated total

benefit (present value) of the averted risk. The estimated benefits reported in Table F-5 reflect

the combined benefit in both internal and external events. The determination of the benefits for

the various SAMAs is further discussed in Section F.6.

The NRC staff questioned the assumptions used in evaluating the benefits or risk reduction

estimates of certain SAMAs provided in the ER (NRC, 2009). For example, for SAMA 6, "change the time available to recover offsite power to 24 hours," the NRC staff requested

July 2010 F-17 NUREG-1437, Supplement 41
Appendix F

clarification on the modeling assumption provided in ER Table 2-2 for this SAMA, which is

inconsistent with the modeling assumption for analysis Case 6, "set failure probability to transfer

the RPS panels to their alternate power source to zero" (NRC, 2009). In response to the RAI,

NPPD clarified that the modeling assumption for SAMA 6, as provided in Table 2-2 of the ER,

was incorrect and should have been the same as described for Case 6. The correct modeling

assumption was used in the cost benefit analysis (NPPD, 2009a).

For SAMA 14, "portable generator for DC power to supply individual panels," the NRC staff

asked NPPD to clarify the rationale for using the modeling assumption for Case 14, which was

to set the CDF contribution due to unavailability of the HPCI system to zero in the Level 1

PSA model (NRC, 2009). In response to the RAI, NPPD explained that the benefit of providing

an alternate DC power source to HPCI to support emergency core cooling was judged to be

larger than the benefit of providing an alternate DC power source to other panels based on:

(1) the importance of HPCI in intermediate LOCA sequences, and (2) the fact that the

turbine-driven HPCI pump can continue to run in SBO sequences as long as DC control power

is available (NPPD, 2009a). The NRC staff further asked NPPD to explain the large CDF

reduction for this SAMA (32 percent) when the CDF contribution from HPCI unavailability due to

test and maintenance is only 3 percent. In response to the RAI, NPPD responded that the

evaluation of this SAMA conservatively assumes HPCI never fails, which eliminates the CDF

contribution from all events contributing to HPCI unavailability, not just the test and maintenance

event. Other contributing events include loss of DC power, failure of the turbine-driven HPCI

pump to start or continue to run, failure of HPCI hydraulic valve HO10, and failure to bypass the

HPCI high temperature trip. The NRC staff considers the assumptions, as clarified, to be

reasonable and acceptable for purposes of the SAMA evaluation.

The NRC staff questioned how the modeling assumption of eliminating failure of the

diesel-driven fire pump in the Level 1 PSA model for SAMA 69, "upgrade the seismic capacity of

the diesel fire pump fuel tank and water supply tank," addresses the intent of this SAMA, which

is to mitigate seismic risk (NRC, 2009). In response to the RAI, NPPD explained that while the

diesel fire pump may be needed to fight a fire following a seismic or fire event, its contribution to

preventing core damage is from its dual function of providing an alternate source of water for

core cooling. NPPD further argued that the estimated risk reduction benefit for this SAMA is

conservative since the analysis credited the benefit from internal events risk reduction, in

addition to the benefit from external events risk reduction, through use of the external events

multiplier (NPPD, 2009a). The NRC staff agrees that the resulting benefit estimate is

conservative since there would be no reduction in internal events risk from implementation of

the SAMA.

The NRC staff requested clarification on how SAMA 70, "install a curb to prevent debris from

spreading across the floor and contacting the shell," reduces CDF as indicated in the ER

(NRC, 2009). In response to the RAI, NPPD explained that SAMA 70 does not impact Level 1

CDF and that the CDF reduction value reported in the ER for this SAMA is actually based on the

release frequency reduction for this SAMA (NPPD, 2009a). In a followup response to the NRC

staff RAI, NPPD further clarified that the analysis of this SAMA resulted in about a 12 percent

reduction in the frequency for the large early release category, and that this was treated as a

12 percent reduction in CDF in assessing the benefits for this SAMA (NPPD, 2009b). NPPD

indicated that a more accurate assessment of SAMA 70 would require modifying the CET and

that the approach taken results in a conservative estimate of the benefits for this SAMA.

Although this approach is not consistent with regulatory analysis methodology, the NRC staff

agrees that the resulting benefit estimate would be conservative since a reduction in CDF would

result in averted onsite costs that would not be included otherwise for the SAMA. NPPD also

NUREG-1437, Supplement 41 F-18 July 2010
Appendix F

noted that this analysis methodology was unique to SAMA 70 and does not impact the

evaluation of other SAMAs.

For SAMA 75, "Generation Risk Assessment (GRA) implementation into plant activities," the

NRC staff asked for additional clarification of the SAMA and justification for the assumed factor

of two reduction in the initiating event frequencies impacted by this SAMA (NRC, 2009). In

response to the RAI, NPPD explained that GRA is a new program to identify plant components

most likely to result in a plant trip, insights from which are used to identify and reevaluate

maintenance and operational practices to reduce the likelihood of future plant trips. NPPD

further explained that the GRA program was only recently piloted by CNS for EPRI and that the

factor of 2 is based on recent plant operating history and opinion based on NPPD's experience

in the GRA process. The NRC staff considers the assumptions, as clarified, to be reasonable

and acceptable for purposes of the SAMA evaluation.

For two of the SAMAs that specifically address fire events (i.e., SAMA 63, "add automatic fire

suppression systems to the dominant fire zones," and SAMA 65, "update the alternate shutdown

system (ASDS) panel to include additional system controls for opposite division," the reduction

in fire CDF and population dose was not directly calculated (in Table F-5 these are noted as

"Not Estimated"). For these SAMAs, a bounding estimate of the impact was made by assuming

the SAMA would eliminate the contribution to fire CDF from fires in the dominant fire zones in

SAMA 63 and the control room in SAMA 65. The dominant fire zones in SAMA 63 are those

having a fire CDF greater than 1.0 x 10-6 per year. Based on information from the IPEEE, the

dominant fire zones are switchgear rooms 1 F and 1 G, the main control room, and the SW pump

room. Based on logic in Section E.2.3 of the ER, only switchgear rooms 1F and 1 G would

benefit from the addition of automatic fire suppression systems. The benefit or averted cost risk

from eliminating the risk in these fire zones is then calculated by multiplying the ratio of the fire

zone CDF to the internal events CDF by the total present dollar-value equivalent associated

with completely eliminating severe accidents from internal events at CNS. These SAMAs were

assumed to have no additional benefits in internal events.

The NRC staff has reviewed NPPD's bases for calculating the risk reduction for the various

plant improvements and concludes that the rationale and assumptions for estimating risk

reduction are reasonable and generally conservative (i.e., the estimated risk reduction is higher

than what would actually be realized). Accordingly, the NRC staff based its estimates of averted

risk for the various SAMAs on NPPD's risk reduction estimates.

F.5. Cost Impacts of Candidate Plant Improvements

NPP[D estimated the costs of implementing the 80 candidate SAMAs through the application of

engineering judgment and use of other licensees' estimates for similar improvements. The cost

estimates conservatively did not include the cost of replacement power during extended

outages required to implement the modifications, nor did they include maintenance and

surveillance costs of the installed equipment (NPPD, 2008), (NPPD, 2009a). The cost estimates

provided in the ER did not account for inflation, which is considered another conservatism.

The NRC staff reviewed the bases for the applicant's cost estimates (presented in Section E.2

of Attachment E to the ER). For certain improvements, the NRC staff also compared the cost

estimates to estimates developed elsewhere for similar improvements, including estimates

developed as part of other licensees' analyses of SAMAs for operating reactors and advanced

light-water reactors. The NRC staff noted that several of the cost estimates provided by the

applicant were drawn from previous SAMA analyses for a dual-unit site. For those cost

July 2010 F-1 9 NUREG-1437, Supplement 41
Appendix F

estimates that were taken from a dual-unit SAMA analysis, NPPD reduced the estimated costs

by one-half. In response to an RAI requesting a more detailed description of the changes

associated with SAMAs 20, 44, 45, 63, 70, 72, 73, 76, 77, and 80, NPPD provided additional

information detailing the analysis and plant modifications included in the cost estimate of each

improvement (NPPD, 2009a). The staff reviewed the costs and found them to be reasonable,

and generally consistent with estimates provided in support of other plants' analyses.

The NRC staff requested additional clarification on the estimated cost of $1,200,000 for

implementation of SAMA 41, "provide ability to align diesel power to more air compressors,"

which is high for what is described as a procedural modification (NRC, 2009). In response to the

RAI, NPPD further described this modification as involving electrical, mechanical, and structural

hardware modifications, in addition to the procedural changes (NPPD, 2009a). Based on this

additional information, the NRC staff considers this estimated cost to be reasonable and

acceptable for purposes of the SAMA evaluation.

The NRC staff concludes that the cost estimates provided by NPPD are sufficient and

appropriate for use in the SAMA evaluation.

NUREG-1437, Supplement 41 F-20 July 2010
Appendix F

Table F-5. Severe Accident Mitigation Alternatives Cost/Benefit Screening Analysis for Cooper Nuclear Station(a)

% Risk Reduction Total Benefit ($)

SAMA Modeling Assumptions Population Baseline Baseline Cost ($)

CDF Dose (internal + With External) Uncertainty

Increase Availability of DC Power Increase time available to recover 3 3 32K 97K

offsite power (before HPCI and RCIC

are lost) to 24 hours during SBO

scenarios

1 - Provide additional DC battery capacity 500K

2 - Replace lead-acid batteries with fuel cells 1.0M

13 - Portable generator for DC power to supply 200K

the battery chargers

21 - Modify plant procedures to allow use of a Included in

portable power supply for battery chargers SAMA

13(b)

Improve DC Battery Charging Reliability Eliminate all common cause failures <1 0 2.3K 7.0K

due to loss of DC battery chargers

3 - Add battery charger to existing DC system 90K

15 - Proceduralize battery charger high-voltage 50K

shutdown circuit inhibitor

Improve DC Power Availability and Reliability

4 - Provide DC bus cross-ties for the 250V Eliminate failure of the 250V DC buses 0 0 0 0 300K

buses

19 - Modify plant procedures to use existing Eliminate failure of the operator to use <1 0 2.0K 6.0K 25K

125V DC bus cross-ties the 125V DC bus cross-tie

Improve Availability of the 120V Vital AC Bus

5 - Provide additional DC power to the Eliminate failure of providing DC power -0 0 470 1.4K >100K

120/240V vital AC system to the no break power panel (NBPP)

6 - Add an automatic feature to transfer the Eliminate failure to transfer the RPS 0 0 0 0 500K

120V vital AC bus from normal to standby panels to their alternate power source power I I IIII_ I

July 2010 F-21 NUREG-1437, Supplement 41
Appendix F

Increase Availability of Onsite AC Power Eliminate failure of the EDGs 13 14 140K 430K

7 - Provide an additional diesel generator 20M

10 - Install a gas turbine generator 2.0M

Increase Reliability of EDGs

11 - Add a new backup source for diesel Eliminate failure of providing SW 5 3 45K 130K 2.OM

cooling cooling to the EDGs

16 - Provide a portable EDG fuel oil transfer Eliminate failure of the EDG fuel oil <1 <1 6.2K 19K 1OOK

pump transfer pumps

Improve Availability of AC Power Eliminate failure of the 4.16-kV buses 3 5 35K 110K

8 - Improve 4.16-kV bus cross-tie ability 660K

17 - Provide alternate feeds to essential loads 220K

directly from an alternate emergency bus

Reduce Probability of Loss of Offsite Power Eliminate the weather-centered loss of 4 4 43K 130K

During Severe Weather offsite power initiating event

9 - Install an additional, buried offsite power 2.5M

source

12 - Bury offsite power lines 1.1B

Reduce Plant-Centered Loss of Offsite Power Eliminate the plant-centered loss of -0 0 610 1.8K

offsite power initiating event

18 - Protect transformers from failure 780K

Improve Reliability of the Direct Torus Vent Eliminate failure to power the hard pipe 4 13 77K 230K

Valves torus vent valves

20 - Provide redundant power to direct torus 710K

hard pipe vent valves

NUREG-1437, Supplement 41 F-22 July 2010
Appendix F

Increase Availability of High Pressure Injection Eliminate the CDF contribution from 32 22 300K 910K

unavailability of the HPCI system

14 - Portable generator for DC power to 710K

supply the individual panels (using

available skid-mounted portable AC

generator)

22 - Install an independent active or passive 1.0M

high pressure injection system

23 - Provide an additional high pressure 1.0M

injection pump with independent diesel

Extend RCIC Operation Eliminate failures due to the RCIC 4 <1 29K 86K

backpressure trip

24 - Raise HPCI/RCIC backpressure trip set >200K

points

25 - Revise procedure to allow bypass of 25K

RCIC turbine exhaust pressure trip

Improve Reliability of the Automatic Eliminate failure of the ADS 0 0 0 0

Depressurization System (ADS) accumulators

26 - Modify ADS components by adding larger >100K

accumulators

Improve Reliability of the SRVs Eliminate failure to open the SRVs 19 <1 140K 410K

when required by reactor pressure

vessel overpressure conditions

27 - Add signals to open SRVs automatically in 1.5M

a main steam isolation valve (MSIV) closure

transient

Increase Availability of Low Pressure Injection Eliminate failure of the low pressure 55 63 600K 1.8M

injection system

28 - Add a diverse low pressure injection 8.8M

system

Emergency Core Cooling System (ECCS) Low Eliminate failure of the low pressure 24 6 190K 570K

Pressure Interlock interlock circuitry

29 - Install a bypass switch to allow operators 1.0M

to bypass the low reactor pressure interlock

circuitry

July 2010 F-23 NUREG-1437, Supplement 41
Appendix F

Improve Reliability of HPCI and RCIC Eliminate failure of the HPCI and RCIC 6 0 42K 130K

turbine driven pumps

67 - Upgrade the HPCI and RCIC control 430K

systems

Improve Reliability/Redundancy of Steam Eliminate failure of the steam tunnel 3 1 27K 80K

Tunnel Heating, Ventilation, and Air HVAC condenser and eliminate the

Conditioning (HVAC) group 1 isolation (closure of the

MSIVs) initiating event

76 - Improve steam tunnel HVAC >100K

reliability/redundancy

Improve Reliability of ECCS Equipment Eliminate failure of the auto-start 1 0 9.3K 28K

features for the ECCS equipment

77 - Improve reliability of auto-start features for >100K

the ECCS equipment

Improve Reliability of Alternate Injection

78 - Improve training on providing alternate Reduce failure of operator actions to 5 4 53K 160K 25K

injection via FPS provide alternate injection via the fire

water system by a factor of 2

32 - Include the RHRSW and fire water Eliminate the CDF contribution due to -0 0 360 1.1K 50K

cross-tie valves in the maintenance program the SW cross-tie valves that are not

contained in the maintenance program

33 - Create ability for emergency Eliminate the CDF contribution due to 38 46 430K 1.3M 25K

connection of existing or new water loss of feedwater and condensate

sources to feedwater and condensate systems as alternate injection paths

systems

Increase Availability of the RHR Heat Eliminate failure of SW to provide 21 16 200K 600K

Exchangers cooling to the RHR heat exchangers

30 - Revise procedures to allow manual 25K

alignment of the fire water system to RHR

heat exchangers

Improve Reliability of the Emergency SW Eliminate all common cause failures <1 0 3.2K 9.5K

System due to loss of SW system pumps 5.9M

31 - Add an additional SW pump

I

NUREG-1437, Supplement 41 F-24 July 2010
Appendix F

Increase Availability of the TEC Heat Eliminate failure of the SW to provide 15 20 180K 530K

Exchangers cooling to the TEC heat exchangers

68 - Proceduralize the ability to 50K

cross-connect the circulating water pumps

and the SW going to the TEC heat

exchangers

Improve Reliability of the Main Feedwater Eliminate failure of feedwater -0 0 90 270

System turbine-driven pumps

34 - Add a motor-driven feedwater pump 1.7M

Increase Availability of the Condensate Storage Eliminate the CDF contribution from 2 2 21K 63K

Tank (CST) operator failure to prevent CST

inventory drain-down to the hotwell

72 - Provide a means of automatically 230K

preventing drain-down of CST to hotwell during

an SBO

Increase Availability of Room Cooling Eliminate failure of room cooling to the 4 3 38K 120K

RHRSW booster pump rooms

35 - Provide a redundant train or means of 2.2M

ventilation

Increase Availability of the EDG System Eliminate failure of the EDG HVAC 3 3 33K 99K

36 -Add a diesel building high temperature 1.3M

alarm or redundant louver and thermostat

38 - Install diverse set of EDG HVAC fan 100K

actuation logic

39 - Install additional fan and louver pair for 6.OM

EDG HVAC

40 - Revise operator procedures to provide 25K

additional space cooling to the EDG room

via the use of portable equipment

Improve Diagnosis of a Loss of Switchgear Eliminate failure of room cooling to the 0 0 0 0

HVAC critical switchgear rooms

37 - Add a switchgear room high temperature 400K

alarm

July 2010 F-25 NUREG-1437, Supplement 41
Appendix F

Increase Reliability of Instrument Air Eliminate failure of the instrument air 17 14 170K 500K

compressors

41 - Provide ability to align diesel power to 1.2M

more air compressors(c)

42 - Replace service and instrument air 1.4M

compressors with more reliable compressors

which have self-contained air cooling by shaft

driven fans

45 - Provide an alternate means of 100K

supplying the instrument air header

Extend SRV Operation Time Eliminate failure of loss of nitrogen and 0 0 0 0

air to the SRVs

43 - Install nitrogen bottles as backup gas >100K

supply for SRVs

Improve Availability of SRVs and MSIVs Eliminate failure of nitrogen, air, and 17 21 190K 570K

accumulators for the SRVs and MSIVs

44 - Improve SRV and MSIV pneumatic 1.5M

components

Improve Reliability of the Decay Heat Removal Eliminate loss of torus cooling mode of 35 37 370K 1.1M

System - Torus Cooling RHR and RHRSW system events

46 - Install an independent method of 5.8M

suppression pool cooling

71 - Upgrade existing equipment to transfer 11M

water from the torus to the radwaste system

73 - Provide ability to maintain suppression 1.3M

pool temperature lower

Improve Reliability of the Decay Heat Removal Eliminate loss of drywell sprays mode 17 55 320K 960K

System - Drywell Spray of RHR and RHRSW system events

47 - Install a passive drywell spray system to 5.8M

provide a redundant drywell spray method

NUREG-1437, Supplement 41 F-26 July 2010
Appendix F

Improve Reliability of Fission Product Reduce accident progression source 0 25 89K 270K

Scrubbing terms by a factor of 2 (excluding noble

gases)

48 - Install a filtered containment vent 1.5M

49 - Enhance fire protection system and/or 2.5M

standby gas treatment system hardware and

procedures

Improve Reliability of Containment Venting Eliminate failure of the operator to -0 0 35K 110K

control the venting evolution

50 - Modify containment venting procedure to 250K

control containment venting within a narrow

band

Improve Reliability of Vacuum Breakers Eliminate failure of the vacuum 1 4 23K 69K

breakers

51 - Install improved vacuum breakers 500K

(redundant valves in each line)

Improve Reliability of Containment Eliminate failure of the hard pipe vent 7 22 130K 380K

Overpressure Relief

52 - Provide passive overpressure relief by 1.0M

changing the containment vent valves to "fail

open" and improving the strength of the rupture

disk

53 - Install an alternate path to the torus hard 5.7M

pipe vent via the wet well using a rupture disk

Improve Reliability of Debris Barriers Eliminate the CDF contribution due to 12 40 230K 680K

failure of the drywell barriers to prevent

debris from contacting the shell

70 - Install a curb to prevent debris from 840K

spreading across the floor-and contacting the

shell

July 2010 F-27 NUREG-1437, Supplement 41
Appendix F

Reduce Probability of an ISLOCA Eliminate all ISLOCA initiating events <1 1 8.6K 26K

54 - Increase frequency of valve leak testing 100K

56 - Revise emergency operating procedures 50K

(EOPs) to improve ISLOCA identification

57- Improve operator training on ISLOCA 110K

coping

Improve Reliability of MSIVs Eliminate failure of the MSIVs to close <1 0 2.7K 8.2K

or remain closed

55 - Improve MSIV design to decrease the 1.0M

likelihood of containment bypass scenarios

Improve Reliability of the Standby Liquid Eliminate the CDF contribution due to <1 2 12K 37K

Control (SLC) System failure to initiate SLC and failures due

to the boron concentration being too

low

58 - Increase boron concentration in the SLC >50K

system

Improve Availability of Boron Injection Eliminate failure of the SLC system 1 4 22K 67K

59- Add an independent boron injection >100K

system

60 - Provide ability to use the CRD for 150K

alternate boron injection

Improve SRV Reseat Reliability Eliminate failure of the SRVs to reseat 1 <1 11K 32K

61 - Increase reliability of SRV to reseat after 2.2M

SLC injection

Reduce Probability of Internal Flooding

62 - Improve internal flooding procedures Eliminate failure of the operator to 2 2 17K 52K 460K

implement flood mitigation measures

74 - Provide flow diversion to help mitigate the Eliminate failure to isolate the large <1 0 2.0K 6.1K >100K

fire water pipe break in the control building and medium fire water pipe breaks in

ground floor corridor the control building ground floor

corridor

NUREG-1437, Supplement 41 F-28 July 2010
Appendix F

Increase Reliability of the Fire Water System Eliminate failure of the diesel-driven 3 2 27K 82K

fire pump

64 - Proceduralize the use of a fire pumper 50K

truck to pressurize the fire water system

69 - Upgrade the seismic capacity of the diesel >100K

fire pump fuel tank and water supply tank

Improve Fire Suppression Capability Eliminate the fire CDF contribution Not Estimated 120K 350K

from critical switchgear rooms 1 F and

1G

63 - Add automatic fire suppression systems to 375K

the dominant fire zones

Reduce Risk from Fires that Require Control Eliminate the fire CDF contribution Not Estimated 110K 340K

Room Evacuation from the main control room

65 - Upgrade the ASDS panel to include 790K

additional system controls for Division 1

equipment

Reduce Probability of a Large Break LOCA Eliminate all large break LOCA 1 3 19K 58K

66 - Provide digital large break LOCA initiating events 100K

protection

Reduce Frequency of Plant Trips and Reduce. the probability of all initiating 39 35 390K 11.2M

Shutdowns events except pipe breaks, floods, and

loss of offsite power (LOOP) by a

factor of 2

75 - Include GRA (trip and shutdown 500K

modeling) in plant activities

Improve Availability of the RHRSW System Eliminate failure to use the RHRSW 11 10 110K 330K

system without a SWBP

79 - Modify procedures to allow use of the 25K

RHRSW system without a service water

booster pump (SWBP)

Improve Plant Identification of Reference Leg Eliminate failure of cognitive 1 0 5.3K 16K

Leakdowns recognition of a leakdown of the

reference legs

80 - Install additional instrumentation to assist >100K

in identifying a reference leg leakdown

July 2010 F-29 NUREG-1437, Supplement 41
Appendix F

(a) SAMAs in bold are potentially cost-beneficial.

(b) In response to an NRC staff RAI, NPPD clarified that SAMA 21 was originally included as a unique SAMA because it was believed that a suitable, existing

portable power supply was available to supply the battery chargers (NPPD, 2009a). However, after further investigation, it was determined that the available

skid-mounted portable power supply is not sufficient to supply the battery chargers and that a portable power supply would need to be purchased (which is the

same as SAMA 13).

(c) SAMA title changed in response to NRC staff RAI 6e (NPPD, 2009a).

NUREG-1437, Supplement 41 F-30 July 2010
Appendix F

F.6. Cost-Benefit Comparison

NPPD's cost-benefit analysis and the NRC staff s review are described in the following sections.

F.6.1. Nebraska Public Power District's Evaluation

The methodology used by NPPD was based primarily on the NRC's guidance for performing

cost-benefit analysis (i.e., NUREG/BR-0184, "Regulatory Analysis Technical Evaluation

Handbook") (NRC, 1997a). The guidance involves determining the net value for each SAMA

according to the following formula:

Net Value = (APE + AOC + AOE + AOSC) - COE where,

APE = present value of averted public exposure ($)

AOC = present value of averted offsite property damage costs ($)

AOE = present value of averted occupational exposure costs ($)

AOSC = present value of averted onsite costs ($)

COE = cost of enhancement ($)

If the net value of a SAMA is negative, the cost of implementing the SAMA is larger than the

benefit associated with the SAMA and it is not considered cost-beneficial. NPPD's derivation of

each of the associated costs is summarized below.

NUREG/BR-0058 has recently been revised to reflect the agency's policy on discount rates.

Revision 4 of NUREG/BR-0058 states that two sets of estimates should be developed, one at

3 percent and one at 7 percent (NRC, 2004). NPPD provided a base set of results using the

7 percent discount rate and a sensitivity study using the 3 percent discount rate (NPPD, 2008).

Averted Public Exposure (APE) Costs

The APE costs were calculated using the following formula:

APE = Annual reduction in public exposure (A person-rem per year)

x monetary equivalent'of unit dose ($2,000 per person-rem)

x present value conversion factor (10.76 based on a 20-year period with a

7-percent discount rate)

As stated in NUREG/BR-0184 (NRC, 1997a), the monetary value of the public health risk after

discounting does not represent the expected reduction in public health risk due to a single

accident. Rather, it is the present value of a stream of potential losses extending over the

remaining lifetime (in this case, the renewal period) of the facility. Thus, it reflects the expected

annual loss due to a single accident, the possibility that such an accident could occur at any

time over the renewal period, and the effect of discounting these potential future losses to

present value. NPPD calculated an APE of approximately $46,000 for the 20-year license

renewal period (NPPD, 2008).

July 2010 F-31 NUREG-1437, Supplement 41
Appendix F

Averted Offsite Property Damage Costs (AOC)

The AOCs were calculated using the following formula:

AOC = Annual CDF reduction

x offsite economic costs associated with a severe accident (on a

per-event basis)

x present value conversion factor

This term represents the sum of the frequency-weighted offsite economic costs for each release

category, as obtained for the Level 3 risk analysis. For the purposes of initial screening, which

assumes elimination of all severe accidents caused by internal events, NPPD calculated an

annual offsite economic cost of about $7,000 based on the Level 3 risk analysis. This results in

a discounted value of approximately $75,000 for the 20-year license renewal period

(NPPD, 2008).

Averted Occupational Exposure (AOE) Costs

The AOE costs were calculated using the following formula:

AOE = Annual CDF reduction

x occupational exposure per core damage event

x monetary equivalent of unit dose

x present value conversion factor

NPPD derived the values for averted occupational exposure from information provided in

Section 5.7.3 of the regulatory analysis handbook (NRC, 1997a). Best estimate values provided

for immediate occupational dose (3,300 person-rem) and long-term occupational dose

(20,000 person-rem over a 10-year cleanup period) were used. The present value of these

doses was calculated using the equations provided in the handbook in conjunction with a

monetary equivalent of unit dose of $2,000 per person-rem, a real discount rate of 7 percent,

and a time period of 20 years to represent the license renewal period. For the purposes of initial

screening, which assumes elimination of all severe accidents caused by internal events, NPPD

calculated an AOE of approximately $4,400 for the 20-year license renewal period

(NPPD, 2008).

Averted Onsite Costs

Averted onsite costs (AOSC) include averted cleanup and decontamination costs and averted

power replacement costs. Repair and refurbishment costs are not for severe accidents. NPPD

derived the values for AOSC based on information provided in Section 5.7.6 of

NUREG/BR-0184, the regulatory analysis handbook (NRC, 1997a).

NPPD divided this cost element into two parts - the onsite cleanup and decontamination cost,

also commonly referred to as averted cleanup and decontamination costs (ACC), and the

replacement power cost.

NUREG-1437, Supplement 41 F-32 July 2010
Appendix F

ACC were calculated using the following formula:

ACC = Annual CDF reduction

x present value of cleanup costs per core damage event

x present value conversion factor

The total cost of cleanup and decontamination subsequent to a severe accident is estimated in

NUREG/BR-0184 to be $1.5 x 109 (undiscounted). This value was converted to present costs

over a 10-year cleanup period and integrated over the term of the proposed license extension.

For the purposes of initial screening, which assumes elimination of all severe accidents caused

by internal events, NPPD calculated an ACC of approximately $134,000 for the 20-year license

renewal period.

Long-term replacement power costs (RPC) were calculated using the following formula:

RPC = Annual CDF reduction

x present value of replacement power for a single event

x factor to account for remaining service years for which replacement

power is required

x reactor power scaling factor

NPPD based its calculations on the 910 megawatt-electric (MWe) reference plant in

NUREG/BR-0184 (NRC, 1997b), and did not scale down to the 830 MWe rating for CNS.

Therefore, NPPD did not apply a power scaling factor to determine the replacement power

costs, which are conservative. For the purposes of initial screening, which assumes elimination

of all severe accidents caused by internal events, NPPD calculated an RPC of approximately

$91,000 and an AOSC of approximately $225,000 for the 20-year license renewal period

(NPPD, 2008).

Using the above equations, NPPD estimated the total present dollar-value equivalent

associated with completely eliminating severe accidents from internal events at CNS to be

about $351,000. Use of a multiplier of 3 to account for external events increases the value to

$1.05M and represents the dollar-value associated with completely eliminating all internal and

external event severe accident risk at CNS.

NPPD's Results

If the implementation costs for a candidate SAMA exceeded the calculated benefit, the SAMA

was considered not to be cost-beneficial. In the baseline analysis contained in the ER (using a

7 percent discount rate) NPPD identified eight potentially cost-beneficial SAMAs. The potentially

cost-beneficial SAMAs are:

SAMA 25 - Develop procedures to allow bypass of the RCIC turbine exhaust

pressure trip, extending the time available for RCIC operation.

SAMA 30 - Revise procedures to allow manual alignment of the fire water

system to the RHR heat exchangers, providing improved ability to cool the RHR

heat exchangers in a loss of SW.

July 2010 F-33 NUREG-1437, Supplement 41
Appendix F

0 SAMA 33 - Provide for the ability to establish an emergency connection of

existing or new water sources to feedwater and condensate systems, increasing

availability of feedwater.

0 SAMA 40 - Revise procedures to provide additional space cooling to the EDG

room via the use of portable equipment, increasing availability of the EDG.

0 SAMA 45 - Provide an alternate means of supplying the instrument air header,

increasing availability of instrument air.

* SAMA 68 - Revise procedures to allow the ability to cross-connect the

circulating water pumps and the SW going to the TEC heat exchangers,

allowing continued use of the power conversion system after SW is lost.

0 SAMA 78 - Improve training on alternate injection via the fire water system,

increasing the availability of alternate injection.

0 SAMA 79 - Revise procedures to allow use of the RHRSW system without a

SW booster pump, increasing availability of the RHRSW system.

NPPD performed additional analyses to evaluate the impact of an alternative discount rate

(3 percent) and remaining plant life (26 years instead of 20 years) on the results of the SAMA

assessment. No additional SAMA candidates were determined to be potentially cost-beneficial

(NPPD, 2008).

If the benefits are increased by an additional factor of 3 to account for uncertainties, three

additional SAMA candidates were determined to be potentially cost-beneficial:

SAMA 14- Provide a portable generator to supply DC power to individual

panels during an SBO, increasing the time available for AC power recovery.

0 SAMA 64 - Revise procedures to allow use of a fire pumper truck to pressurize

the fire water system, increasing availability of the fire water system.

0 SAMA 75 - Implement GRA (trip and shutdown risk modeling) into plant

activities, decreasing the probability of trips/shutdown.

The potentially cost-beneficial SAMAs, and NPPD's plans for further evaluation of these SAMAs

are discussed in more detail in Section F.6.2.

F.6.2. Review of Nebraska Public Power District's Cost-Benefit Evaluation

The cost-benefit analysis performed by NPPD was based primarily on NUREG/BR-0184

(NRC, 1997a) and discount rate guidelines in NUREG/BR-0058 (NRC, 2004) and was executed

consistent with this guidance.

SAMAs identified primarily on the basis of the internal events analysis could provide benefits in

certain external events, in addition to internal events. To account for the additional benefits in

external events, NPPD multiplied the internal event benefits by a factor of 3 for each SAMA,

except for two SAMAs that specifically address fire risk (SAMAs 63 and 65). Doubling the

NUREG-1437, Supplement 41 F-34 July 2010
Appendix F

internal event estimate for SAMAs 63 and 65 would not be appropriate because these SAMAs

are specific to fire risks and would not have a corresponding benefit on the risk from internal

events. The NRC staff notes that the CNS external events CDF is approximately 200 percent of

the internal events CDF from the CNS 2007TM PSA model (based on the fire CDF of 1.9 x 10. 5

per year, a seismic CDF of 6 x 106 per year as estimated by the NRC staff, a negligible HFO

contribution, and an internal events CDF of 1.2 x 105 per year). Accordingly, the total CDF from

internal and external events would be approximately 2.1 times the internal events CDF from the

CNS 2007 TM PSA model. Because the CDF from internal fires and other external events, as

reported by NPPD, is about twice the CDF for internal events, the NRC staff agrees that the

factor of 3 multiplier for external events is reasonable.

NPPD provided the results of additional sensitivity analyses in the ER, including use of a

3 percent discount rate and use of a longer plant life. These analyses did not identify any

additional potentially cost-beneficial SAMAs.

NPPD considered the impact that possible increases in benefits from analysis uncertainties

would have on the results of the SAMA assessment. In the ER, NPPD states that an uncertainty

analysis of the internal events CDF resulted in a 95th percentile value that is a factor of

1.86 times the mean CDF. The ER further states that an uncertainty factor of 3 was

conservatively selected for the uncertainty analysis. The NRC staff asked NPPD to provide the

results of the internal events CDF uncertainty analysis and to provide further justification for the

use of a factor of 3 for the SAMA uncertainty analysis. In response to the RAI, NPPD provided

the results of the internal events CDF, which indicates that the 95th percentile is a factor of

1.86 x the mean CDF as described in the ER. NPPD further clarified that the uncertainty factor

of 3 was developed from an earlier version of the uncertainty analysis and that the SAMA

analysis was not subsequently updated to avoid rework (NPPD, 2009a). Since the Phase I

SAMAs were not screened based on quantitative criteria, a reexamination of the Phase I

SAMAs based on the upper bound benefits was not necessary. NPPD considered the impact on

the Phase II screening if the estimated benefits were increased by a factor of 3 (in addition to

the multiplier of 3 for external events). Three additional SAMAs became cost-beneficial in

NPPD's analysis (SAMAs 14, 64, and 75 as described above).

The NRC staff noted that SAMA 14, "portable generator for DC power to supply the individual

panels," and SAMA 13, "portable generator for DC power to supply the battery chargers," both

involve use of a portable generator and requested that NPPD reassess whether or not SAMA 13

would be cost-beneficial if it were to use the same portable generator as for SAMA 14, which

was determined to be cost-beneficial (NRC, 2009). In response, NPPD stated that since the

SAMA submittal, SAMA 13 has been implemented at CNS (NPPD, 2009a). NPPD also stated

that the available skid mounted portable power supply considered in the cost estimate for SAMA

14 was not sufficient to supply the battery chargers as proposed in SAMA 13. No draft

supplemental environmental impact statement (DSEIS) change is needed.

The NRC staff also noted that all of the SAMAs considered for basic event

PCI-CNT-FF-PREEX, "pre-existing containment failure," involve major hardware modifications.

The NRC staff asked NPPD to provide an assessment of lower cost alternatives, such as

periodic monitoring of containment integrity during normal operation or procedures to isolate the

containment following an event (NRC, 2009). In response to the RAI, NPPD stated that these

two specific alternatives have already been implemented at CNS (NPPD, 2009a). NPPD further

clarified that basic event PCI-CNT-FF-PREEX represents a preexisting containment failure

leading to loss of net positive suction head (NPSH) to the ECCS pumps and that since the CNS

July 2010 F-35 NUREG-1437, Supplement 41
Appendix F

containment is inerted during normal operation, a leak large enough to lead to loss of NPSH

would require significant nitrogen makeup and would be noticed by the operators.

The NRC staff noted that for certain SAMAs considered in the ER, there may be alternatives

that could achieve much of the risk reduction at a lower cost. The NRC staff asked the applicant

to evaluate several additional lower cost alternatives to the SAMAs considered in the ER,

including SAMAs that had been found to be potentially cost-beneficial at other BWR plants.

These alternatives were: (1) providing additional space cooling to the RHRSW booster pump

rooms, CS pump rooms, RHR pump rooms, SW pump rooms, and HPCI pump room via the use

of portable equipment; (2) improving alternate shutdown training and equipment; (3) enhancing

DC power availability by providing cables from diesel generators or another source to directly

power battery chargers; (4) developing guidance/procedures for local, manual control of reactor

core isolation cooling following loss of DC power; and (5) manually venting containment using

either a local hand wheel or gas bottle supplies (NRC, 2009). NPPD provided a further

evaluation of these alternatives and concluded that each had already been implemented at CNS

(NPPD, 2009a).

In the ER and in response to an NRC staff RAI, NPPD indicated that detailed engineering

project cost-benefit analyses have been initiated for the 11 potentially cost-beneficial SAMAs

(NPPD, 2008), (NPPD, 2009a).

In light of the many potentially cost-beneficial SAMAs identified in the ER, the NRC staff asked

NPPD to identify those SAMAs having higher priority for being considered for implementation

based on risk reduction potential and implementation cost, and which SAMAs would no longer

be cost-beneficial if these higher priority SAMAs were implemented (NRC, 2009). In response to

the RAI (NPPD, 2009a), NPPD performed a qualitative assessment to prioritize the

cost-beneficial SAMAs. NPPD determined that SAMAs 30, 33, 68, and 79 would have the

highest priority based on their potential for significant reduction in risk and relatively low

implementation cost. NPPD further identified SAMAs 14, 45, 75, and 78 as a second priority

based on their potential for risk reduction and mitigation of plant risk contributors not addressed

by SAMAs 30, 33, 68, and 79. The impact of the remaining potentially cost-beneficial SAMAs is

expected to be reduced significantly if the higher priority SAMAs are implemented. The NRC

considers this approach for prioritizing SAMAs to be reasonable.

The NRC staff concludes that, with the exception of the potentially cost-beneficial SAMAs

discussed above, the costs of the other SAMAs evaluated would be higher than the associated

benefits.

F.7. Conclusions

NPPD compiled a list of 244 SAMAs based on a review of the most significant basic events from

the plant-specific PSA, insights from the plant-specific IPE and IPEEE, Phase II SAMAs from

license renewal applications for other plants, and review of other NRC and industry

documentation. A qualitative screening removed SAMA candidates that: (1) modified features

not applicable to CNS, (2) had already been implemented at CNS, or (3) were similar and could

be combined with another SAMA. Based on this screening, 164 SAMAs were eliminated leaving 80 candidate SAMAs for evaluation.

For the remaining SAMA candidates, a more detailed design and cost estimate were developed

as shown in Table F-5. The cost-benefit analyses showed that eight of the SAMA candidates

were potentially cost-beneficial in the baseline analysis (Phase II SAMAs 25, 30, 33, 40, 45, 68,

NUREG-1437, Supplement 41 F-36 July 2010
Appendix F

78, and 79). NPPD performed additional analyses to evaluate the impact of parameter choices

and uncertainties on the results of the SAMA assessment. Three additional SAMAs were

identified as potentially cost-beneficial in the ER (Phase II SAMAs 14, 64, and 75). NPPD has

indicated that detailed engineering project cost-benefit analyses have been initiated for the

11 potentially cost-beneficial SAMAs.

The NRC staff reviewed the NPPD analysis and concludes that the methods used and the

implementation of those methods were sound. The treatment of SAMA benefits and costs

support the general conclusion that the SAMA evaluations performed by NPPD are reasonable

and sufficient for the license renewal submittal. Although the treatment of SAMAs for external

events was somewhat limited, the likelihood of there being cost-beneficial enhancements in this

area was minimized by improvements that have been realized as a result of the IPEEE process,

and inclusion of a multiplier to account for external events.

The NRC staff concurs with NPPD's identification of areas in which risk can be further reduced

in a cost-beneficial manner through the implementation of the identified, potentially

cost-beneficial SAMAs. Given the potential for cost-beneficial risk reduction, the NRC staff

agrees that further evaluation of these SAMAs by NPPD is warranted. However, these SAMAs

do not relate to adequately managing the effects of aging during the period of extended

operation. Therefore, they need not be implemented as part of license renewal pursuant to Title

10 of the Code of Federal Regulations, Part 54.

F.8. References

American Association of Mechanical Engineers (ASME). 2007. "Standard for Probabilistic Risk

Assessment for Nuclear Power Plant Applications," RA-Sc-2007, August 2007.

Eklund, D.L. et al. (Eklund et al.) 1999. "Using Water Demand to Determine Population

Estimates and Projections for Kansas," June 8, 1999.

Electric Power Research Institute (EPRI). 1991. "A Methodology for Assessment of Nuclear

Power Plant Seismic Margin," EPRI NP-6041-SL, Revision 1, Palo Alto, CA, August 1991.

Electric Power Research Institute (EPRI). 1993. "Fire-Induced Vulnerability Evaluation (FIVE),"

EPRI TR-100370, Revision 1, Palo Alto, CA, September 1993.

Electric Power Research Institute (EPRI). 1994. "EPRI Fire PRA Implementation Guide,"

prepared by Science Applications International Corporation for EPRI, Palo Alto, CA, January

1994.

Global Insight. 2006. "How Important is Tourism in Kansas? The Tourism Satellite Account

Perspective," Kansas Tourism in 2004, prepared by Global Insight, October 3, 2006.

Iowa Department of Economic Development (IDED). 2006. "Iowa Tourism Results as of October

1, 2006," Iowa Department of Economic Development Tourism Office.

Kaylen, M. 2006. "Economic Impact of Missouri's Tourism and Travel Industry: July 2004-June

2005 (FY05)," Executive Summary, MU-Tourism Economics Research Initiative, Columbia,

Missouri, May 2006.

Kennedy, R.P. 1999. "Overview of Methods for Seismic PRA and Margin Analysis Including

Recent Innovations," Proceedings of the OECD-NEA Workshop of Seismic Risk, Tokyo, Japan,

August 10-12 1999.

July 2010 F-37 NUREG-1437, Supplement 41
Appendix F

Missouri Census Data Center (Missouri). 2007. "Population Projections for Missouri and the

U.S." Available URL: http://mcdc2.missouri.edu/trends/proiections/shtml (accessed June 12,

2007).

I Nebraska Department of Economic Development (NDED). 2006. "2006 Fiscal Year Annual

Report, July 1, 2005-June 30, 2006," Lincoln, Nebraska.

Nebraska Public Power District (NPPD). 1993. Generic Letter 88-20, "Individual Plant

Examination for Severe Accident Vulnerabilities - 10 CFR 50.54(f), IPE Report Submittal,

Cooper Nuclear Station, Docket No. 50-298, DPR-46," March 1993, Agencywide Documents

Access and Management System (ADAMS) Accession Nos. ML073600192 (Volume 1) and

ML073600193 (Volume 2).

Nebraska Public Power District (NPPD). 1996. "Individual Plant Examination for External Events

Report - 10 CFR 50.54(f), Cooper Nuclear Station, NRC Docket No. 50-298, License No.

DPR-46," October 1996, ADAMS Accession No. ML073580487.

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

Station, Appendix E - Applicant's Environmental Report, Operating License Renewal Stage,"

Columbus, Nebraska. September 24, 2008, ADAMS Accession No ML083030246 (main report)

and ML083030252 (attachments).

Nebraska Public Power District (NPPD). 2009a. Letter from Stewart B. Minahan, Nebraska

Public Power District, to the U.S. Nuclear Regulatory Commission Document Control Desk,

Subject: "Response to Request for Additional Information for License Renewal Application -

Severe Accident Mitigation Alternatives, Cooper Nuclear Station, Docket No. 50-298, DPR-46,"

July 1, 2009, ADAMS Accession No. ML091880319.

Nebraska Public Power District (NPPD). 2009b. E-mail from David W. Bremer, Nebraska Public

Power District, to Bennett Brady, U.S. Nuclear Regulatory Commission, Subject: "NRC

Teleconference to discuss SAMA RAI Followup Questions and ER Questions," August 10,

2009.

Nebraska Public Power District (NPPD). 2009c. Letter from Nebraska Public Power District,

Subject: "SAMA Meteorological Anomaly Related to the Cooper Nuclear Station License

Renewal Application," December 7, 2009, ADAMS Accession No. 093490997.

Nuclear Energy Institute (NEI). 2007. "Process for Performing Follow-on PRA Peer Reviews

Using the ASME PRA Standard," NEI 05-04, Revision 1 (Draft G), November 2007.

Seismic Qualification Users Group (SQUG). 1992. "Generic Implementation Procedure (GIP) for

Seismic Verification of Nuclear Plant Equipment," Revision 2, Corrected, February 14, 1992.

University of Nebraska (UN). 2007. "Business in Nebraska Population Projection," University of

Nebraska Bureau of Business Research. Available URL: http://www.bbr.uni.edu/PopProiections/

(accessed June 20, 2007).

U.S. Department of Agriculture (USDA). 2002. "2002 Census of Agriculture," National

Agriculture Statistics Service. Available URL:

http://www.nass.usda.qov/Census of Aqriculture/index.asp (accessed June 2007).

U. S. Geological Survey (USGS). 2008. "2008 NSHM Gridded Data, Peak Ground

Acceleration." Available URL:

http :i/earthquake.usgs.gov/hazards/iroducts/conterminous/20O8/data/

U.S. Nuclear Regulatory Commission (NRC). 1988. Generic Letter 88-20, "Individual Plant

Examination for Severe Accident Vulnerabilities," November 23, 1988.

NUREG-1437, Supplement 41 F-38 July 2010
Appendix F

U.S. Nuclear Regulatory Commission (NRC). 1990. Severe Accident Risks: An Assessment for

Five U.S. Nuclear Power Plants, NUREG-1150, Washington, D.C., December 1990.

U.S. Nuclear Regulatory Commission (NRC). 1991. Generic Letter No. 88-20, Supplement 4,

Individual Plant Examination of External Events for Severe Accident Vulnerabilities,

NUREG-1407, Washington, D.C., June 28, 1991.

U.S. Nuclear Regulatory Commission (NRC). 1996. Letter from David L. Wigginton, U.S.

Nuclear Regulatory Commission, to Guy R. Horn, Nebraska Public Power District, Subject:

"Cooper Nuclear Station - Individual Plant Examination (IPE) for Internal Events (TAC No.

M74400)," Washington, D.C., February 14, 1996.

U.S. Nuclear Regulatory Commission (NRC). 1997a. "Regulatory Analysis Technical Evaluation

Handbook," NUREG/BR-0184, Washington, D.C., January 1997.

U.S. Nuclear Regulatory Commission (NRC). 1997b. Individual Plant Examination Program:

Perspectives on Reactor Safety and Plant Performance, NUREG-1560, Washington, D.C.,

December 1997.

U.S. Nuclear Regulatory Commission (NRC). 1998. "Code Manual for MACCS2: Volume 1,

User's Guide," NUREG/CR-6613, Washington, D.C., May 1998.

U.S. Nuclear Regulatory Commission (NRC). 1999. Letter from Lawrence Burkhart, U.S.

Nuclear Regulatory Commission, to G.R. Horn, Nebraska Public Power District, Subject:

"Plant-Specific Safety Evaluation Report for USI A-46 Program Implementation at Cooper

Nuclear Station (TAC No. M69439)," Washington, D.C., September 30, 1999.

U.S. Nuclear Regulatory Commission (NRC). 2001. "Cooper Nuclear Station - Review of

Individual Plant Examination of External Events (TAC No. 83611)," Washington, D.C., April 27,

2001.

U.S. Nuclear Regulatory Commission (NRC). 2004. "Regulatory Analysis Guidelines of the U.S.

Nuclear Regulatory Commission," NUREG/BR-0058, Revision 4, Washington, D.C., September

2004.

U.S. Nuclear Regulatory Commission (NRC). 2007. "An Approach for Determining the Technical

Adequacy of Probabilistic Risk Assessment Results for Risk-Informed Activities," Regulatory

Guide 1.200, Revision 1, Washington, D.C., January 2007.

U.S. Nuclear Regulatory Commission (NRC). 2009. Letter from Tam Tran, U.S. Nuclear

Regulatory Commission, to Stewart B. Minahan, Nebraska Public Power District, Subject:

"Request for Additional Information for the Review of the Cooper Nuclear Station License

Renewal Application (TAC Nos. MD9763 and MD9737)," Washington, D.C., June 8, 2009,

ADAMS Accession No. ML091530316.

Woods & Poole. 2006. "2006 State Profile: Iowa," Woods & Poole Economics, Inc.

July 2010 F-39 NUREG-1437, Supplement 41

NRC FORM 335 U.S. NUCLEAR REGULATORY COMMISSION 1. REPORT NUMBER

(9-2004) (Assigned by NRC, Add Vol., Supp., Rev.,

NRCMD 3.7 and Addendum Numbers, If any.)

BIBLIOGRAPHIC DATA SHEET

(See instructions on the reverse) NUREG-1437, Supplement 41

2. TITLE AND SUBTITLE 3. DATE REPORT PUBLISHED

Generic Environmental Impact Statement for License Renewal of Nuclear Plants (GElS) MONTH YEAR

Supplement 41

Regarding Cooper Nuclear Station July 2010

Final Report 4. FIN OR GRANT NUMBER

5. AUTHOR(S) 6. TYPE OF REPORT

See Chapter 10 of report Technical

7. PERIOD COVERED (Inclusive Dates)

8. PERFORMING ORGANIZATION - NAME AND ADDRESS (It NRC. provide Division. Office or Region. U.S Nuclear Regulatory Commission. and mailing address; if contractor,

provide name and mailing address.)

Division of License Renewal

Office of Nuclear Reactor Regulation

U.S. Nuclear Regulatory Commission

Washington, D.C. 20555-0001

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,

and mailing address.)

Same as 8 above

10. SUPPLEMENTARY NOTES

Docket Number 50-298

11. ABSTRACT (200 words or less)

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

Nebraska Public Power District (NPPD) to the Nuclear Regulatory Commission (NRC) to renew the Operating License for

Cooper Nuclear Station (CNS) for an additional 20 years under 10 CFR Part 54. The SEIS includes the NRC staffs

analysis that considers and weighs the environmental impacts of the proposed action, the environmental impacts of alternatives

to the proposed action, and mitigation measures available for reducing or avoiding adverse impacts. It also includes the staffs

recommendation regarding the proposed action.

The NRC staffs recommendation is that the Commission determine that the adverse environmental impacts of license renewal

for CNS 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 GELS; (2) the Environmental Report

submitted by NPPD; (3) consultation with Federal, State, and local agencies; (4) the staffs own independent review; and (5) the

staffs consideration of public comments.

12. KEY WORDSIDESCRIPTORS (List words orphrases that will assist researchers in locating the report.) 13. AVAILABILITY STATEMENT

Cooper Nuclear Station unlimited

NPPD 14. SECURITY CLASSIFICATION

Nebraska Public Power District (This Page)

Supplement to the Generic Environmental Impact Statement unclassified

FSEIS (This Report)

National Environmental Policy Act unclassified

NEPA

License Renewal 15. NUMBER OF PAGES

GElS

NUREG 1437, Supplement 41 16. PRICE

NRC FORM 335 (9.-2004) PRINTED ON RECYCLED PAPER
A

Federal Recycling Program

UNITED STATES

NUCLEAR REGULATORY COMMISSION

WASHINGTON, DC 20555-0001

OFFICIAL BUSINESS

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