Environmental Impact Statement 

for the Combined License (COL) for 

Calvert Cliffs Nuclear Power Plant 

Unit 3 

Draft Report for Comment 

U.S. Nuclear Regulatory Commission 

Office of New Reactors 

Washington, DC 20555-0001 

U.S. Army Corps of Engineers 

U.S. Army Engineer District, Baltimore 

Baltimore, MD 21203-1715 

NUREG-1936, Vol. 2
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Environmental Impact Statement 

for the Combined License (COL) for 

Calvert Cliffs Nuclear Power Plant 

Unit 3 

Draft Report for Comment 

Manuscript Completed: March 2010 

Date Published: April 2010 

Division of Site and Environmental Review 

Office of New Reactors 

U.S. Nuclear Regulatory Commission 

Washington, DC 20555-0001 

Regulatory Branch 

Operations Division 

U.S. Army Corps of Engineers 

U.S. Army Engineer District, Baltimore 

Baltimore, MD 21203-1715 

NUREG-1936, Vol. 2 
COMMENTS ON DRAFT REPORT 

Any party may submit comments on this report for consideration by the NRC staff. Comments 

may be accompanied by additional relevant information or supporting data. Please specify the 

report number NUREG-1936 in your comments and send them by the end of the 75-day 

comment period specified in the Federal Register notice announcing the availability of this draft. 

To submit comments: 

Chief, Rulemaking and Directives Branch 

Office of Administration 

Mail Stop: TWB-05-B01M 

U.S. Nuclear Regulatory Commission 

Washington, DC 20555-0001 

Fax: (301) 492-3446 

Electronic comments may be submitted to the NRC by e-mail at CalvertCliffsCOLAEIS@nrc.gov 

For any additional information or copies of this draft, contact: 

Ms. Laura Quinn Ms. Stacey Imboden 

Office of New Reactors Office of New Reactors 

Mail Stop: T-7D30 Mail Stop T-7E18 

U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission 

Washington, DC 20555-0001 Washington, DC 20555-0001 

Phone: 1-800-368-5642, extension 2220 Phone: 1-800-368-5642, extension 2462 

Email: Laura.Quinn@nrc.gov Email: Stacey.Imboden@nrc.gov

Paperwork Reduction Act Statement 

This NUREG references information collection requirements that are subject to the Paperwork 

Reduction Act of 1995 (44 U.S.C. 3501 et seq.). There were no new information collection 

requirements in this NUREG. The existing information collections in the NUREG were 

previously approved by the Office of Management and Budget, approval numbers 3150-0014; 

3150-0011; 3150-0021; 3150-0151; 3150-0008; 3150-0002; and 3150-0093. 

Public Protection Notification 

The NRC may not conduct or sponsor, and a person is not required to respond to, a request for 

information or an information collection requirement unless the requesting documents displays a 

currently valid OMB control number. 
April 2010 iii Draft NUREG-1936 

1 Abstract 

2 This environmental impact statement (EIS) has been prepared to satisfy the requirements of the 

3 National Environmental Policy Act of 1969, as amended (NEPA). The EIS has been prepared in 

4 response to an application submitted to the U.S. Nuclear Regulatory Commission (NRC) by 

5 UniStar Nuclear Development, LLC, on behalf of Calvert Cliffs 3 Nuclear Project, LLC, and 

6 UniStar Nuclear Operating Services, LLC, (collectively known as UniStar) for a combined 

7 construction permit and operating license (combined license or COL). UniStar also submitted a 

8 joint Federal/State Application for the Alteration of Any Floodplain, Waterway, Tidal or Nontidal 

9 Wetland in Maryland to the U.S. Army Corps of Engineers (USACE or Corps) and the Maryland 

10 Department of the Environment (MDE). The proposed actions related to the UniStar application 

11 are (1) NRC issuance of a COL for a new power reactor unit (Unit 3) at the Calvert Cliffs 

12 Nuclear Power Plant (CCNPP) in Calvert County, Maryland and (2) Corps permit action on a 

13 Department of the Army (DA) Individual Permit application to perform certain activities on the 

14 site. The Corps is participating with the NRC in preparing this EIS as a cooperating agency and 

15 participates collaboratively on the review team. 

16 This EIS includes the analysis by the NRC and Corps staff that considers and weighs the 

17 environmental impacts of constructing and operating a new nuclear unit at the Calvert Cliffs site 

18 and at alternative sites and mitigation measures available for reducing or avoiding adverse 

19 impacts. This EIS also addresses consultation for Federally listed species, cultural resources, 

20 and essential fish habitat (EFH). 

21 This EIS includes the evaluation of the proposed project’s impacts to waters of the United States 

22 pursuant to Section 404 of the Clean Water Act and Section 10 of the Rivers and Harbors Act of 

23 1899. The Corps will base its evaluation of the DA Individual Permit application on the 

24 requirements of Corps regulations, the Clean Water Act Section 404(b)(1) Guidelines, and the 

25 Corps public interest review (PIR) process. 

26 After considering the environmental aspects of the proposed NRC action, the NRC staff’s 

27 preliminary recommendation to the Commission is that the COL be issued as requested. This 

28 recommendation is based on (1) the application, including the Environmental Report (ER), 

29 submitted by UniStar and responses to requests for additional information (RAI); (2) 

30 consultation with Federal, State, Tribal, and local agencies; (3) the staff’s independent review; 

31 (4) the staff’s consideration of comments related to the environmental review that were received 

32 during the public scoping process; and (5) the assessments summarized in this EIS, including 

33 the potential mitigation measures identified in the ER and this EIS. The Corps permit decision 

34 will be made following issuance of the final EIS.

April 2010 v Draft NUREG-1936 

1 Contents 

2 Abstract.........................................................................................................................................iii

3 Executive Summary ..................................................................................................................xxix

4 Abbreviations/Acronyms ......................................................................................................... xxxiii

5 1.0 Introduction.......................................................................................................................1-1

6 1.1 Background ..............................................................................................................1-2

7 1.1.1 Applications and Review ..............................................................................1-2

8 1.1.1.1 NRC COL Application Review .......................................................1-3

9 1.1.1.2 Corps Permit Application Review...................................................1-4

10 1.1.2 Preconstruction Activities .............................................................................1-6

11 1.1.3 Cooperating Agencies ..................................................................................1-6

12 1.1.4 Concurrent NRC Reviews ............................................................................1-8

13 1.2 The Proposed Federal Actions.................................................................................1-8

14 1.3 The Purpose and Need for the Proposed Actions....................................................1-9

15 1.3.1 NRC’s Proposed Action................................................................................1-9

16 1.3.2 The Corps’ Permit Action..............................................................................1-9

17 1.4 Alternatives to the Proposed Actions .....................................................................1-10

18 1.5 Compliance and Consultations...............................................................................1-12

19 1.6 Report Contents .....................................................................................................1-12

20 1.7 References.............................................................................................................1-13

21 2.0 Affected Environment .......................................................................................................2-1

22 2.1 Site Location.............................................................................................................2-1

23 2.2 Land Use..................................................................................................................2-1

24 2.2.1 The Site and Vicinity.....................................................................................2-4

25 2.2.2 Transmission Line Corridors.........................................................................2-9

26 2.2.3 The Region.................................................................................................2-10

27 2.3 Water......................................................................................................................2-10

28 2.3.1 Hydrology ...................................................................................................2-10

29 2.3.1.1 Surface-Water Hydrology ............................................................2-10

30 2.3.1.2 Groundwater Hydrology...............................................................2-15

31 2.3.2 Water Use...................................................................................................2-17

32 2.3.2.1 Surface-Water Use ......................................................................2-18
Draft NUREG-1936 vi April 2010 

1 2.3.2.2 Groundwater Use.........................................................................2-18

2 2.3.3 Water Quality..............................................................................................2-19

3 2.3.3.1 Surface-Water Quality .................................................................2-19

4 2.3.3.2 Groundwater Quality....................................................................2-21

5 2.3.4 Water Monitoring ........................................................................................2-21

6 2.4 Ecology...................................................................................................................2-22

7 2.4.1 Terrestrial and Wetland Ecology ................................................................2-22

8 2.4.1.1 Terrestrial Resources – Site and Vicinity.....................................2-22

9 2.4.1.2 Terrestrial Resources – Transmission Lines................................2-28

10 2.4.1.3 Important Terrestrial Species and Habitats..................................2-28

11 2.4.1.4 Terrestrial Ecology Monitoring .....................................................2-44

12 2.4.2 Aquatic Ecology..........................................................................................2-44

13 2.4.2.1 Freshwater Habitats – Site and Vicinity .......................................2-45

14 2.4.2.2 Important Freshwater Species – Site and Vicnity ........................2-54

15 2.4.2.3 Non-Native and Nuisance Freshwater Species – Site and 

16 Vicinity .........................................................................................2-59

17 2.4.2.4 Estaurine Habitats – Site and Vicinity..........................................2-60

18 2.4.2.5 Important Estuarine Species – Site and Vicinity ..........................2-66

19 2.4.2.6 Non-Native and Nuisance Estuarine Species – Site and 

20 Vicinity .........................................................................................2-90

21 2.4.2.7 Aquatic Resources – Transmission Lines....................................2-91

22 2.4.2.8 Aquatic Monitoring .......................................................................2-92

23 2.5 Socioeconomics .....................................................................................................2-92

24 2.5.1 Demographics ............................................................................................2-94

25 2.5.1.1 Resident Population.....................................................................2-95

26 2.5.1.2 Transient Population....................................................................2-97

27 2.5.1.3 Agricultural, Seasonal and Migrant Labor....................................2-99

28 2.5.2 Community Characteristics.........................................................................2-99

29 2.5.2.1 Economy....................................................................................2-101

30 2.5.2.2 Taxes .........................................................................................2-103

31 2.5.2.3 Transportation............................................................................2-104

32 2.5.2.4 Aesthetics and Recreation.........................................................2-108

33 2.5.2.5 Housing......................................................................................2-109

34 2.5.2.6 Public Services ..........................................................................2-110

35 2.5.2.7 Education...................................................................................2-113

36 2.6 Environmental Justice ..........................................................................................2-115

37 2.6.1 Methodology.............................................................................................2-115

38 2.6.1.1 Minority Populations ..................................................................2-117
April 2010 vii Draft NUREG-1936 

1 2.6.1.2 Low- Income Populations ..........................................................2-118

2 2.6.2 Scoping and Outreach..............................................................................2-118

3 2.6.3 Subsistence and Communities with Unique Characteristics ....................2-120

4 2.6.4 Migrant Populations..................................................................................2-122

5 2.6.5 Environmental Justice Summary ..............................................................2-123

6 2.7 Historic and Cultural Resources...........................................................................2-123

7 2.7.1 Cultural Background.................................................................................2-124

8 2.7.2 Historic and Cultural Resources at the Proposed Unit 3 Site ...................2-124

9 2.7.3 Consultation..............................................................................................2-130

10 2.8 Geology................................................................................................................2-131

11 2.9 Meteorology and Air Quality.................................................................................2-135

12 2.9.1 Climate ...................................................................................................2-135

13 2.9.1.1 Wind...........................................................................................2-136

14 2.9.1.2 Temperature ..............................................................................2-137

15 2.9.1.3 Atmospheric Moisture ................................................................2-137

16 2.9.1.4 Atmospheric Stability .................................................................2-138

17 2.9.1.5 Severe Weather.........................................................................2-138

18 2.9.2 Air Quality.................................................................................................2-139

19 2.9.3 Atmospheric Dispersion............................................................................2-139

20 2.9.4 Meteorological Monitoring ........................................................................2-142

21 2.10 Nonradiological Health .........................................................................................2-142

22 2.10.1 Public and Occupational Health ...............................................................2-143

23 2.10.1.1 Air Quality ..................................................................................2-143

24 2.10.1.2 Occupational Injuries .................................................................2-143

25 2.10.1.3 Etiological Agents ......................................................................2-144

26 2.10.2 Noise ...................................................................................................2-145

27 2.10.3 Transportation ..........................................................................................2-145

28 2.10.4 Electromagnetic Fields .............................................................................2-145

29 2.11 Radiological Environment.....................................................................................2-146

30 2.12 Related Federal Projects and Consultations........................................................2-147

31 2.13 References...........................................................................................................2-148

32 3.0 Site Layout and Plant Description ....................................................................................3-1

33 3.1 External Appearance and Plant Layout....................................................................3-1

34 3.2 Proposed Plant Structures .......................................................................................3-2
Draft NUREG-1936 viii April 2010 

1 3.2.1 Reactor Power Conversion System..............................................................3-4

2 3.2.2 Structures with a Major Plant-Environmental-Interface ................................3-5

3 3.2.2.1 Landscape and Stormwater Drainage ...........................................3-5

4 3.2.2.2 Cooling-Water System...................................................................3-8

5 3.2.2.3 Other Permanent Plant-Environment Interfacing Structures..........3-9

6 3.2.2.4 Other Temporary Plant-Environment Interfacing Structures........3-10

7 3.2.2.5 Power Transmission System .......................................................3-11

8 3.2.3 Structures with a Minor Environmental Interface........................................3-13

9 3.2.3.1 Power Block.................................................................................3-13

10 3.2.3.2 Pipelines ......................................................................................3-13

11 3.2.3.3 Wastewater Retention Basin........................................................3-13

12 3.2.3.4 Miscellaneous Buildings ..............................................................3-13

13 3.2.3.5 Parking.........................................................................................3-14

14 3.2.3.6 Laydown Areas ............................................................................3-14

15 3.2.3.7 Seal Well......................................................................................3-14

16 3.2.3.8 Desalination Plant........................................................................3-14

17 3.3 Construction and Preconstruction Activities...........................................................3-14

18 3.3.1 Major Activity Areas....................................................................................3-16

19 3.3.1.1 Landscape and Stormwater Drainage .........................................3-17

20 3.3.1.2 Power Block.................................................................................3-17

21 3.3.1.3 Cooling Tower..............................................................................3-17

22 3.3.1.4 Cooling-Water Intake Structures..................................................3-17

23 3.3.1.5 Fish-return System.......................................................................3-19

24 3.3.1.6 Discharge Structure .....................................................................3-21

25 3.3.1.7 Barge Facility ...............................................................................3-21

26 3.3.1.8 Construction Support and Laydown Areas ..................................3-25

27 3.3.1.9 Switchyard and Onsite Transmission Corridor.............................3-26

28 3.3.1.10 Roadways ....................................................................................3-26

29 3.3.1.11 Pipelines ......................................................................................3-26

30 3.3.1.12 Concrete Batch Plant...................................................................3-26

31 3.3.1.13 Parking.........................................................................................3-27

32 3.3.1.14 Miscellaneous Buildings ..............................................................3-27

33 3.3.1.15 Cranes and Crane Footings.........................................................3-27

34 3.3.2 Summary of Resource Parameters During Construction and 

35 Preconstruction...........................................................................................3-27

36 3.4 Operational Activities..............................................................................................3-28

37 3.4.1 Description of Operational Modes ..............................................................3-28

38 3.4.2 Plant-Environment Interfaces During Operation.........................................3-29
April 2010 ix Draft NUREG-1936 

1 3.4.2.1 Circulating Water System – Intakes, Discharges, Cooling 

2 Tower...........................................................................................3-29

3 3.4.2.2 Essential Service Water System..................................................3-30

4 3.4.2.3 Power Transmission System .......................................................3-30

5 3.4.2.4 Emergency Diesel Generators.....................................................3-30

6 3.4.3 Radioactive Waste Management System...................................................3-31

7 3.4.3.1 Liquid Radioactive Waste Management System .........................3-31

8 3.4.3.2 Gaseous Radioactive Waste Management System.....................3-32

9 3.4.3.3 Solid Radioactive Waste Management System...........................3-32

10 3.4.4 Nonradioactive Waste Systems..................................................................3-33

11 3.4.4.1 Solid Waste Management............................................................3-33

12 3.4.4.2 Liquid Waste Management ..........................................................3-33

13 3.4.4.3 Gaseous Waste Management .....................................................3-34

14 3.4.4.4 Hazardous and Mixed Waste Management.................................3-35

15 3.4.5 Summary of Resource Parameters during Operation ................................3-35

16 3.5 References.............................................................................................................3-36

17 4.0 Construction Impacts at the Proposed Site ......................................................................4-1

18 4.1 Land-Use Impacts ....................................................................................................4-4

19 4.1.1 The Site and Vicinity.....................................................................................4-4

20 4.1.2 Transmission Line Corridors and Offsite Areas............................................4-6

21 4.2 Water-Related Impacts.............................................................................................4-7

22 4.2.1 Hydrological Alterations................................................................................4-8

23 4.2.2 Water Use Impacts.......................................................................................4-8

24 4.2.2.1 Surface Water Use Impacts...........................................................4-9

25 4.2.2.2 Groundwater Use Impacts ...........................................................4-10

26 4.2.3 Water Quality Impacts ................................................................................4-11

27 4.2.3.1 Surface Water Quality Impacts ....................................................4-11

28 4.2.3.2 Groundwater Quality Impacts ......................................................4-12

29 4.2.4 Water Monitoring ........................................................................................4-13

30 4.3 Ecological Impacts .................................................................................................4-13

31 4.3.1 Terrestrial and Wetland Impacts.................................................................4-13

32 4.3.1.1 Terrestrial Resources – Site and Vicinity.....................................4-14

33 4.3.1.2 Terrestrial Resources – Transmission Lines................................4-20

34 4.3.1.3 Important Terrestrial Species and Habitats..................................4-21

35 4.3.1.4 Terrestrial Monitoring...................................................................4-34

36 4.3.1.5 Summary of Impacts to Terrestrial and Wetland Resources .......4-34

37 4.3.2 Aquatic Impacts..........................................................................................4-35
Draft NUREG-1936 x April 2010 

1 4.3.2.1 Aquatic Resources – Site and Vicinity .........................................4-35

2 4.3.2.2 Important Aquatic Species...........................................................4-42

3 4.3.2.3 Aquatic Resources – Transmission Lines....................................4-47

4 4.3.2.4 Aquatic Monitoring .......................................................................4-47

5 4.3.2.5 Summary of Impacts to Aquatic Resources.................................4-47

6 4.4 Socioeconomic Impacts .........................................................................................4-49

7 4.4.1 Physical Impacts.........................................................................................4-50

8 4.4.1.1 Workers and the Local Public ......................................................4-50

9 4.4.1.2 Noise............................................................................................4-51

10 4.4.1.3 Air Quality ....................................................................................4-51

11 4.4.1.4 Buildings ......................................................................................4-52

12 4.4.1.5 Transportation..............................................................................4-52

13 4.4.1.6 Aesthetics ....................................................................................4-53

14 4.4.1.7 Summary of Physical Impacts......................................................4-53

15 4.4.2 Demography...............................................................................................4-54

16 4.4.3 Economic Impacts on the Community........................................................4-55

17 4.4.3.1 Economy......................................................................................4-55

18 4.4.3.2 Taxes ...........................................................................................4-56

19 4.4.3.3 Summary of Economic Impacts on the Community.....................4-58

20 4.4.4 Infrastructure and Community Service Impacts..........................................4-58

21 4.4.4.1 Transportation..............................................................................4-58

22 4.4.4.2 Recreation ...................................................................................4-60

23 4.4.4.3 Housing........................................................................................4-60

24 4.4.4.4 Public Services ............................................................................4-62

25 4.4.4.5 Education.....................................................................................4-64

26 4.4.4.6 Summary of Infrastructure and Community Services Impacts.....4-65

27 4.4.5 Summary of Socioeconomic Impacts .........................................................4-65

28 4.5 Environmental Justice Impacts...............................................................................4-66

29 4.5.1 Health Impacts............................................................................................4-67

30 4.5.2 Physical and Environmental Impacts..........................................................4-68

31 4.5.2.1 Soil...............................................................................................4-68

32 4.5.2.2 Water ...........................................................................................4-69

33 4.5.2.3 Air ................................................................................................4-69

34 4.5.2.4 Noise............................................................................................4-70

35 4.5.2.5 Summary of Physical and Environmental Impacts.......................4-70

36 4.5.3 Socioeconomic Impacts..............................................................................4-70

37 4.5.4 Subsistence and Special Conditions ..........................................................4-71

38 4.5.4.1 Summary of Physical and Environmental Impacts.......................4-71 
April 2010 xi Draft NUREG-1936 

1 4.5.4.2 High-Density Communities ..........................................................4-71

2 4.5.5 Summary of Environmental Justice Impacts ..............................................4-71 

3 4.6 Historic and Cultural Resources.............................................................................4-72

4 4.6.1 Summary of Impacts to Historic and Cultural Resources ...........................4-74

5 4.7 Meteorological and Air Quality Impacts..................................................................4-76

6 4.7.1 Construction and Preconstruction Activities ...............................................4-76

7 4.7.2 Transportation ............................................................................................4-78

8 4.7.3 Summary of Meteorological and Air Quality Impacts..................................4-79

9 4.8 Nonradiological Health Impacts..............................................................................4-79

10 4.8.1 Public and Occupational Health .................................................................4-80

11 4.8.1.1 Public Health................................................................................4-80

12 4.8.1.2 Construction Worker Health.........................................................4-80

13 4.8.1.3 Summary of Public and Construction Worker Health Impacts.....4-81

14 4.8.2 Noise Impacts.............................................................................................4-81

15 4.8.3 Transporting Construction Materials and Personnel to the Proposed 

16 Site .....................................................................................................4-83

17 4.8.4 Summary of Nonradiological Health Impacts .............................................4-85

18 4.9 Radiological Exposure to Construction Workers....................................................4-85

19 4.9.1 Direct Radiation Exposures........................................................................4-86

20 4.9.2 Radiation Exposures from Gaseous Effluents............................................4-86

21 4.9.3 Radiation Exposures from Liquid Effluents.................................................4-87

22 4.9.4 Total Dose to Construction Workers...........................................................4-87

23 4.9.5 Summary of Radiological Health Impacts...................................................4-88

24 4.10 Nonradioactive Waste Impacts...............................................................................4-88

25 4.10.1 Impacts to Land..........................................................................................4-88

26 4.10.2 Impacts to Water ........................................................................................4-89

27 4.10.3 Impacts to Air..............................................................................................4-89

28 4.10.4 Summary of Nonradiological Waste Impacts..............................................4-90

29 4.11 Measures and Controls to Limit Adverse Impacts During Construction and 

30 Preconstruction ......................................................................................................4-91

31 4.12 Summary of Construction Impacts .........................................................................4-91

32 4.13 References.............................................................................................................4-97

33 5.0 Station Operation Impacts at the Proposed Site ..............................................................5-1

34 5.1 Land-Use Impacts ....................................................................................................5-1
Draft NUREG-1936 xii April 2010 

1 5.1.1 The Site and Vicinity.....................................................................................5-2

2 5.1.2 Transmission Line Corridors and Offsite Areas............................................5-2

3 5.2 Water-Related Impacts.............................................................................................5-2

4 5.2.1 Hydrological Alterations................................................................................5-3

5 5.2.2 Water Use Impacts.......................................................................................5-4

6 5.2.2.1 Surface Water Use Impacts...........................................................5-4

7 5.2.2.2 Groundwater Use Impacts .............................................................5-5

8 5.2.3 Water Quality Impacts ..................................................................................5-5

9 5.2.3.1 Surface Water Quality Impacts ......................................................5-5

10 5.2.3.2 Groundwater Quality Impacts ........................................................5-7

11 5.2.4 Water Monitoring ..........................................................................................5-7

12 5.3 Ecological Impacts ...................................................................................................5-8

13 5.3.1 Terrestrial and Wetland Impacts...................................................................5-8

14 5.3.1.1 Terrestrial Resources – Site and Vicinity.......................................5-8

15 5.3.1.2 Terrestrial Resources – Transmission Line Corridors....................5-9

16 5.3.1.3 Important Terrestrial Species and Habitat ...................................5-11

17 5.3.1.4 Terrestrial Monitoring...................................................................5-13

18 5.3.1.5 Summary of Impacts to Terrestrial Resources.............................5-13

19 5.3.2 Aquatic Impacts..........................................................................................5-14

20 5.3.2.1 Aquatic Resources – Site and the Vicinity ...................................5-14

21 5.3.2.2 Aquatic Resources – Transmission Line Corridor........................5-24

22 5.3.2.3 Important Aquatic Species...........................................................5-24

23 5.3.2.4 Aquatic Monitoring .......................................................................5-29

24 5.3.2.5 Summary of Impacts to Aquatic Resources.................................5-29

25 5.4 Socioeconomic Impacts .........................................................................................5-29

26 5.4.1 Physical Impacts.........................................................................................5-30

27 5.4.1.1 Workers and the Local Public ......................................................5-30

28 5.4.1.2 Buildings ......................................................................................5-31

29 5.4.1.3 Roads ..........................................................................................5-31

30 5.4.1.4 Aesthetics ....................................................................................5-31

31 5.4.1.5 Summary of Physical Impacts......................................................5-32

32 5.4.2 Demography...............................................................................................5-32

33 5.4.3 Economic Impacts to the Community .........................................................5-33

34 5.4.3.1 Economy......................................................................................5-33

35 5.4.3.2 Taxes ...........................................................................................5-34

36 5.4.3.3 Summary of Economic Impacts to the Community......................5-36

37 5.4.4 Infrastructure and Community Services .....................................................5-36
April 2010 xiii Draft NUREG-1936 

1 5.4.4.1 Transportation..............................................................................5-36

2 5.4.4.2 Recreation ...................................................................................5-37

3 5.4.4.3 Housing........................................................................................5-37

4 5.4.4.4 Public Services ............................................................................5-38

5 5.4.4.5 Education.....................................................................................5-39

6 5.4.4.6 Summary of Impacts to Infrastructure and Community 

7 Services.......................................................................................5-39

8 5.4.5 Summary of Socioeconomic Impacts .........................................................5-40

9 5.5 Environmental Justice ............................................................................................5-40

10 5.5.1 Health Impacts............................................................................................5-40

11 5.5.2 Physical and Environmental Impacts..........................................................5-41

12 5.5.2.1 Soil...............................................................................................5-41

13 5.5.2.2 Water ...........................................................................................5-41

14 5.5.2.3 Air ................................................................................................5-42

15 5.5.3 Socioeconomic Impacts..............................................................................5-42

16 5.5.4 Subsistence and Special Conditions ..........................................................5-43

17 5.5.5 Summary of Environmental Justice Impacts ..............................................5-43

18 5.6 Historic and Cultural Resource Impacts from Operation........................................5-43

19 5.7 Meteorological and Air Quality Impacts..................................................................5-45

20 5.7.1 Cooling Tower Impacts...............................................................................5-45

21 5.7.2 Air Quality...................................................................................................5-46

22 5.7.3 Transmission Line Impacts.........................................................................5-49

23 5.7.4 Summary of Impacts to Air Quality .............................................................5-49

24 5.8 Nonradiological Health Impacts..............................................................................5-49

25 5.8.1 Etiological Agents.......................................................................................5-50

26 5.8.2 Noise .....................................................................................................5-51

27 5.8.3 Acute Effects of Electromagnetic Fields .....................................................5-52

28 5.8.4 Chronic Effects of Electromagnetic Fields..................................................5-52

29 5.8.5 Occupational Health ...................................................................................5-53

30 5.8.6 Transporting Operations Personnel to the Proposed Site ..........................5-54

31 5.8.7 Summary of Nonradiological Health Impacts .............................................5-55

32 5.9 Radiological Impacts of Normal Operations...........................................................5-55

33 5.9.1 Exposure Pathways....................................................................................5-56

34 5.9.2 Radiation Doses to Members of the Public ................................................5-58
Draft NUREG-1936 xiv April 2010 

1 5.9.2.1 Liquid Effluent Pathway ...............................................................5-58

2 5.9.2.2 Gaseous Effluent Pathway ..........................................................5-60

3 5.9.3 Impacts to Members of the Public ..............................................................5-61

4 5.9.3.1 Maximally Exposed Individual......................................................5-61

5 5.9.3.2 Population Dose ..........................................................................5-63

6 5.9.3.3 Summary of Radiological Impacts to Members of the Public.......5-64

7 5.9.4 Occupational Doses to Workers .................................................................5-64

8 5.9.5 Doses to Biota Other than Humans............................................................5-65

9 5.9.5.1 Liquid Effluent Pathway ...............................................................5-65

10 5.9.5.2 Gaseous Effluent Pathway ..........................................................5-66

11 5.9.5.3 Impact of Estimated Non-Human Biota Doses ............................5-66

12 5.9.6 Radiological Monitoring ..............................................................................5-67

13 5.10 Nonradioactive Waste Impacts...............................................................................5-68

14 5.10.1 Impacts to Land..........................................................................................5-68

15 5.10.2 Impacts to Water ........................................................................................5-69

16 5.10.3 Impacts to Air..............................................................................................5-70

17 5.10.4 Mixed Waste Impacts .................................................................................5-70

18 5.10.5 Summary of Nonradiological Impacts.........................................................5-70

19 5.11 Environmental Impacts of Postulated Accidents ....................................................5-71

20 5.11.1 Design Basis Accidents ..............................................................................5-73

21 5.11.1.1 Summary of DBA Impacts............................................................5-75

22 5.11.2 Severe Accidents........................................................................................5-75

23 5.11.2.1 Air Pathway..................................................................................5-77

24 5.11.2.2 Surface Water Pathways .............................................................5-82

25 5.11.2.3 Groundwater Pathway .................................................................5-83

26 5.11.3 Severe Accident Mitigation Alternatives .....................................................5-84

27 5.11.4 Summary of Postulated Accident Impacts..................................................5-85

28 5.12 Measures and Controls to Limit Adverse Impacts During Operation .....................5-86

29 5.13 Summary of Operational Impacts...........................................................................5-90

30 5.14 References.............................................................................................................5-93

31 6.0 Fuel Cycle, Transportation, and Decommissioning ..........................................................6-1

32 6.1 Fuel Cycle Impacts and Solid Waste Management..................................................6-1

33 6.1.1 Land Use ......................................................................................................6-8

34 6.1.2 Water Use.....................................................................................................6-9

35 6.1.3 Fossil Fuel Impacts.......................................................................................6-9
April 2010 xv Draft NUREG-1936 

1 6.1.4 Chemical Effluents......................................................................................6-10

2 6.1.5 Radiological Effluents.................................................................................6-11

3 6.1.6 Radiological Wastes...................................................................................6-13

4 6.1.7 Occupational Dose .....................................................................................6-16

5 6.1.8 Transportation ............................................................................................6-16

6 6.1.9 Conclusions................................................................................................6-17

7 6.2 Transportation Impacts...........................................................................................6-17

8 6.2.1 Transportation of Unirradiated Fuel............................................................6-19

9 6.2.1.1 Normal Conditions .......................................................................6-19

10 6.2.1.2 Radiological Impacts of Transportation Accidents.......................6-25

11 6.2.1.3 Nonradiological Impacts of Transportation Accidents..................6-25

12 6.2.2 Transportation of Spent Fuel......................................................................6-27

13 6.2.2.1 Normal Conditions .......................................................................6-28

14 6.2.2.2 Radiological Impacts of Accidents ...............................................6-34

15 6.2.2.3 Nonradiological Impact of Spent Fuel Shipments........................6-37

16 6.2.3 Transportation of Radioactive Waste .........................................................6-38 

17 6.2.4 Conclusions................................................................................................6-40

18 6.3 Decommissioning Impacts .....................................................................................6-41

19 6.4 References.............................................................................................................6-42

20 7.0 Cumulative Impacts..........................................................................................................7-1

21 7.1 Land Use..................................................................................................................7-7

22 7.2 Water Use and Quality .............................................................................................7-9

23 7.2.1 Surface Water Use Impacts..........................................................................7-9

24 7.2.2 Groundwater Use Impacts..........................................................................7-10

25 7.2.3 Surface Water Quality Impacts...................................................................7-11

26 7.2.4 Groundwater Quality Impacts.....................................................................7-12

27 7.3 Ecology...................................................................................................................7-14

28 7.3.1 Terrestrial Ecology and Wetlands...............................................................7-14

29 7.3.1.1 Wildlife Habitat.............................................................................7-14

30 7.3.1.2 Wetlands......................................................................................7-16

31 7.3.1.3 Important Species........................................................................7-17

32 7.3.1.4 Summary of Terrestrial Ecology and Wetland Impacts................7-20

33 7.3.2 Aquatic Ecology..........................................................................................7-21

34 7.3.2.1 Freshwater Habitats and Fauna...................................................7-22

35 7.3.2.2 Estuarine Habitats and Fauna .....................................................7-24
Draft NUREG-1936 xvi April 2010 

1 7.3.2.3 Summary of Aquatic Ecology Impacts .........................................7-28

2 7.4 Socioeconomics and Environmental Justice..........................................................7-29

3 7.4.1 Socioeconomics .........................................................................................7-29

4 7.4.2 Environmental Justice ................................................................................7-31

5 7.5 Historic and Cultural Resources.............................................................................7-32

6 7.6 Air Quality...............................................................................................................7-33

7 7.6.1 Criteria Pollutants .......................................................................................7-33

8 7.6.2 Greenhouse Gas Emissions.......................................................................7-34 

9 7.6.3 Summary of Air Quality Impacts .................................................................7-36 

10 7.7 Nonradiological Health ...........................................................................................7-36

11 7.8 Radiological Health Impacts of Normal Operation .................................................7-38

12 7.9 Postulated Accidents..............................................................................................7-39

13 7.10 Fuel Cycle, Transportation, and Decommissioning................................................7-40

14 7.10.1 Fuel Cycle...................................................................................................7-40

15 7.10.2 Transportation ............................................................................................7-41

16 7.10.3 Decommissioning .......................................................................................7-43

17 7.11 Conclusions............................................................................................................7-43

18 7.12 References.............................................................................................................7-45

19 8.0 Need for Power.................................................................................................................8-1

20 8.1 Description of Power System ...................................................................................8-2

21 8.2 Power Demand.........................................................................................................8-3

22 8.3 Power Supply ...........................................................................................................8-3

23 8.4 Assessment of Need for Power................................................................................8-5

24 8.4.1 Grant of a Certificate of Public Convenience and Necessity for Unit 3 ........8-5

25 8.4.2 Maryland Public Service Commission Electric Supply Adequacy 

26 Report .......................................................................................................8-6

27 8.4.3 Reliability First Corporation Reserve Margin Projections .............................8-7

28 8.4.4 Maryland Energy Administration...................................................................8-7

29 8.5 NRC Staff Conclusions.............................................................................................8-8

30 8.6 References...............................................................................................................8-9

31 9.0 Environmental Impacts of Alternatives .............................................................................9-1

32 9.1 No-Action Alternative................................................................................................9-2

33 9.2 Energy Alternatives ..................................................................................................9-3
April 2010 xvii Draft NUREG-1936 

1 9.2.1 Alternatives Not Requiring New Generating Capacity..................................9-3

2 9.2.2 Alternatives Requiring New Generating Capacity ........................................9-7

3 9.2.2.1 Coal-Fired Generation ...................................................................9-8

4 9.2.2.2 Natural Gas-Fired Generation......................................................9-14

5 9.2.3 Other Alternatives.......................................................................................9-20

6 9.2.3.1 Oil-Fired Generation ....................................................................9-20

7 9.2.3.2 Wind Power .................................................................................9-20

8 9.2.3.3 Solar Power .................................................................................9-22

9 9.2.3.4 Hydropower .................................................................................9-23

10 9.2.3.5 Geothermal Energy......................................................................9-23

11 9.2.3.6 Wood Waste ................................................................................9-24

12 9.2.3.7 Municipal Solid Waste .................................................................9-24

13 9.2.3.8 Other Biomass-Derived Fuels......................................................9-25

14 9.2.3.9 Fuel Cells.....................................................................................9-25

15 9.2.4 Combination of Alternatives........................................................................9-26

16 9.2.5 Summary Comparison of Energy Alternatives............................................9-28

17 9.3 Alternative Sites .....................................................................................................9-30

18 9.3.1 Alternative Site Selection Process..............................................................9-30

19 9.3.1.1 Selection of Region of Interest.....................................................9-31

20 9.3.1.2 UniStar’s Site Selection Process .................................................9-31

21 9.3.2 NRC/Corps Alternative Site Evaluation ......................................................9-35

22 9.3.3 Bainbridge Naval Training Center ..............................................................9-38

23 9.3.3.1 Land Use .....................................................................................9-41

24 9.3.3.3 Terrestrial and Wetland Resources .............................................9-49

25 9.3.3.4 Aquatic Resources.......................................................................9-57

26 9.3.3.5 Socioeconomics...........................................................................9-65

27 9.3.3.6 Environmental Justice..................................................................9-70

28 9.3.3.7 Historic and Cultural Resources ..................................................9-73

29 9.3.3.8 Air Quality ....................................................................................9-74

30 9.3.3.9 Nonradiological Health Impacts ...................................................9-75

31 9.3.3.10 Radiological Impacts of Normal Operations.................................9-77

32 9.3.3.11 Postulated Accidents ...................................................................9-78

33 9.3.4 Eastalco Site...............................................................................................9-79

34 9.3.4.1 Land Use .....................................................................................9-83

35 9.3.4.2 Water Use and Quality.................................................................9-85

36 9.3.4.3 Terrestrial and Wetland Resources .............................................9-88

37 9.3.4.4 Aquatic Resources.......................................................................9-97

38 9.3.4.5 Socioeconomics.........................................................................9-102
Draft NUREG-1936 xviii April 2010 

1 9.3.4.6 Environmental Justice................................................................9-108

2 9.3.4.7 Historic and Cultural Resources ................................................9-111

3 9.3.4.8 Air Quality ..................................................................................9-112

4 9.3.4.9 Nonradiological Health Impacts .................................................9-113

5 9.3.4.10 Radiological Impacts of Normal Operations...............................9-115

6 9.3.4.11 Postulated Accidents .................................................................9-115

7 9.3.5 Former Thiokol Brownfield Site ................................................................9-116

8 9.3.5.1 Land Use ...................................................................................9-117

9 9.3.5.2 Water Use and Quality...............................................................9-124

10 9.3.5.3 Terrestrial and Wetland Resources ...........................................9-127

11 9.3.5.4 Aquatic Resources.....................................................................9-134

12 9.3.5.5 Socioeconomics.........................................................................9-142

13 9.3.5.6 Environmental Justice................................................................9-147

14 9.3.5.7 Historic and Cultural Resources ................................................9-148

15 9.3.5.8 Air Quality ..................................................................................9-152

16 9.3.5.9 Nonradiological Health Impacts .................................................9-152

17 9.3.5.10 Radiological Impacts of Normal Operations...............................9-154

18 9.3.5.11 Postulated Accidents .................................................................9-155

19 9.3.6 Comparison of the Impacts of the Proposed Action and Alternative 

20 Sites ...................................................................................................9-156

21 9.3.6.1 Comparison of Propose Site and Alternative Site Cumulative 

22 Impacts ......................................................................................9-157

23 9.3.6.2 Environmentally Preferable Sites...............................................9-158

24 9.3.6.3 Obviously Superior Sites............................................................9-161

25 9.4 System Design Alternatives .................................................................................9-161

26 9.4.1 Heat Dissipation Systems.........................................................................9-162

27 9.4.1.1 Once-Through Cooling ..............................................................9-162

28 9.4.1.2 Wet Mechanical Draft Cooling Towers without Plume 

29 Abatement .................................................................................9-162

30 9.4.1.3 Mechanical Draft with Plume Abatement...................................9-163

31 9.4.1.4 Combination Wet-Dry Mechanical Draft Cooling .......................9-163

32 9.4.1.5 Natural Draft Cooling Towers.....................................................9-163

33 9.4.1.6 Dry Cooling Towers ...................................................................9-164

34 9.4.1.7 Cooling Pond and Spray Ponds.................................................9-164

35 9.4.2 Intake and Discharge Systems.................................................................9-164

36 9.4.2.1 Intake Alternatives .....................................................................9-164

37 9.4.2.2 Discharge Alternatives...............................................................9-165

38 9.4.3 Water Supplies .........................................................................................9-165

39 9.4.4 Water Treatment.......................................................................................9-166
April 2010 xix Draft NUREG-1936 

1 9.4.5 Summary of System Design Alternatives .................................................9-166

2 9.5 References...........................................................................................................9-166

3 10.0 Conclusions and Recommendations ..............................................................................10-1

4 10.1 Impacts of the Proposed Action .............................................................................10-4

5 10.2 Unavoidable Adverse Environmental Impacts........................................................10-4

6 10.2.1 Unavoidable Adverse Impacts During Construction and 

7 Preconstruction Activities ...........................................................................10-5

8 10.2.2 Unavoidable Adverse Impacts During Operation .......................................10-9

9 10.3 Relationship Between Short-Term Uses and Long-term Productivity of the 

10 Human Environment.............................................................................................10-13

11 10.4 Irreversible and Irretrievable Commitments of Resources ...................................10-14

12 10.4.1 Irreversible Commitments of Resources ..................................................10-14

13 10.4.1.1 Land Use ...................................................................................10-14

14 10.4.1.2 Water Use..................................................................................10-14

15 10.4.1.3 Terrestrial and Aquatic Biota......................................................10-15

16 10.4.1.4 Socioeconomic Resources ........................................................10-15

17 10.4.1.5 Historic and Cultural Resources ................................................10-15

18 10.4.1.6 Air and Water.............................................................................10-15

19 10.4.2 Irretrievable Commitments of Resources .................................................10-16

20 10.5 Alternatives to the Proposed Action .....................................................................10-16

21 10.6 Benefit-Cost Balance............................................................................................10-17

22 10.6.1 Benefits ...................................................................................................10-20

23 10.6.1.1 Societal Benefits ........................................................................10-20

24 10.6.1.2 Regional Benefits.......................................................................10-21

25 10.6.2 Costs ...................................................................................................10-22

26 10.6.2.1 Internal Costs.............................................................................10-24

27 10.6.2.2 External Costs ...........................................................................10-27

28 10.6.3 Summary of Benefits and Costs ...............................................................10-28

29 10.7 NRC Staff Recommendation................................................................................10-29

30 10.8 References...........................................................................................................10-29

31 Appendix A – Contributors to the Environmental Impact Statement ........................................ A-1

32 Appendix B – Organizations Contacted .................................................................................... B-1

33 Appendix C – Chronology of NRC and Corps........................................................................... C-1

34 Appendix D – Scoping Comments and Responses .................................................................. D-1

35 Appendix E – Draft Environmental Impact Statement Comments and Responses .................. E-1
Draft NUREG-1936 xx April 2010 

1 Appendix F – Key Consultation Correspondence ......................................................................F-1

2 Appendix G – Supporting Documentation on Radiological Dose Assessment .........................G-1

3 Appendix H – Authorizations, Permits, and Certifications......................................................... H-1

4 Appendix I – Severe Accident Mitigation Alternatives.................................................................I-1

5 Appendix J – UniStar’s Least Environmentally Damaging Practicable Alternative (LEDPA) 

6 and Onsite Alternatives Analysis......................................................................................J-1

7 Appendix K – UniStar’s Phase I Mitigation Plan Summary for Wetlands and Stream 

8 Impacts............................................................................................................................ K-1

9 Appendix L – Carbon Dioxide Footprint Estimates for a 1000-MW(e) Reference Reactor.......L-1

10 Appendix M – Supplemental Terrestrial Ecology Information ...................................................M-1
April 2010 xxi Draft NUREG-1936 

1 Figures 

2 2-1 Calvert Cliffs Site and Proposed New Plant Layout.........................................................2-2

3 2-2 The Calvert Cliffs Site and the 50-mi Region...................................................................2-3

4 2-3 Calvert Cliffs Site Map .....................................................................................................2-5

5 2-4 Land Use on the Calvert Cliffs Site..................................................................................2-6

6 2-5 Land-Use Classification Within 8 mi of the Calvert Cliffs Site..........................................2-7

7 2-6 Major Public and Trust Lands in the 50-mi Region........................................................2-11

8 2-7 Maryland Portion of Chesapeake Bay Watershed.........................................................2-12

9 2-8 Watersheds and Proposed Unit 3 Location at the Calvert Cliffs Site.............................2-13

10 2-9 Major Aquifers Beneath the Calvert Cliffs Site...............................................................2-15

11 2-10 Plant Community ..........................................................................................................2-23

12 2-11 FIDS Habitat within Calvert County, Maryland ..............................................................2-35

13 2-12 Calvert Cliffs Wetland Delineation Area.........................................................................2-39

14 2-13 Vicinity Wetlands in Calvert County, Maryland..............................................................2-43

15 2-14 Population within the 50-mi Radius of Proposed Unit 3 by 10-mi Increments 

16 and Direction .................................................................................................................2-96

17 2-15 Highways and Major Roads within Approximately 10 mi of the Proposed Calvert 

18 Cliffs Site .....................................................................................................................2-107 

19 2-16 Distribution of Aggregate Minority Populations of Significance in 2000.......................2-119

20 2-17 Distribution of the Low-Income Populations of Significance in 2000 ...........................2-121

21 2-18 Physiographic Map of Maryland and Surrounding Area .............................................2-133

22 2-19 Stratigraphic Column for the Calvert Cliffs Site ...........................................................2-134

23 3-1 Calvert Cliffs Site and Layout of Proposed Unit 3............................................................3-3

24 3-2 Calvert Cliffs Site with Existing Units 1 and 2 at Left and Superimposed Illustration 

25 of Proposed Unit 3 at Right, Looking to the Southeast....................................................3-4

26 3-3 Simplified Flow Diagram of the Reactor Power Conversion System...............................3-6

27 3-4 Grid Overlay of the Calvert Cliffs Site Layout Showing Major Structure and Activity 

28 Areas ...............................................................................................................................3-7

29 3-5 Existing Transmission System to Support Operation of Proposed Unit 3......................3-12

30 3-6 Site Plan at Unit 3 Intake Structure...............................................................................3-18

31 3-7 Fish-return System ........................................................................................................3-20

32 3-8 Discharge Outfall Details ...............................................................................................3-22

33 3-9 Proposed Restoration of Barge Slip ..............................................................................3-23

34 3-10 Modifications at Existing Barge Unloading Facility ........................................................3-24
Draft NUREG-1936 xxii April 2010 

1 4-1 Locations of Impacts within Vegetation Cover Types of the Calvert Cliffs Site .............4-16

2 4-2 Proposed Mitigation Actions on the Calvert Cliffs Site...................................................4-18

3 4-3 Location and Extent of Non-tidal Wetlands of the Calvert Cliffs Site.............................4-29

4 4-4 Proposed Wetland and Stream Mitigation Actions on the Calvert Cliffs Site.................4-33

5 5-1 Exposure Pathways to Man...........................................................................................5-57

6 5-2 Exposure Pathways to Biota Other Than Man...............................................................5-59

7 6-1 The Uranium Fuel Cycle: No-Recycle Option..................................................................6-6

8 6-2 Illustration of Truck Stop Model .....................................................................................6-31

9 9-1 Locations of UniStar’s Candidate Areas in Maryland ....................................................9-33

10 9-2 Locations of Alternative Sites and Proposed Site..........................................................9-36

11 9-3 Site Location of the Bainbridge Naval Training Center..................................................9-42

12 9-4 Bainbridge Naval Training Center Site and Surrounding Area ......................................9-43

13 9-5 Distribution of Aggregate Minority Populations of Significance in 2000 for the 

14 Bainbridge Site ..............................................................................................................9-71

15 9-6 Distribution of Low-Income Populations of Significance in 2000 for the 

16 Bainbridge Site ..............................................................................................................9-72

17 9-7 Eastalco Site Location ...................................................................................................9-80

18 9-8 Eastalco Site and Surrounding Area..............................................................................9-81

19 9-9 Distribution of Aggregate Minority Populations of Significance in 2000 for the 

20 Eastalco Site................................................................................................................9-109

21 9-10 Distribution of Aggregate Low-Income Populations of Significance in 2000 for the 

22 Eastalco Site................................................................................................................9-110

23 9-11 Thiokol Site Location ...................................................................................................9-121

24 9-12 Thiokol Site and Surrounding Area..............................................................................9-122

25 9-13 Distribution and Abundance of Wetlands Documented by the National Wetlands 

26 Inventory as Occurring On and Around the Thiokol Site .............................................9-129

27 9-14 Distribution of Aggregate Minority Populations of Significance in 2000 for the 

28 Thiokol Site..................................................................................................................9-149

29 9-15 Distribution of Aggregate Low-Income Populations of Significance in 2000 for the 

30 Thiokol Site..................................................................................................................9-150

31 
April 2010 xxiii Draft NUREG-1936 

1 Tables 

2 2-1 Important Species Identified as Known or Likely to Occur on the Calvert Cliffs Site.....2-29

3 2-2 Calvert Cliffs Site Delineated Wetland Summary Table ................................................2-40

4 2-3 Important Freshwater Species at the Calvert Cliffs Site ................................................2-55

5 2-4 Important Estuarine Species that May Occur in Chesapeake Bay Near the Calvert 

6 Cliffs Site .......................................................................................................................2-67

7 2-5 Total Population for Counties within or partially within the 50-mi Radius of CCNPP 

8 in 2000 and 2006...........................................................................................................2-93

9 2-6 Distribution of Current Calvert Cliffs Site Employees by County of Residence in 

10 2006...............................................................................................................................2-94

11 2-7 Select Demographic Characteristics for the Resident Population in Calvert and 

12 St. Mary’s Counties .......................................................................................................2-97

13 2-8 Projection of the Resident Population for Geographic Areas within a 50-mi Radius 

14 of the Proposed Unit 3 Site by 10-mi Increments from 2000 to 2060............................2-98

15 2-9 Projected Population Growth in Calvert and St. Mary’s Counties and Maryland 

16 from 2000-2030 .............................................................................................................2-99

17 2-10 Transient Population in the Calvert Cliffs Site Vicinity in 2000 ......................................2-99

18 2-11 Employment by Class and Occupation in Calvert and St. Mary’s Counties and 

19 Maryland 2006.............................................................................................................2-101

20 2-12 Total and Per Capita Income in 2005 ..........................................................................2-102

21 2-13 Sales & Use, Income, and Property Tax Rates (%) for Maryland and Calvert and 

22 St. Mary’s Counties in 2007.........................................................................................2-103

23 2-14 Revenues by Major Category for the State of Maryland and Calvert and St. Mary’s 

24 Counties in 2007..........................................................................................................2-105

25 2-15 Recreational Acreage Needed in Calvert and St. Mary’s Counties to Meet Goal 

26 from 2005-2020 ...........................................................................................................2-109

27 2-16 Number of Housing Units in Calvert and St. Mary’s Counties in 2006 ........................2-110

28 2-17 Police Activity Levels in 2005 and 2006 ......................................................................2-111

29 2-18 Number of Fire, EMS, and Rescue Calls/Responses in 2006 and 2007.....................2-112

30 2-19 Public and Private School Enrollment in Calvert and St. Mary’s Counties in the 

31 2005-06 School Year...................................................................................................2-114

32 2-20 Regional Minority and Low-Income Populations by Census Block Analysis Results ..2-118

33 2-21 Low Income Census Block Groups in 2000.................................................................2-120

34 2-22 Calvert Cliffs Archaeological Sites Identified - Phase I/II Investigations......................2-128

35 2-23 Calvert Cliffs Architectural Structures Identified - Phase I/II Investigations .................2-129
Draft NUREG-1936 xxiv April 2010 

1 2-24 Annual Average Atmospheric Dispersion and Deposition Factors for the Nearest 

2 Residence for Evaluation of Normal Effluents .............................................................2-140

3 2-25 Annual Average Atmospheric Dispersion and Deposition Factors for the Nearest 

4 Vegetable Gardens for Evaluation of Normal Effluents ...............................................2-141

5 2-26 Atmospheric Dispersion Factors for Calvert Cliffs Design Basis Accident 

6 Calculations .................................................................................................................2-141

7 3-1 Descriptions and Examples of Activities Associated with Building Proposed Unit 3 .....3-15

8 3-2 Summary of Resource Commitments Associated with Building Proposed Unit 3 .........3-27

9 3-3 Resource Parameters During Operation .......................................................................3-35

10 4-1 Areal Extent of Disturbance to Cover Types on the Calvert Cliffs Site..........................4-15

11 4-2 FIDS Habitat Impact Table ............................................................................................4-26

12 4-3 Areal Extent of Impacts to Non-tidal Wetlands of the Calvert Cliffs Site........................4-28

13 4-4 UniStar Proposed Wetland Mitigation Actions within the Calvert Cliffs Site ..................4-32

14 4-5 Potential Peak Increase in Population During Peak Construction and 

15 Preconstruction Activities of Proposed Unit 3................................................................4-55

16 4-6 Proposed Unit 3 Direct and Indirect Employment During Construction and 

17 Preconstruction Activities from 2011–2016 ...................................................................4-56

18 4-7 Expected Increase in Police and Fire Services Related to Proposed Unit 3 .................4-63

19 4-8 Worst Year (Year Two) Annual Construction Emissions (Tons/yr)................................4-77

20 4-9 Estimated Impacts of Transporting Workers and Materials to and from the 

21 Proposed Unit 3 Site......................................................................................................4-85

22 4-10 Summary of Measures and Controls Proposed by UniStar to Limit Adverse 

23 Impacts When Building Proposed Unit 3 .......................................................................4-92

24 4-11 Summary of Impacts from Construction of Proposed Unit 3..........................................4-95

25 5-1 Estimated Impingement and Mortality at CCNPP Units 1 and 2 and Projected 

26 Values for Proposed Unit 3............................................................................................5-19

27 5-2 Estimated Entrainment at CCNPP Units 1 and 2 for March 2006 through 

28 September 2007 and Projected Values for Proposed Unit 3.........................................5-26

29 5-3 Occurrence of Important Fish Species in Impingement Samples Collected at 

30 CCNPP Units 1 and 2 from 1975 to 1995......................................................................5-28

31 5-4 Potential Increase in Resident Population Resulting from Operating Proposed 

32 Unit 3 .............................................................................................................................5-33

33 5-5 Regulated Sources Emissions.......................................................................................5-47

34 5-6 Circulating Water Supply System Cooling Tower Toxic Air Pollutant Emission 

35 Rates ............................................................................................................................5-48

36 5-7 Estimated Impacts of Transporting Workers to and from the Proposed Unit 3 Site ......5-55

37 5-8 Annual Doses to the Maximally Exposed Individual for Liquid Effluent Releases 

38 from Calvert Cliffs Proposed Unit 3 ...............................................................................5-60
April 2010 xxv Draft NUREG-1936 

1 5-9 Doses to the MEI from Gaseous Effluent Pathway for Unit 3........................................5-61

2 5-10 Comparisons of MEI Annual Dose Estimates from Liquid and Gaseous Effluents 

3 to 10 CFR Part 50, Appendix I Design Objectives.........................................................5-62

4 5-11 Comparison of Doses to 40 CFR Part 190 ....................................................................5-63

5 5-12 Biota Doses for Proposed Unit 3 ...................................................................................5-66

6 5-13 Comparison of Biota Doses from the Proposed Unit 3 to Relevant Guidelines for 

7 Biota Protection .............................................................................................................5-67

8 5-14 Atmospheric Dispersion Factors for Calvert Cliffs Site DBA Calculations .....................5-74

9 5-15 DBA Doses for a U.S. EPR Reactor..............................................................................5-75

10 5-16 Environmental Risks from an U.S. EPR Reactor Severe Accident at the Calvert 

11 Cliffs Site .......................................................................................................................5-78

12 5-17 Comparison of Environmental Risks for an U.S. EPR Reactor at the Calvert Cliffs 

13 Site with Risks for Current-Generation Reactors at Five Sites Evaluated in 

14 NUREG-1150 ................................................................................................................5-79

15 5-18 Comparison of Environmental Risks from Severe Accidents for an U.S. EPR 

16 Reactor at the Calvert Cliffs Site with Risks for Current Plants from Operating 

17 License Renewal Reviews, including CCNPP Units 1 and 2.........................................5-80

18 5-19 Summary of Measures and Controls Proposed by UniStar to Limit Adverse 

19 Impacts During Operation..............................................................................................5-86

20 5-20 Characterization of Operational Impacts at the Proposed Unit 3 Site ...........................5-90

21 6-1 Table S–3 from 10 CFR 51.51(b), Table of Uranium Fuel Cycle Environmental 

22 Data .................................................................................................................................6-2

23 6-2 Comparison of Annual Average Dose Received by an Individual from All Sources ......6-13

24 6-3 Numbers of Truck Shipments of Unirradiated Fuel for the Reference LWR and the 

25 U.S. EPR .......................................................................................................................6-20

26 6-4 RADTRAN 5.6 Input Parameters for Unirradiated Fuel Shipments...............................6-21

27 6-5 Radiological Impacts Under Normal Conditions of Transporting Unirradiated Fuel 

28 to the Calvert Cliffs Site and Alternative Sites ...............................................................6-22

29 6-6 Nonradiological Impacts of Transporting Unirradiated Fuel to the Calvert Cliffs Site 

30 and Alternative Sites, Normalized to Reference LWR...................................................6-26

31 6-7 Transportation Route Information for Shipments from the Calvert Cliffs Site and 

32 Alternative Sites to the Geologic HLW Repository at Yucca Mountain Spent Fuel 

33 Disposal Facility.............................................................................................................6-29

34 6-8 RADTRAN 5.6 Normal Exposure Parameters...............................................................6-30

35 6-9 Normal Radiation Doses to Transport Workers and the Public from Shipping 

36 Spent Fuel from the Calvert Cliffs Site and Alternative Sites to the Geologic HLW 

37 Repository at Yucca Mountain.......................................................................................6-32
Draft NUREG-1936 xxvi April 2010 

1 6-10 Radionuclide Inventories Used in Transportation Accident Risk Calculations for 

2 the U.S. EPR .................................................................................................................6-35

3 6-11 Annual Spent Fuel Transportation Accident Impacts for an U.S. EPR Reactor at 

4 the Calvert Cliffs Site and Alternative Sites, Normalized to Reference 1100-MW(e) 

5 LWR Net Electrical Generation......................................................................................6-37

6 6-12 Nonradiological Impacts of Transporting Spent Fuel from the Calvert Cliffs Site 

7 and Alternative Sites to the Geologic HLW Repository at Yucca Mountain, 

8 Normalized to Reference LWR......................................................................................6-38

9 6-13 Summary of Radioactive Waste Shipments from the Calvert Cliffs Site and 

10 Alternative Sites.............................................................................................................6-39

11 6-14 Nonradiological Impacts of Radioactive Waste Shipments from the Calvert Cliffs 

12 Site ................................................................................................................................6-40

13 7-1 Past, Present, and Reasonably Foreseeable Projects and Other Actions 

14 Considered in the Cumulative Analysis ...........................................................................7-3

15 7-2 Comparison of Annual Carbon Dioxide Emission Rates ...............................................7-35

16 7-3 Cumulative Impacts on Environmental Resources, Including the Impacts of 

17 Proposed Unit 3.............................................................................................................7-44

18 9-1 Summary of Environmental Impacts of Coal-Fired Power Generation..........................9-15

19 9-2 Summary of Environmental Impacts of Natural Gas-Fired Power Generation ..............9-19

20 9-3 Summary of Environmental Impacts of a Combination of Power Sources ....................9-27

21 9-4 Summary of Environmental Impacts of Construction and Operation of New 

22 Nuclear, Coal-Fired, and Natural Gas-Fired Generating Units and a Combination 

23 of Alternatives................................................................................................................9-28

24 9-5 Comparison of Carbon Dioxide Emissions for Energy Alternatives...............................9-29

25 9-6 Past, Present, and Reasonably Foreseeable Projects and Other Actions 

26 Considered in the Bainbridge Site Cumulative Analysis................................................9-39

27 9-7 Federally and State-Listed Terrestrial Species that Occur in Cecil County and May 

28 Occur on the Bainbridge Site or in the Immediate Vicinity.............................................9-50

29 9-8 Past, Present, and Reasonably Foreseeable Projects and Other Actions 

30 Considered in the Eastalco Site Cumulative Analysis ...................................................9-82

31 9-9 State-Listed Terrestrial Species that Occur in Frederick County and May Occur on 

32 the Eastalco Site or in the Immediate Vicinity ...............................................................9-90

33 9-10 Past, Present, and Reasonably Foreseeable Projects and Other Actions 

34 Considered in the Thiokol Site Cumulative Analysis ...................................................9-118

35 9-11 Federally and State-Listed Terrestrial Species that Occur in St. Mary’s County and 

36 May Occur on the Thiokol Site or in the Immediate Vicinity ........................................9-130

37 9-12 Comparison of Cumulative Impacts at the Proposed and Alternative Sites ................9-159
April 2010 xxvii Draft NUREG-1936 

1 10-1 Unavoidable Adverse Environmental Impacts from Construction and 

2 Preconstruction Activities ..............................................................................................10-6

3 10-2 Unavoidable Adverse Environmental Impacts from Operation......................................10-9

4 10-3 Summary of Benefits of the Proposed Action..............................................................10-19

5 10-4 Summary of Costs of Preconstruction, Construction, and Operation ..........................10-23

6 

April 2010 xxix Draft NUREG-1936 

1 Executive Summary 

2 By letter dated July 13, 2007, the U.S. Nuclear Regulatory Commission (NRC) received a partial 

3 application from UniStar Nuclear Development, LLC, on behalf of Constellation Generation 

4 Group, LLC and UniStar Nuclear Operating Services, LLC (collectively known as UniStar), for a 

5 combined construction permit and operating license (combined license or COL) for Calvert Cliffs 

6 Nuclear Power Plant (CCNPP) Unit 3 to be located adjacent to the existing Units 1 and 2 in 

7 Calvert County, Maryland. Part 1 of the application contained the applicant’s Environmental 

8 Report (ER) and site suitability information and was accepted on January 25, 2008. Part 2, 

9 which contained the balance of information required for a COL application, was received on 

10 March 14, 2008 and was accepted on June 3, 2008. On July 7, 2008, Constellation Generation 

11 Group, LLC withdrew as an applicant and Calvert Cliffs 3 Nuclear Project, LLC joined as an 

12 applicant. The application was supplemented by letters between June 2008 and September 

13 2009. Revision 6 of the application was submitted on September 30, 2009. The NRC staff’s 

14 review is based on Revision 6 of the application, the applicant’s responses to staff’s requests for 

15 additional information (RAI), and supplemental letters from the applicant. 

16 On May 16, 2008, UniStar submitted a joint Federal/State Application for the Alteration of Any 

17 Floodplain, Waterway, Tidal or Nontidal Wetland in Maryland to the U.S. Army Corps of 

18 Engineers (USACE or Corps) and the Maryland Department of the Environment (MDE). The 

19 Corps application number is NAB-2007-08123-M05 (Calvert Cliffs 3 Nuclear Project, 

20 LLC/UniStar Nuclear Operating Service, LLC), on behalf of co-applicants, Calvert Cliffs 3 

21 Nuclear Project, LLC and UniStar Nuclear Operating Services, LLC. The MDE Tidal Application 

22 number is Calvert Cliffs 3 Nuclear Project, LLC/200862371/08-WL-1462. The MDE Nontidal 

23 Application number is Calvert Cliffs 3 Nuclear Project, LLC/200862335/08-NT-0191. 

24 The proposed actions related to the Calvert Cliffs Unit 3 application are (1) NRC issuance of a 

25 COL for construction and operation of a new nuclear unit at the Calvert Cliffs site and (2) Corps 

26 permit action on a Department of the Army (DA) Individual Permit application pursuant to 

27 Section 404 of the Clean Water Act and Section 10 of the Rivers and Harbors Act of 1899. The 

28 U.S. Environmental Protection Agency (EPA) has the authority to review and veto Corps 

29 decisions of Section 404 permits. The Corps is participating with the NRC in preparing this 

30 environmental impact statement (EIS) as a cooperating agency and participates collaboratively 

31 on the review team. 

32 Section 102 of the National Environmental Policy Act of 1969, as amended (NEPA), directs that 

33 an EIS be prepared for major Federal actions that significantly affect the quality of the human 

34 environment. The NRC has implemented Section 102 of NEPA in Title 10 of the Code of 

35 Federal Regulations (CFR) Part 51. Further, in 10 CFR 51.20, the NRC has determined that the 

36 issuance of a COL under 10 CFR Part 52 is an action that requires an EIS. 
Draft NUREG-1936 xxx April 2010 

1 The purpose of UniStar’s requested NRC action is to obtain a COL to construct and operate a 

2 baseload nuclear power plant. This license is necessary but not sufficient by itself for 

3 construction and operation of the unit. A COL applicant must obtain and maintain the necessary 

4 permits from other Federal, State, and local agencies and permitting authorities. Therefore, the 

5 purpose of the NRC’s environmental review of the UniStar application is to determine the 

6 impacts on the human environment if one new nuclear power plant of the proposed U.S. EPR 

7 design is constructed and operated at the Calvert Cliffs site. The purpose of UniStar’s 

8 requested Corps action is to obtain a DA permit decision on the Individual Permit application to 

9 construct the proposed structures in and under navigable waters and to discharge dredged, 

10 excavated, and/or fill material into waters of the United States, including jurisdictional wetlands. 

11 Upon acceptance of the UniStar application, the NRC began the environmental review process 

12 described in 10 CFR Part 51 by publishing a Notice of Intent (73 FR 8719) to prepare an EIS 

13 and conduct scoping in the Federal Register (FR). On March 19, 2008, the NRC held two 

14 scoping meetings in Solomons, Maryland, to obtain public input on the scope of the 

15 environmental review. To gather information and to become familiar with the proposed and 

16 alternative sites and their environs, the NRC and its contractor, Pacific Northwest National 

17 Laboratory (PNNL), visited the Calvert Cliffs site in March 2008 and the alternative site, the 

18 former Thiokol brownfield site, in October 2008. The NRC, PNNL, and the Corps visited the 

19 alternative sites Eastalco and Bainbridge in August 2009. During the site visits, the NRC, 

20 PNNL, and Corps staff met with UniStar staff and public officials. During the scoping process, 

21 the NRC staff reviewed the comments received and contacted Federal, State, Tribal, regional, 

22 and local agencies to solicit comments. 

23 Included in this EIS are (1) the results of the joint NRC/Corps review team’s analyses, which 

24 consider and weigh the environmental effects of the NRC’s proposed action (i.e., issuance of 

25 the COL) and of constructing and operating a new nuclear unit at the Calvert Cliffs site; (2) 

26 mitigation measures for reducing or avoiding adverse effects; (3) the environmental impacts of 

27 alternatives to the proposed action; and (4) the staff’s recommendation regarding the proposed 

28 action. 

29 To guide its assessment of the environmental impacts of a proposed action or alternative 

30 actions, the NRC has established a standard of significance for impacts based on Council on 

31 Environmental Quality (CEQ) guidance. Table B-1 of 10 CFR Part 51, Subpart A, Appendix B, 

32 provides the following definitions of the three significance levels – SMALL, MODERATE, and 

33 LARGE: 

34 SMALL – Environmental effects are not detectable or are so minor that they will 

35 neither destabilize nor noticeably alter any important attribute of the resource. 
April 2010 xxxi Draft NUREG-1936 

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

2 destabilize, important attributes of the resource. 

3 LARGE – Environmental effects are clearly noticeable and sufficient to 

4 destabilize important attributes of the resource. 

5 Potential mitigation measures were considered for each resource category and are discussed in 

6 the appropriate sections of the EIS. 

7 In preparing this EIS, the review team reviewed the applications, including the ER submitted by 

8 UniStar; consulted with Federal, State, Tribal, and local agencies; and followed the guidance set 

9 forth in NUREG-1555, Environmental Standard Review Plan (ESRP). In addition, the review 

10 team considered the public comments related to the environmental review received during the 

11 scoping process. Comments within the scope of the environmental review are included in 

12 Appendix D of this EIS. 

13 The NRC staff’s preliminary recommendation to the Commission related to the environmental 

14 aspects of the proposed action is that the COL be issued as requested. This recommendation 

15 is based on (1) the application, including the ER submitted by UniStar and the applicant’s 

16 supplemental letters and responses to staff’s RAIs; (2) consultation with Federal, State, Tribal, 

17 and local agencies; (3) the staff’s independent review; (4) the staff’s consideration of comments 

18 related to the environmental review that were received during the scoping process; and (5) the 

19 assessments summarized in this EIS, including the potential mitigation measures identified in 

20 the ER. The Corps will base its evaluation of the DA Individual Permit application on the 

21 requirements of Corps regulations, the Clean Water Act Section 404(b)(1) Guidelines, and the 

22 Corps public interest review (PIR) process. The Corps permit decision will be made following 

23 issuance of the final EIS. 

24 A 75-day comment period will begin on the date of publication of the EPA Notice of Availability 

25 of the filing of the draft EIS to allow members of the public to comment on the results of the 

26 NRC and Corps staffs’ review. During this period, the NRC and Corps staff will conduct a public 

27 meeting near the Calvert Cliffs site to describe the results of the environmental review, provide 

28 members of the public with information to assist them in formulating comments on this EIS, 

29 respond to questions, and accept public comment. The public meeting also serves as the 

30 Corps public hearing, which means a public proceeding conducted for the purpose of acquiring 

31 information or evidence that will be considered in evaluating a proposed DA permit action and 

32 affords the public an opportunity to present their views, opinions, and information on such permit 

33 actions or Federal projects. After the comment period, the review team will consider all the 

34 comments received. The final EIS will include these comments and the review team responses. 

35 The NRC staff’s evaluation of the site safety and emergency preparedness aspects of the 

36 proposed action will be addressed in the NRC’s final Safety Evaluation Report (SER), currently 
Draft NUREG-1936 xxxii April 2010 

1 anticipated to be published in July 2012. The reactor specified in the application is the AREVA 

2 NP Inc.’s U.S. EPR design, which is currently undergoing a design certification review. The 

3 NRC staff’s evaluation of the design certification and final rulemaking is currently anticipated to 

4 be completed in June 2012. 
April 2010 xxxiii Draft NUREG-1936 

1 Abbreviations/Acronyms 

2 χ/Q dispersion values 

3 °C degree(s) Celsius 

4 °F degree(s) Fahrenheit 

5 ac acre(s) 

6 ADAMS Agencywide Documents Access and Management System 

7 AEC U.S. Atomic Energy Commission 

8 ALARA as low as reasonably achievable 

9 ANC acid neutralizing capacity 

10 ANSI American National Standards Institute 

11 APE Area of Potential Effects 

12 AREVA AREVA NP Inc. 

13 AQCR Air Quality Control Region 

14 B&O Baltimore and Ohio 

15 BA biological assessment 

16 BACT best available control technology 

17 BEA U.S. Department of Commerce Bureau of Economic Analysis 

18 BEIR Biological Effects of Ionizing Radiation 

19 BGE Baltimore Gas and Electric Company 

20 B-IBI Benthic Index of Biotic Integrity 

21 BMP best management practice(s) 

22 Bq becquerels 

23 BRAC base realignment and closure 

24 Btu British thermal unit 

25 C&O Chesapeake and Ohio 

26 CAC Critical Area Commission 

27 CAES compressed air energy storage 

28 CBCA Chesapeake Bay Critical Area 

29 CBP Chesapeake Bay Program 

30 CCNPP Calvert Cliffs Nuclear Power Plant 

31 CCPS Calvert County Public Schools 

32 CCWS component cooling water system 

33 CDC Centers for Disease Control and Prevention 

34 CDF core damage frequency 

35 CEQ Council on Environmental Quality 

36 CFR Code of Federal Regulations 
Draft NUREG-1936 xxxiv April 2010 

1 cfs cubic feet per second (water flow) 

2 Ci curies 

3 cm centimeters 

4 CMH Calvert Memorial Hospital 

5 CO carbon monoxide 

6 CO2 carbon dioxide 

7 COL combined license 

8 COMAR Code of Maryland Regulations 

9 Constellation Constellation Energy Nuclear Group, LLC 

10 Corps U.S. Army Corps of Engineers (also USACE) 

11 CPCN Certificate of Public Convenience and Necessity 

12 CWMA Cooperative Wildlife Management Area 

13 CWP Center for Watershed Protection 

14 CWS circulating water supply system 

15 CZMA Coastal Zone Management Act 

16 d day 

17 D/Q deposition values 

18 DA Department of the Army 

19 dB decibel(s) 

20 dBA decibel(s) (acoustic) 

21 DBA design basis accidents 

22 DC District of Columbia 

23 DE Delaware 

24 DECOM decommissioning 

25 DO dissolved oxygen 

26 DOE U.S. Department of Energy 

27 DOT U.S. Department of Transportation 

28 DPS distinct population segments 

29 D/Q deposition values 

30 EAB exclusion area boundary 

31 EDG emergency diesel generators 

32 EFH essential fish habitat 

33 EIA Department of Energy’s Energy Information Administration 

34 EIS environmental impact statement 

35 ELF extremely low frequency 

36 EMF electromagnetic field(s) 

37 EMS Emergency Medical Services 

38 EO Executive Order 

39 EPA U.S. Environmental Protection Agency 
April 2010 xxxv Draft NUREG-1936 

1 EPR Evolutionary Power Reactor 

2 EPRI Electric Power Research Institute 

3 EPT Ephemeroptera-Plecoptera-Trichoptera 

4 EPZ emergency planning zone 

5 ER Environmental Report 

6 ESA U.S. Endangered Species Act of 1973, as amended 

7 ESP Energy Storage and Power LLC 

8 ESRP Environmental Standard Review Plan

9 ESWS essential service water system 

10 FAA Federal Aviation Administration 

11 FEMA Federal Emergency Management Agency 

12 FERC Federal Energy Regulatory Commission 

13 FHWG Fisheries Hydroacoustic Working Group 

14 FIDS forest interior dwelling species 

15 fps feet per second 

16 FONSI finding of no significant impact 

17 FR Federal Register

18 FSAR Final Safety Analysis Report 

19 ft foot/feet 

ft2 20 square feet 

ft3 21 cubic feet 

22 FTE full-time equivalent 

23 FWS U.S. Fish and Wildlife Service 

24 FY fiscal year 

25 g gram(s) 

26 GAI GAI Consultants, Inc. 

27 gal gallon(s) 

28 GBq gigabecquerel 

29 GC gas centrifuge 

30 GCC global climate change 

31 GD gaseous diffusion 

32 GEIS generic environmental impact statement 

33 GHG greenhouse gas 

34 GI-LLI adult lower intestine 

35 GIS geographical information system 

36 GIT Georgia Institute of Technology 

37 gpd gallon(s) per day 

38 gpm gallon(s) per minute 

39 
Draft NUREG-1936 xxxvi April 2010 

1 ha hectare(s) 

2 HAP hazardous air pollutants 

3 HAPC habitat areas of particular concern 

4 HLW high level waste 

5 HQUSACE Headquarters, U.S. Army Corps of Engineers 

6 hr hour 

7 Hz hertz 

8 IAEA International Atomic Energy Agency 

9 ICRP International Commission on Radiological Protection 

10 IDAs Intensely Developed Areas 

11 IGCC integrated gasification combined cycle 

12 in. inch(es) 

13 INEEL Idaho National Engineering and Environmental Laboratory 

14 IRSA interim resin storage area 

15 ISFSI independent spent fuel storage installation 

16 Kcal kilocalorie 

17 kg kilogram 

18 km kilometer(s) 

km2 19 square kilometer(s) 

20 kV kilovolt(s) 

21 kW(e) kilowatts electric 

22 kWh kilowatt hour(s) 

23 L liter(s) 

24 lb pound(s) 

25 LDAs Limited Development Areas 

26 LEAs Local Educational Agencies 

27 LEDPA least environmentally damaging practicable alternative 

28 LFAA Low Flow Allocation Agreement 

29 LLW low-level waste 

30 LNG liquefied natural gas 

31 LOS level of service 

32 LPZ low population zone 

33 LR license renewal 

34 LRF large release frequencies 

35 LWR light-water reactor 

36 m meter(s) 

m2 37 square meter 

m3 38 cubic meter(s) 
April 2010 xxxvii Draft NUREG-1936 

1 mA milliamperes 

2 MACCS2 MELCOR Accident Consequence Code System 

3 MAPP Mid-Atlantic Power Pathway 

4 MBq million becquerels 

5 mCi millicuries 

6 MBTA Migratory Bird Treaty Act 

7 MD Maryland 

8 MBSS Maryland Biological Stream Survey 

9 MDE Maryland Department of the Environment 

10 MDNR Maryland Department of Natural Resources 

11 MDOT Maryland Department of Transportation 

12 MDP Maryland Department of Planning 

13 MDSDAT Maryland State Department of Assessments and Taxation 

14 MEA Maryland Energy Administration 

15 MEI maximally exposed individual 

16 mg milligram(s) 

17 MGD million gallon(s) per day 

18 mGy milligray 

19 MHT Maryland Historical Trust 

20 MHW mean high water 

21 mi mile(s) 

mi2 22 square mile(s) 

23 MISO Midwest Independent Transmission System Operator, Inc. 

24 MIT Massachusetts Institute of Technology 

25 mL millilitres 

26 mm millimetres 

27 MMS Minerals Management Service 

28 mo month 

29 MOA memorandum of agreement 

30 MOU memorandum of understanding 

31 mph mile(s) per hour 

32 MPSC Maryland Public Service Commission 

33 mR milliroentgen 

34 mrad millirad(s) 

35 mrem millirem(s) 

36 MSA Metropolitan Statistical Area 

37 MSFCMA Magnuson-Stevens Fishery Conservation and Management Act of 1976 

38 MSL mean sea level 

39 mSv millisievert(s) 

40 MSX Multinucleate Sphere X 

41 MT metric ton(s) (or tonne[s]) 
Draft NUREG-1936 xxxviii April 2010 

1 MTU metric ton of uranium 

2 MVA motor vehicle accidents 

3 MW megawatt(s) 

4 MW(e) megawatt(s) electric 

5 MW(t) megawatt(s) thermal 

6 MWd megawatt-day(s) 

7 MWh megawatt hour(s) 

8 NA Not Applicable 

9 NAGPRA Native American Graves Protection & Repatriation Act 

10 NA-NSR Nonattainment New Source Review 

11 NCES National Center for Education Statistics 

12 NCI National Cancer Institute 

13 NCRP National Council on Radiation Protection and Measurements 

14 NEPA National Environmental Policy Act of 1969, as amended 

15 NERC North American Electric Reliability Corporation 

16 NESC National Electric Safety Code 

17 NETL National Energy Technology Laboratory 

18 NHPA National Historic Preservation Act of 1966, as amended 

19 NIEHS National Institute of Environmental Health Sciences 

20 NIST National Institute of Standards and Technology 

21 NMFS National Marine Fisheries Service 

22 NO2 nitrogen dioxide 

23 NOAA National Oceanic and Atmospheric Administration

24 NOB Natural Oyster Bar 

25 NOx nitrogen oxide(s) 

26 NPCC Northeast Power Coordinating Council 

27 NPDES National Pollutant Discharge Elimination System 

28 NPS National Park Service 

29 NRC U.S. Nuclear Regulatory Commission 

30 NRHP National Register of Historic Places 

31 NUREG NRC publication 

32 NYSDEC New York State Department of Environmental Conservation 

33 ODCM Offsite Dose Calculation Manual 

34 OSHA Occupational Safety and Health Administration 

35 Pa pascal 

36 PATH Potomac-Appalachian Transmission Highline Project 

37 PCB polychlorinated biphenyls 

38 pCi picocuries 
April 2010 xxxix Draft NUREG-1936 

1 PDCC Port Deposit Chamber of Commerce 

2 PIR public interest review 

3 P-IBI phytoplankton index of biotic integrity 

4 PJM PJM Interconnection, LLC 

5 PM particulate matter 

6 PM10 particulate matter with a diameter of 10 microns or less 

7 PM2.5 particulate matter with a diameter of 2.5 microns or less 

8 PNNL Pacific Northwest National Laboratory 

9 PPRP Power Plant Research Program 

10 ppt parts per thousand 

11 PRA probabilistic risk assessment 

12 PSD prevention of significant deterioration 

13 PWR pressurized water reactor(s) 

14 rad radiation absorbed dose 

15 RAI Request for Additional Information 

16 RCAs resource conservation areas 

17 RCP reinforced concrete pipe 

18 RCRA Resource Conservation and Recovery Act of 1976, as amended 

19 RCS reactor coolant system 

20 rem Roentgen equivalent man (a special unit of radiation dose) 

21 REMP radiological environmental monitoring program 

22 RFC ReliabilityFirst Corporation 

23 RIMS Regional Input-Output Multiplier System 

24 ROD Record of Decision 

25 ROI region of interest 

26 ROW rights-of-way 

27 RSICC Radiation Safety Information Computational Center 

28 Ryr reactor year 

29 s second(s) 

30 SAMA severe accident mitigation alternative 

31 SAMDA severe accident mitigation design alternative 

32 SAV submerged aquatic vegetation 

33 SBO station blackout 

34 SCR selective catalytic reduction 

35 SEL sound exposure level 

36 SER Safety Evaluation Report 

37 SERC SERC Reliability Corporation 

38 SHA State Highway Administration 

39 SHPO State Historic Preservation Office 
Draft NUREG-1936 xl April 2010 

1 SMCMC St. Mary’s County Metropolitan Commission 

2 SNE-MA Southern New England/Middle Atlantic 

3 SO2 sulfur dioxide 

4 SOx sulfur oxide(s) 

5 SPCC Spill Prevention Control and Countermeasures 

6 SSC structures, systems, or components 

7 Sv sievert(s) 

8 SWPPP Stormwater Pollution Prevention Plan 

9 TAP toxic air pollutant(s) 

10 TBq tera becquerel(s) 

11 TDS total dissolved solids 

12 TEDE total effective dose equivalent 

13 TIA Traffic Impact Analysis 

14 TLD thermoluminescent dosimeter(s) 

15 TOC total organic carbon 

16 TRU Transuranic waste 

17 TSP total suspended particulates 

18 U.S. United States 

19 U.S. EPR U.S. Evolutionary Power Reactor 

20 U3O8 triuranium octaoxide (“yellowcake”) 

21 UHS ultimate heat sink 

22 UMTRI University of Michigan Transportation Research Institute 

23 UniStar UniStar Nuclear Operating Services, LLC and Calvert Cliffs 3 Nuclear 

24 Project, LLC (collective applicant) 

25 UO2 uranium(IV) oxide 

26 USACE U.S. Army Corps of Engineers (also Corps) 

27 USBLS United States Bureau of Labor Statistics 

28 U.S.C. United States Code 

29 USCB U.S. Census Bureau 

30 USDA U.S. Department of Agriculture 

31 USGS U.S. Geological Survey 

32 VA Virginia 

33 VIMS Virginia Institute of Marine Science 

34 VOC volatile organic compound(s) 

35 WHO World Health Organization 

36 WNA World Nuclear Association 

37 WV West Virginia 
April 2010 xli Draft NUREG-1936 

1 yd yard 

yd3 2 cubic yards 

3 yr year(s) 

Appendix A 

Contributors to the Environmental Impact Statement 

April 2010 A-1 Draft NUREG-1936 

Appendix A 

Contributors to the Environmental Impact Statement 

1 The overall responsibility for the preparation of this environmental impact statement was 

2 assigned to the Office of New Reactors, U.S. Nuclear Regulatory Commission (NRC). The 

3 U.S. Army Corps of Engineers (Corps) is participating as a cooperating agency. The statement 

4 was prepared by members of the Office of New Reactors with assistance from other NRC 

5 organizations, the Corps, and Pacific Northwest National Laboratory. 

6 

Name Affiliation Function or Expertise

NUCLEAR REGULATORY COMMISSION

Laura Quinn Office of New Reactors Project Manager 

Stacey Imboden Office of New Reactors Project Manager 

Alicia Williamson Office of New Reactors Project Manager 

Thomas Fredrichs Office of New Reactors Project Manager 

Robert Schaaf Office of New Reactors Environmental Projects Branch Chief 

Andrew Kugler Office of New Reactors Alternatives 

Jack Cushing Office of New Reactors Cultural Resources 

Irene Yu Office of New Reactors Alternatives/Historical/Cultural Resources 

Joe Hoch Office of New Reactors Meteorology 

Mike Mazaika Office of New Reactors Meteorology 

David Brown Office of New Reactors Meteorology 

Richard Raione Office of New Reactors Hydrology Branch Chief 

Henry Jones Office of New Reactors Hydrology 

Nebiyu Tiruneh Office of New Reactors Hydrology 

Jill Caverly Office of New Reactors Hydrology 

Alice Stieve Office of New Reactors Geology 

Richard Emch Office of New Reactors Radiation Impacts/Health Physics 

Jean-Claude Dehmel Office of New Reactors Radiation Impacts/Health Physics 

Michelle Hart Office of New Reactors Accidents 

Jay Lee Office of New Reactors Accidents 

Harriet Nash Office of New Reactors Aquatic/Terrestrial Ecology/Land Use 

Daniel Mussatti Office of New Reactors Socioeconomics/Benefit-Cost/Need for Power/Environmental 

Justice 

Seshagira Tammara Office of New Reactors Demographics 

Sara Bernal Office of New Reactors Construction Worker Dose 

Ed Fuller Office of New Reactors PRA & SAMA 

Jessie Muir Office of New Reactors Nonradioactive Waste 

Michelle Moser Office of New Reactors Cumulative Impacts 

Norma Garcia-Santos Office of Nuclear Material Safety and 

Safeguards 

Transportation 
Appendix A 

Draft NUREG-1936 A-2 April 2010 

Name Affiliation Function or Expertise

John Cook Office of Nuclear Material Safety and 

Safeguards 

Transportation 

Lucieann Vechioli Office of Nuclear Material Safety and 

Safeguards 

Transportation 

James Shepherd Office of Federal and State Materials and 

Environmental Management Programs 

Decommissioning 

Jennifer Davis Office of Federal and State Materials and 

Environmental Management Programs 

Cultural Resources 

Stan Echols Office of Nuclear Material Safety and 

Safeguards 

Fuel Cycle 

US ARMY CORPS OF ENGINEERS

Kathy Anderson Baltimore District, Operations Division, 

Regulatory Branch 

Project Manager/Biologist 

Woody Francis Baltimore District, Operations Division, 

Regulatory Branch 

Project Manager/Biologist 

PACIFIC NORTHWEST NATIONAL LABORATORY(a)

Mary Ann Parkhurst Task Leader/Site Selection Alternatives 

Elaine Chapman Deputy Task Leader 

Robin Durham Deputy Task Leader 

Michael Fayer Hydrology and Geology 

Lance Vail Hydrology/System Alternatives 

Corey Duberstein Terrestrial Ecology 

Roy Kropp Aquatic Ecology 

Michelle Niemeyer Socioeconomics/Environmental Justice/Benefit-Cost 

Tom Secrest Socioeconomics and Environmental Justice 

Tara O’Neil Historic and Cultural Resources 

J.V. Ramsdell, Jr. Meteorology and Air Quality/Accidents 

Philip Daling Transportation 

Lissa Staven Radiation Protection/Health Physics/Decommissioning 

Paul Hendrickson Land Use/Need for Power/Energy Alternatives 

David Payson Technical Editing 

Charity Plata Technical Editing 

Mike Parker Text Processing 

Christine Ross Text Processing 

Sharon Johnson References 

Tomiann Parker References 

Donna Austin-Workman Graphics 

AMEC EARTH & ENVIRONMENTAL, INC. 

Michael French Cultural Resources 

(a) Pacific Northwest National Laboratory is operated by Battelle for the U.S. Department of Energy.

1 
Appendix B 

Organizations Contacted

April 2010 B-1 Draft NUREG-1936 

Appendix B 

Organizations Contacted 

1 The following Federal, State, regional, Tribal, and local organizations were contacted during the 

2 course of the U.S. Nuclear Regulatory Commission (NRC) staff’s and the U.S. Army Corps of 

3 Engineers (Corps) independent review of potential environmental impacts from the construction 

4 and operation of one new nuclear unit (Unit 3) at the Calvert Cliffs site in Calvert County, 

5 Maryland: 

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

7 Alcoa, Inc., Frederick, Maryland 

8 Bainbridge Development Corp, Port Deposit, Maryland 

9 Calvert County Department of Community Resources, Prince Frederick, Maryland 

10 Calvert County Department of Economic Development, Prince Frederick, Maryland 

11 Calvert County Department of Finance and Budget, Prince Frederick, Maryland 

12 Calvert County Department of Planning and Zoning, Prince Frederick, Maryland 

13 Calvert County Department of Public Safety, Prince Frederick, Maryland 

14 Calvert County Department of Public Works, Prince Frederick, Maryland 

15 Calvert County Emergency Management Office, Prince Frederick, Maryland 

16 Calvert County Housing Authority, Prince Frederick, Maryland 

17 Calvert County Minority Business Alliance, Huntingtown, Maryland 

18 Calvert County Sheriff’s Department, Prince Frederick, Maryland 

19 Cedarville Band of Piscataway Indians, Inc., Waldorf, Maryland 

20 Commission on African History and Culture, Annapolis, Maryland 

21 Maryland Department of the Environment, Baltimore, Maryland 
Appendix B 

Draft NUREG-1936 B-2 April 2010 

1 Maryland Department of Natural Resources, Annapolis, Maryland 

2 Maryland Department of Transportation, Hanover, Maryland 

3 Maryland Emergency Management Agency, Reisterstown, Maryland 

4 Maryland Historical Trust, Crownsville, Maryland 

5 National Marine Fisheries Service, Annapolis, Maryland 

6 National Marine Fisheries Service, Gloucester, Massachusetts 

7 National Park Service, Washington, DC 

8 New York State Department of Environmental Conservation, Bureau of Habitat, Albany, 

9 New York 

10 Pennsylvania Fish and Boat Commission, Harrisburg, Pennsylvania 

11 Pennsylvania Game Commission, Harrisburg, Pennsylvania 

12 Piscataway Conoy Confederacy and Subtribes, Inc., La Plata, Maryland 

13 Piscataway Indian Nation, Accokeek, Maryland 

14 St. Mary’s County Department of Economic & Community Development, Leonardtown, 

15 Maryland 

16 St. Mary’s County Department of Land Use & Growth Management, Leonardtown, Maryland 

17 St. Mary’s County Department of Social Services, Leonardtown, Maryland 

18 Susquehanna River Basin Commission, Harrisburg, Pennsylvania 

19 United Association of Journeymen and Apprentices of the Plumbing and Pipe Fitting Industry of 

20 the United States and Canada, Road Sprinkler Fitters Local Union 669, Columbia, Maryland 

21 United States Fish and Wildlife Service, Annapolis, Maryland 

22 United Way of Calvert County, Prince Frederick, Maryland 

23 Virginia Department of Game and Inland Fisheries, Richmond, Virginia 

24 Virginia Marine Resources Commission, Newport News, Virginia 
Appendix B 

April 2010 B-3 Draft NUREG-1936 

1 The following Federal, State, regional, Tribal, and local organizations were sent the U.S. Army 

2 Corps of Engineers public notice dated September 3, 2008, which solicited comments from the 

3 public; Federal, State, and local agencies and officials; Indian Tribes; and other interested 

4 parties in order to consider and evaluate the proposed construction of one new nuclear unit 

5 (Unit 3) at the Calvert Cliffs site in Calvert County, Maryland: 

6 Anne Arundel County, Maryland 

7 Audubon Naturalist Society 

8 Baltimore County, Maryland 

9 Baltimore County Public Schools, Maryland 

10 Blair County Conservation District, Pennsylvania 

11 Calvert County, Maryland 

12 Campaign to Reinvest in Oxon Hill 

13 Carroll Citizens 

14 Carroll County, Maryland 

15 Charles County, Maryland 

16 Chesapeake Bay Foundation 

17 Citizens to Save South Valley Park and Whetstone Run, Maryland 

18 City of Alexandria, Virginia 

19 City of Baltimore, Maryland 

20 City of Greenbelt, Maryland 

21 City of Rockville, Maryland 

22 City of Sunbury, Pennsylvania 

23 College of Southern Maryland 

24 Conservancy for Charles County, Inc. 
Appendix B 

Draft NUREG-1936 B-4 April 2010 

1 Earth Conservation Corps 

2 Fairfax County, Virginia 

3 Fairfax County Water Authority, Virginia 

4 Federal Highway Administration 

5 Garrett County, Maryland 

6 Georgetown University Law Center 

7 Government of the Commonwealth of Pennsylvania 

8 Government of the District of Columbia 

9 Government of the State of Delaware 

10 Government of the State of Maryland 

11 Harford County, Maryland 

12 Herring Run Watershed Association, Baltimore, Maryland 

13 Historic Preservation Trust of Lancaster County, Pennsylvania 

14 Huntington Township, Pennsylvania 

15 Kent County, Maryland 

16 Luzerne Conservation District 

17 Manheim Township, Lancaster County, Pennsylvania 

18 Mattawoman Watershed Society, Inc. 

19 Maryland Association of Soil Conservation Districts, Inc. 

20 Maryland Bass Federation 

21 Maryland Coastal Bays Program 

22 Maryland Department of Business and Economic Development 
Appendix B 

April 2010 B-5 Draft NUREG-1936 

1 Maryland Department of the Environment 

2 Maryland Department of Health and Mental Hygiene 

3 Maryland Department of Natural Resources 

4 Maryland Department of Planning 

5 Maryland Department of Transportation 

6 Maryland Military Department 

7 Maryland National Capital Building Industry Association 

8 Montgomery County Sierra Club, Maryland 

9 National Oceanic and Atmospheric Administration 

10 National Park Service 

11 National Trust for Historic Preservation 

12 Naval Research Laboratory 

13 Nuclear Regulatory Commission 

14 Organization of American States 

15 Pennsylvania Association of Soil Conservation Districts, Inc. 

16 Prince George’s County Planning Department, Maryland 

17 Queen Anne’s County, Maryland 

18 Saint Mary’s County, Maryland 

19 Somerset County, Maryland 

20 Southern Maryland Electric Cooperative 

21 Sparrows Point Action, Maryland 

22 Talbot County, Maryland 
Appendix B 

Draft NUREG-1936 B-6 April 2010 

1 Tri-County Regional Planning Commission, Harrisburg, Pennsylvania 

2 United States Coast Guard 

3 United States Department of Agriculture 

4 United States Department of Energy 

5 United States Department of Housing and Urban Development 

6 United States Department of Transportation 

7 United States Environmental Protection Agency 

8 United States Fish and Wildlife Service 

9 University of Maryland 

10 University of Maryland Center for Environmental Science 

11 Virginia Department of Conservation and Recreation 

12 Virginia Department of Environmental Quality 

13 Virginia Institute of Marine Science 

14 Washington County, Maryland 

15 West Shore Community Association, Maryland 
Appendix C 

Chronology of NRC and Corps 

Environmental Review Correspondence 

April 2010 C-1 Draft NUREG-1936

Appendix C 

Chronology of NRC and Corps 

Environmental Review Correspondence 

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

2 Regulatory Commission (NRC) and UniStar, and other correspondence related to the NRC 

3 staff’s environmental review, under Title 10 of the Code of Federal Regulations (CFR) Part 51, 

4 for a Combined License (COL) application for the Calvert Cliffs Nuclear Power Plant (CCNPP) 

5 near Lusby, Maryland. This application was submitted by UniStar Nuclear Development, LLC 

6 on behalf of Calvert Cliffs 3 Nuclear Project, LLC and UniStar Nuclear Operating Services, LLC 

7 (collectively referred to as UniStar). The appendix also includes correspondence between the 

8 U.S. Army Corps of Engineers (USACE or Corps) and UniStar relating to UniStar’s request for a 

9 Department of the Army permit for wetland and shoreline development. 

10 All documents, with the exception of those containing proprietary information, are available 

11 through the Commission’s Public Document Room, at One White Flint North, 11555 Rockville 

12 Pike (first floor), Rockville, MD, and are available electronically from the Public Electronic 

13 Reading Room found on the Internet at the following web address: http://www.nrc.gov/reading14 rm.html. From this site, the public can gain access to the NRC's Agencywide Document Access 

15 and Management System (ADAMS), which provides text and image files of NRC's public 

16 documents in the component of ADAMS. The ADAMS accession numbers for each document 

17 are included below. 

18 July 13, 2007 Letter from Mr. R.M. Krich, UniStar, to NRC transmitting application for 

19 Combined License for the Calvert Cliffs Nuclear Power Plant 

20 (Accession No. ML071980294). 

21 August 15, 2007 Federal Register Notice of Receipt and Availability of the partial COL 

22 application for Calvert Cliffs Nuclear Power Plant (72 FR 45832). 

23 December 14, 2007 Letter from Mr. R. M. Krich to NRC transmitting revision 1 of the 

24 application for a Combined License for the Calvert Cliffs Nuclear Power 

25 Plant (Accession No. ML073520191). 

26 January 25, 2008 Letter from Mr. David B. Matthews, NRC, to Mr. R.M. Krich, UniStar, 

27 accepting and docketing the partial COL application for Calvert Cliffs 

28 Nuclear Power Plant (Accession No. ML080160547). 
Appendix C 

Draft NUREG-1936 C-2 April 2010

1 January 25, 2008 Press Release No. 08-013: NRC Accepts Partial Application for New 

2 Reactor at Calvert Cliffs (Accession No. ML080250401). 

3 January 31, 2008 Federal Register Notice of Acceptance for Part 1 of the COL application 

4 for Calvert Cliffs Nuclear Power Plant (73 FR 5877). 

5 February 5, 2008 Letter from Mr. Thomas Fredrichs, NRC, to Mr. Robert Gatton, Calvert 

6 Library Southern Branch, regarding maintenance of reference materials 

7 for the environmental review of the Calvert Cliffs Nuclear Power Plant 

8 combined license application (Accession No. ML080290168). 

9 February 5, 2008 Letter from Mr. Thomas Fredrichs, NRC, to Ms. Pamela Perrygo, Calvert 

10 Library Prince Frederick, regarding maintenance of reference materials 

11 for the environmental review of the Calvert Cliffs Nuclear Power Plant 

12 combined license application (Accession No. ML080290195). 

13 February 7, 2008 Letter from Mr. James E. Lyons, NRC, to Mr. John E. Price, UniStar, 

14 transmitting Notice of Intent to Prepare an Environmental Impact 

15 Statement and Conduct Scoping Related to a Combined License for 

16 Calvert Cliffs Nuclear Power Plant (Accession No. ML080390115). 

17 February 14, 2008 Federal Register Notice of Intent to Prepare an Environmental Impact 

18 Statement and Conduct Scoping Process for the partial Calvert Cliffs 

19 Nuclear Power Plant Combined License Application (73 FR 8719). 

20 February 15, 2008 Telecom Summary between the NRC and Maryland Historic Trust 

21 (Accession No. ML091350331). 

22 February 20, 2008 Telecom Summary between the NRC and Maryland Historic Trust 

23 (Accession No. ML080730294). 

24 February 28, 2008 Press Release No. 08-039: NRC Meeting with Public March 19 on 

25 Environmental Issues for Calvert Cliffs New Reactor Application 

26 (Accession No. ML080590136). 

27 February 29, 2008 Letter from Mr. Richard Raione, NRC, to Mr. Don Klima, Advisory Council 

28 on Historic Preservation, regarding request for participation in the scoping 

29 process for the Calvert Cliffs Nuclear Power Plant combined license 

30 application review (Accession No. ML080430649). 
 Appendix C 

April 2010 C-3 Draft NUREG-1936

1 February 29, 2008 Letter from Mr. Richard Raione, NRC, to Ms. Patricia Kurkul, NOAA 

2 National Marine Fisheries Service, regarding request for participation in 

3 environmental scoping process and a list of protected species within the 

4 area under evaluation for the Calvert Cliffs Nuclear Power Plant 

5 combined license application review (Accession No. ML080370414). 

6 February 29, 2008 Letter from Mr. Richard Raione, NRC, to Mr. J. Rodney Little, Director 

7 and State Historic Preservation Officer, regarding request for participation 

8 in the scoping process for the Calvert Cliffs Nuclear Power Plant 

9 combined license application review (Accession No. ML080430656). 

10 February 29, 2008 Letter from Mr. Richard Raione, NRC, to Mr. Dan Murphy, U.S. Fish and 

11 Wildlife Service, regarding request for participation in the environmental 

12 scoping process and a list of protected species within the area under 

13 evaluation for the Calvert Cliffs Nuclear Power Plant combined license 

14 application review (Accession No. ML080390482). 

15 March 3, 2008 Letter from Mr. Richard Raione, NRC, to Mr. Douglas J. Austin, 

16 Pennsylvania Fish and Boat Commission, regarding request for 

17 participation in the scoping process for the Calvert Cliffs Nuclear Power 

18 Plant combined license application review (Accession No. 

19 ML080520182). 

20 March 3, 2008 Letter from Mr. Richard Raione, NRC, to The Honorable Natalie Proctor, 

21 Cedarville Band of Piscataway Indians, Inc., regarding request for 

22 participation in the scoping process for the Calvert Cliffs Nuclear Power 

23 Plant combined license application review (Accession No. 

24 ML080570335). 

25 March 5, 2008 Letter from Mr. Richard Raione, NRC, to Mr. Steven G. Bowman, Virginia 

26 Marine Resources Commission, regarding request for participation in the 

27 scoping process for the Calvert Cliffs Nuclear Power Plant combined 

28 license application review (Accession No. ML080520160). 

29 March 5, 2008 Letter from Mr. Richard Raione, NRC, to Mr. Robert W. Duncan, Virginia 

30 Department of Game and Inland Fisheries, regarding request for 

31 participation in the scoping process for the Calvert Cliffs Nuclear Power 

32 Plant combined license application review (Accession No. 

33 ML080520092). 
Appendix C 

Draft NUREG-1936 C-4 April 2010

1 March 5, 2008 Letter from Mr. Richard Raione, NRC, to Mr. John R. Griffin, Maryland 

2 Department of Natural Resources, regarding request for participation in 

3 the scoping process for the Calvert Cliffs Nuclear Power Plant combined 

4 license application review (Accession No. ML080450160). 

5 March 5, 2008 Letter from Mr. Richard Raione, NRC, to Ms. Tonya Hardy, Commission 

6 on African History and Culture, regarding request for participation in the 

7 scoping process for the environmental review of the Calvert Cliffs Nuclear 

8 Power Plant combined license application (Accession No. 

9 ML080570370). 

10 March 5, 2008 Letter from Mr. Richard Raione, NRC, to Mr. Carl Roe, Pennsylvania 

11 Game Commission, regarding request for participation in the scoping 

12 process for the environmental review of the Calvert Cliffs Nuclear Power 

13 Plant combined license application (Accession No. ML080520172). 

14 March 5, 2008 Letter from Mr. Richard Raione, NRC, to The Honorable Mervin Savory, 

15 Piscataway Conoy Confederacy and Subtribes, regarding request for 

16 participation in the scoping process for the environmental review of the 

17 Calvert Cliffs Nuclear Power Plant combined license application 

18 (Accession No. ML080510408). 

19 March 5, 2008 Letter from Mr. Richard Raione, NRC, to The Honorable William “Red 

20 Wing” Tayac, Piscataway Indian Nation, regarding request for 

21 participation in the scoping process for the environmental review of the 

22 Calvert Cliffs Nuclear Power Plant combined license application 

23 (Accession No. ML080570294). 

24 March 5, 2008 Memo from Mr. Thomas Fredrichs, NRC, to Mr. Richard Raione, NRC, 

25 transmitting the Meeting Notice of Public Meeting to Discuss 

26 Environmental Scoping Process for the Calvert Cliffs Nuclear Power Plant 

27 Combined License Application (Accession No. ML080460479). 

28 March 14, 2008 Letter from Mr. George Vanderheyden, UniStar, to NRC transmitting 

29 Revision 2 of the partial combined license application for Calvert Cliffs 

30 Nuclear Power Plant (Accession No. ML080990114). 

31 April 3, 2008 Press Release No. 08-071: Corrected Scoping Comment End Date for 

32 Calvert Cliffs New Reactor Application (Accession No. ML080940321). 
 Appendix C 

April 2010 C-5 Draft NUREG-1936

1 April 11, 2008 Letter from Ms. Margaret E. Gaffney-Smith, U.S. Army Corps of 

2 Engineers, to NRC regarding cooperating status on the Calvert Cliffs 

3 Nuclear Power Plant Environmental Impact Statement (Accession No. 

4 ML081130278). 

5 April 16, 2008 Letter from Ms. Susan T. Gray, Maryland Department of Natural 

6 Resources, to NRC regarding the environmental review of the Calvert 

7 Cliffs Nuclear Power Plant combined license application (Accession No. 

8 ML081130284). 

9 April 18, 2008 Press Release No. 08-079: Complete Calvert Cliffs Application for New 

10 Reactor Available on NRC Website (Accession No. ML081090082). 

11 April 25, 2008 Letter from Mr. John Rycyna, NRC, to Mr. George Vanderheyden, 

12 UniStar, acknowledging receipt of the combined license application for 

13 Calvert Cliffs Nuclear Power Plant (Accession No. ML081060307). 

14 May 7, 2008 Letter from Dr. Mary J. Ratnaswamy, U.S. Fish and Wildlife Service, to 

15 Ms. Harriet Nash, NRC, providing information on endangered and 

16 threatened species within the project area for the Calvert Cliffs Nuclear 

17 Power Plant (Accession No. ML081340645). 

18 May 8, 2008 Memo from Mr. Thomas Fredrichs, NRC, to Mr. Richard Raione, NRC, 

19 transmitting the Summary of the Public Scoping Meeting to Support the 

20 Review of the Calvert Cliffs Nuclear Power Plant Combined License 

21 Application (Accession No. ML091690293). 

22 May 13, 2008 Email from Mr. Thomas Fredrichs, NRC, to Mr. George Wrobel, UniStar, 

23 transmitting Requests for Additional Information for the Environmental 

24 Review of the Calvert Cliffs Combined License Application (Accession 

25 No. ML081430521). 

26 May 16, 2008 Letter from Mr. Dimitri Lutchenkov, UniStar to the U.S. Army Corps of 

27 Engineers transmitting Joint Federal / State Application for the Alteration 

28 of Any Floodplain, Waterway, Tidal or Nontidal Wetland in Maryland 

29 (Accession No. ML081840343). 

30 May 20, 2008 Letter from Robin D. Leone, on behalf of UniStar, to the Maryland Public 

31 Service Commission, transmitting the Joint Federal/State Application for 

32 the Alteration of Any Floodplain, Waterway, Tidal or Nontidal Wetland in 

33 Maryland for Calvert Cliffs (Accession No. ML093370101). 
Appendix C 

Draft NUREG-1936 C-6 April 2010

1 May 30, 2008 Letter from Mr. John E. Price, UniStar, to Ms. Kathy Anderson, U.S. Army 

2 Corps of Engineers, supplementing Joint Federal/State Application for 

3 Calvert Cliffs Nuclear Power Plant Unit 3 (Accession No. ML093630079). 

4 June 3, 2008 Letter from Mr. John Rycyna, NRC, to Mr. George Vanderheyden, 

5 UniStar, accepting and docketing Part 2 of the combined license 

6 application for Calvert Cliffs Nuclear Power Plant (Accession No. 

7 ML081510149). 

8 June 4, 2008 Press Release No. 08-110: NRC Accepts Application for the New 

9 Reactor at Calvert Cliffs (Accession No. ML081560749). 

10 June 9, 2008 Federal Register Notice of Acceptance for Part 2 of the combined license 

11 application for Calvert Cliffs Nuclear Power Plant (73 FR 32606). 

12 June 10, 2008 Letter from Mr. George Vanderheyden, UniStar, to NRC transmitting the 

13 responses to the May 13, 2008 requests for additional information 

14 (Accession No. ML100040300. 

15 June 11, 2008 Letter from Mr. Nilesh Chokshi, NRC, to Ms. Margaret E. Gaffney-Smith, 

16 U.S. Army Corps of Engineers, responding to cooperating agency status 

17 request for the Calvert Cliffs Nuclear Power Plant Environmental Impact 

18 Statement (Accession No. ML081570139). 

19 July 10, 2008 Memo from Mr. Thomas Fredrichs, NRC, to Mr. Richard Raione, NRC, 

20 transmitting the Trip Report for the Calvert Cliffs Environmental Site Audit 

21 from March 17-20, 2008 (Accession No. ML081900202). 

22 July 10, 2008 Memo from Mr. Robert Tabisz, Maryland Department of the Environment, 

23 to Calvert Cliffs 3 Nuclear Project LLC and Bechtel Power Corporation 

24 regarding permit request (Accession No. ML093630084). 

25 July 14, 2008 Letter from Mr. Dimitri Lutchenkov, UniStar, to Ms. Kathy Anderson, U.S. 

26 Army Corps of Engineers, providing supplemental information for Joint 

27 Federal / State Application (Accession No. ML091671199). 

28 August 1, 2008 Letter from Ms. Robin D. Leone, Saul Ewing Attorneys at Law 

29 representing UniStar, to Ms. Terry J. Romine, Maryland Public Service 

30 Commission, transmitting revised information for the Certificate of Public 

31 Convenience and Necessity to Construct a Nuclear Power Plant at 

32 Calvert Cliffs (Accession No. ML091671372). 
 Appendix C 

April 2010 C-7 Draft NUREG-1936

1 August 18, 2008 Letter from Mr. George Vanderheyden, UniStar, to NRC transmitting 

2 responses to environmental requests for additional information for the 

3 combined license application for the Calvert Cliffs Nuclear Power Plant 

4 (Accession No. ML083480179). 

5 August 20, 2008 Letter from Mr. George Wrobel, UniStar, to NRC transmitting Revision 3 

6 of the Calvert Cliffs Combined License Application (Accession No 

7 ML082390786). 

8 August 29, 2008 E-mail from Mr. Thomas Fredrichs, NRC, to Mr. George Wrobel, UniStar, 

9 transmitting feedback on UniStar responses to environmental requests for 

10 additional information for the combined license application for the Calvert 

11 Cliffs Nuclear Power Plant (Accession No. ML082910710). 

12 September 3, 2008 U.S. Army Corps of Engineers Public Notice for comment period for 

13 Calvert Cliffs Nuclear Power Plant (Accession No. ML082550288). 

14 September 10, 2008 E-mail from Mr. Thomas Fredrichs, NRC, to Mr. George Wrobel, UniStar, 

15 transmitting supplemental terrestrial ecology requests for additional 

16 information for the combined license application for the Calvert Cliffs 

17 Nuclear Power Plant (Accession No. ML082910713). 

18 September 18, 2008 Letter from Mr. John Rycyna, NRC, to Mr. George Vanderheyden, 

19 UniStar, enclosing Notice of Hearing and Opportunity to Petition for Leave 

20 to Intervene and Order Imposing Procedures for Access to Sensitive 

21 Unclassified Non-Safeguards Information (SUNSI) and Safeguards 

22 Information (SGI) for Contention Preparation on a Combined License for 

23 the Calvert Cliffs Nuclear Power Plant Unit 3 (Accession No. 

24 ML082530335). 

25 September 19, 2008 E-mail from Mr. Thomas Fredrichs, NRC, to Mr. George Wrobel, UniStar, 

26 transmitting revised terrestrial ecology requests for additional information 

27 for the combined license application for the Calvert Cliffs Nuclear Power 

28 Plant (Accession No. ML082910711). 

29 September 19, 2008 Letter from Mr. George Vanderheyden, UniStar, to NRC transmitting 

30 Request for Additional Information Response related to LADTAP and 

31 GASPAR Files (Accession No. ML093370357). 

32 September 22, 2008 Email from Mr. Jim Burkman, Constellation, to Ms. Kathy Anderson, U.S. 

33 Army Corps of Engineers, transmitting revision 3 corrections to the work 

34 description for the Corps review (Accession No. ML091350328). 
Appendix C 

Draft NUREG-1936 C-8 April 2010

1 September 25, 2008 Comment form submitted by Maryland Historical Trust in response to U.S. 

2 Army Corps of Engineers public notice (Accession No. ML093630083). 

3 September 26, 2008 Federal Register Notice of Hearing and Opportunity to Petition for Leave 

4 to Intervene and Order Imposing Procedures for Access to SUNSI and 

5 SGI for Contention Preparation on a Combined License for the Calvert 

6 Cliffs Nuclear Power Plant Unit 3 (73 FR 55876). 

7 September 26, 2008 Press Release No. 08-178: NRC Announces Opportunity to Participate in 

8 the Hearing on the New Reactor Application for Calvert Cliffs (Accession 

9 No. ML082700493). 

10 September 29, 2008 Letter from Mr. Greg Gibson, UniStar, to NRC transmitting responses to 

11 supplemental aquatic ecology requests for additional information 

12 (Accession No. ML090420560). 

13 September 30, 2008 Letter from Mr. Greg Gibson, UniStar, to NRC transmitting updated 

14 response to environmental request for additional information (Accession 

15 No. ML082770047). 

16 September 30, 2008 Letter from Mr. Leopoldo Miranda, U.S. Fish and Wildlife Service, to 

17 Colonel Peter W. Mueller, U.S. Army Corps of Engineers- Baltimore 

18 District, responding to public notice (Accession No. ML093630080). 

19 October 3, 2008 Letter from Mr. John Nichols, NOAA, to Ms. Kathy Anderson, U.S. Army 

20 Corps of Engineers, regarding the Calvert Cliffs Nuclear Power Plant 

21 combined operating license application environmental review (Application 

22 No. ML082910715). 

23 October 9, 2008 Memo from Mr. Thomas Fredrichs, NRC, to Mr. Andrew Kugler, NRC 

24 transmitting the Scoping Summary Report Related to the Environmental 

25 Scoping Process for the Calvert Cliffs Unit 3 Combined License 

26 Application Review (Accession No. ML093290199). 

27 October 14, 2008 E-mail from Mr. John Rycyna, NRC, to Mr. George Wrobel, UniStar, 

28 transmitting supplemental environmental requests for additional 

29 information (Accession No. ML082900834). 

30 October 17, 2008 Letter from Mr. Greg Gibson, UniStar, to NRC transmitting responses to 

31 terrestrial ecology requests for additional information (Accession No. 

32 ML082960400). 
 Appendix C 

April 2010 C-9 Draft NUREG-1936

1 October 21, 2008 Memo from Mr. Thomas Fredrichs, NRC, to Mr. Gregory Hatchett, NRC, 

2 transmitting the Trip report from Calvert Cliffs intake structure and Thiokol 

3 Alternative site visits (Accession No. ML082910218). 

4 October 23, 2008 Letter from Ms. Linda C. Janey, Maryland Department of Planning, to Mr. 

5 Dimitri Lutchenkov, UniStar, transmitting comments on the proposed 

6 Calvert Cliffs Nuclear Power Plant Unit 3 (Accession No. ML093630081). 

7 October 27, 2008 Letter from Mr. Greg Gibson, UniStar, to NRC transmitting supplemental 

8 responses to aquatic ecology requests for additional information 

9 (Accession No. ML083080068). 

10 October 27, 2008 Letter from Mr. Dimitri Lutchenkov, UniStar, to the Ms. Kathy Anderson, 

11 U.S. Army Corps of Engineers, requesting a decision on wetlands permits 

12 to be made within 30 days of publication of the final environmental impact 

13 statement (Accession No. ML083230532). 

14 October 28, 2008 Letter from Mr. William P. Seib, U.S. Army Corps of Engineers, to Mr. 

15 Thomas E. Roberts, Calvert Cliffs 3 Nuclear Project LLC, in response to 

16 application to build a nuclear power plant at the Calvert Cliffs site 

17 (Accession No. ML083170295). 

18 October 31, 2008 Letter from Mr. Elder Ghigiarelli, Jr., Maryland Department of the 

19 Environment, to Ms. Kathy Anderson, U.S. Army Corps of Engineers, 

20 regarding Section 401 Water Quality Certification for Calvert Cliffs 

21 Nuclear Power Plant (Accession No. ML093630082). 

22 October 31, 2008 Letter from Mr. Greg Gibson, UniStar, to NRC transmitting responses to 

23 environmental requests for additional information (Accession No. 

24 ML083110676). 

25 October 31, 2008 Letter from Mr. Greg Gibson, UniStar, to NRC transmitting response to 

26 request for additional information related to intake structure relocation 

27 affected sections in the combined license application (Accession No. 

28 ML0831008361). 

29 November 11, 2008 Letter from Mr. Dimitri Lutchenkov, UniStar, to Mr. William P. Seib, U.S. 

30 Army Corps of Engineers, transmitting responses to information needs 

31 detailed in October 28, 2008 letter (Accession No. ML091530687). 
Appendix C 

Draft NUREG-1936 C-10 April 2010

1 November 25, 2008 Letter from Mr. Greg Gibson, UniStar, to NRC transmitting corrected 

2 revision 3 to the combined license application (Accession No. 

3 ML083470549). 

4 December 4, 2008 Letter from Mr. Greg Gibson, UniStar, to NRC transmitting supplemental 

5 response to environmental impact statement issue #5 (Accession No. 

6 ML083440067). 

7 January 9, 2009 Letter from Mr. Greg Gibson, UniStar, to NRC transmitting supplemental 

8 responses to hydrology requests for additional information (Accession No. 

9 ML090710106). 

10 January 14, 2009 Letter from Mr. Greg Gibson, UniStar, to NRC transmitting intake 

11 structure relocation changes for the Environmental Report (Accession No. 

12 ML090220368). 

13 January 16, 2009 Letter from Mr. Joseph Colaccino, NRC, to Mr. Greg Gibson, UniStar, 

14 indicating a change in the schedule for the environmental review 

15 (Accession No. ML083570651). 

16 January 20, 2009 Letter from Mr. Dimitri Lutchenkov, UniStar, to Mr. William P. Seib, U.S. 

17 Army Corps of Engineers- Baltimore District, providing updated 

18 responses to questions on the Joint Federal/State Application (Accession 

19 No. ML093630095). 

20 January 30, 2009 Letter from Mr. Greg Gibson, UniStar, to NRC transmitting draft 

21 Unanticipated Discoveries Plan (Accession No. ML090350358). 

22 February 3, 2009 Letter from Mr. Thomas L. Fredrichs, NRC, to Mr. Greg Gibson, UniStar, 

23 transmitting environmental requests for additional information (Accession 

24 No. ML083310256). 

25 February 12, 2009 Letter from Mr. Dimitri Lutchenkov, UniStar, to Mr. William P. Seib, U.S. 

26 Army Corps of Engineers in regards to multi-agency site visit on January 

27 15 and 16, 2009 (Accession No. ML090620242). 

28 February 13, 2009 Letter from Mr. J. Rodney Little, Maryland Historical Trust, to Mr. William 

29 P. Seib, U.S. Army Corps of Engineers regarding effects on cultural 

30 resources (Accession No. ML090570416). 
 Appendix C 

April 2010 C-11 Draft NUREG-1936

1 February 18, 2009 Letter from Mr. Dimitri Lutchenkov, UniStar, to Ms. Amanda Sigillito, 

2 Maryland Department of the Environment, transmitting Phase I 

3 Compensatory Mitigation Plan for Non-Tidal and Stream Impacts 

4 associated with Calvert Cliffs Unit 3 (Accession No. ML093630094). 

5 February 19, 2009 Letter from Mr. Greg Gibson, UniStar, to NRC transmitting supplemental 

6 response to hydrology requests for additional information (Accession No. 

7 ML090550125). 

8 February 27, 2009 Letter from Mr. Dimitri Lutchenkov, UniStar, to Mr. William P. Seib, U.S. 

9 Army Corps of Engineers, transmitting responses to information needs 

10 detailed in October 28, 2008 letter (Accession No. ML091480200). 

11 February 27, 2009 Telecom Summaries for Telecoms held with UniStar from February 13, 

12 2009 to February 24, 2009 regarding Requests for Additional Information 

13 issued February 3, 2009 (Accession No ML090820698). 

14 March 3, 2009 Letter from Mr. Greg Gibson, UniStar, to NRC transmitting the Phase I 

15 Wetland/Stream Mitigation Plan (Accession No. ML093380593) 

16 March 5, 2009 Letter from Mr. Greg Gibson, UniStar, to NRC responding to 

17 environmental requests for additional information (Accession No. 

18 ML090710146). 

19 March 9, 2009 Letter from Mr. Greg Gibson, UniStar, to NRC transmitting Revision 4 to 

20 the Combined License Application for the Calvert Cliffs Nuclear Power 

21 Plant (Accession No. ML090860325). 

22 March 16, 2009 Letter from Mr. Greg Gibson, UniStar, to NRC transmitting schedule for 

23 revisions to the Combined License Application for the Calvert Cliffs 

24 Nuclear Power Plant (Accession No. ML090770890). 

25 March 17, 2009 Letter from Mr. Robert G. Schaaf, NRC, to Mr. Steve Sanford, Bureau of 

26 Habitat, regarding request for participation in the scoping process for the 

27 environmental review of the Calvert Cliffs Nuclear Power Plant combined 

28 license application (Accession No. ML083400571). 

29 March 23, 2009 Letter from Mr. Robert G. Schaaf, NRC, to Mr. Greg Gibson, UniStar, 

30 regarding project manager change for the combined license 

31 environmental review for Calvert Cliffs Nuclear Power Plant Unit 3 

32 (Accession No. ML090700448). 
Appendix C 

Draft NUREG-1936 C-12 April 2010

1 March 23, 2009 Letter from Mr. Greg Gibson, UniStar, to NRC responding to 

2 environmental requests for additional information (Accession No. 

3 ML090840149). 

4 March 27, 2009 Letter from Mr. Greg Gibson, UniStar, to NRC describing scope of 

5 Revision 5 to the Combined License Application for the Calvert Cliffs 

6 Nuclear Power Plant (Accession No. ML090900186). 

7 March 30, 2009 Memo from Mr. Thomas Fredrichs, NRC, to Mr. Robert Schaaf, NRC, 

8 transmitting the Trip Report from Calvert Cliffs alternative site visits 

9 (Accession No. ML090650192). 

10 April 2, 2009 Email from Mr. Chuck Nieder, New York Natural Heritage Program to Ms. 

11 Laura Quinn, NRC, regarding information request on the alternative sites 

12 located in New York State (Accession No. ML 091170694). 

13 April 14, 2009 Letter from Mr. Greg Gibson, UniStar, to NRC regarding restrictions of 

14 construction and refurbishment of the barge slip and unloading facility and 

15 associated dredging (Accession No. ML091060748). 

16 April 22, 2009 Letter from Ms. Laura Quinn, NRC, to Mr. Greg Gibson, UniStar, 

17 transmitting supplemental environmental requests for additional 

18 information (Accession No. ML090580042). 

19 April 24, 2009 Memo from Ms. Laura Quinn, NRC, to Mr. Robert Schaaf, NRC 

20 transmitting the Meeting Notice for the Public Meeting to Discuss the 

21 Alternative Siting Process for the Proposed Calvert Cliffs Combined 

22 License Application for Unit 3 (Accession No. ML091180022). 

23 April 27, 2009 Letter from Ms. Kelly P. Neff, Maryland Department of the Environment, 

24 to Mr. Dimitri Lutchenkov, UniStar, approving the Phase I Mitigation Plan 

25 for Calvert Cliffs Nuclear Power Plant (Accession No. ML091270980). 

26 May 13, 2009 Letter from Mr. Greg Gibson, UniStar, to NRC transmitting the Federal 

27 Fish and Wildlife Permit for Eagle Scientific Collecting (Accession No. 

28 ML091340643). 

29 May 19, 2009 Letter from Mr. Greg Gibson, UniStar, to NRC transmitting responses to 

30 environmental requests for additional information (Accession No. 

31 ML091410432). 
 Appendix C 

April 2010 C-13 Draft NUREG-1936

1 May 22, 2009 Letter from Mr. Greg Gibson, UniStar, to NRC transmitting Biological 

2 Evaluation for Tiger Beetles (Accession No. ML091480389). 

3 May 22, 2009 Letter from Mr. Greg Gibson, UniStar, to Ms. Kathy Anderson, U.S. Army 

4 Corps of Engineers, transmitting Mitigation Summary for National 

5 Register of Historic Places- Eligible Historic Properties (Accession No. 

6 ML091660537). 

7 May 22, 2009 Letter from Mr. Greg Gibson, UniStar, to Ms. Kathy Anderson, U.S. Army 

8 Corps of Engineers, transmitting the Maryland Department of the 

9 Environment approval letter for the Calvert Cliffs Nuclear Power Plant 

10 Unit 3 Phase I Nontidal Wetlands Mitigation Plan (Accession No. 

11 ML091660577). 

12 June 1, 2009 Letter from Mr. Greg Gibson, UniStar, to NRC regarding Alternate Site 

13 Evaluation Report Submittal Schedule (Accession No. ML091540279). 

14 June 2, 2009 Memo from Ms. Laura Quinn, NRC, to Mr. Robert Schaaf, NRC 

15 transmitting the Meeting Summary of the Alternative Site Selection 

16 Process Meeting for the Calvert Cliffs Nuclear Power Plant Combined 

17 License Application (Accession No. ML091390621). 

18 June 3, 2009 Letter from Mr. Greg Gibson, UniStar, to NRC regarding request for 

19 Portable Document Format Meteorological Data (Accession No. 

20 ML091620273). 

21 June 8, 2009 Letter from Mr. Greg Gibson, UniStar, to NRC transmitting U.S. 

22 Department of Energy contract in response to environmental request for 

23 additional information (Accession No. ML091610666). 

24 June 11, 2009 Letter from Mr. Greg Gibson, UniStar, to NRC, transmitting figure in 

25 response to environmental request for additional information (Accession 

26 No. ML091690067). 

27 June 30, 2009 Letter from Mr. Greg Gibson, UniStar, to NRC transmitting Revision 5 of 

28 the Calvert Cliffs Nuclear Power Plant Combined License Application 

29 (Accession No. ML0918805530). 

30 July 15, 2009 Letter from Ms. Beth Bachur, U.S. Army Corps of Engineers, to Mr. Reid 

31 J. Nelson, Advisory Council on Historic Preservation, notifying the Council 

32 of a Memorandum of Agreement for the review of the Calvert Cliffs 

33 application (Accession No. ML0930602350). 
Appendix C 

Draft NUREG-1936 C-14 April 2010

1 July 17, 2009 Letter from Mr. Greg Gibson, UniStar, to NRC providing revised alternate 

2 site evaluation (Accession No. ML092020313). 

3 July 24, 2009 Letter from Mr. Greg Gibson, UniStar, to NRC providing follow-up 

4 responses to environmental requests for additional information 

5 (Accession No. ML092150728). 

6 July 24, 2009 Letter from Mr. Raymond Wallace, Advisory Council on Historic 

7 Preservation, to Ms. Beth E. Bachur, U.S. Army Corps of Engineers, 

8 regarding the Memorandum of Agreement for the Calvert Cliffs 

9 application review (Accession No. ML093060220). 

10 July 29, 2009 Letter from Mr. Greg Gibson, UniStar, to NRC providing follow-up 

11 responses to environmental requests for additional information 

12 (Accession No. ML092120061). 

13 July 30, 2009 Letter from Ms. Beth E. Bachur, U.S. Army Corps of Engineers, to Mr. 

14 Michael Lesar, NRC, regarding the Corps’ comments on the Phase I 

15 Stream and Wetland Mitigation Plan for the Calvert Cliffs project 

16 (Accession No. ML093240035). 

17 July 31, 2009 Letter from Mr. Greg Gibson, UniStar, to NRC providing follow-up 

18 responses to environmental requests for additional information 

19 (Accession No. ML092190635). 

20 August 7, 2009 Email from Ms. Laura Quinn, NRC, to Mr. Dimitri Lutchenkov, UniStar, 

21 transmitting the Calvert Cliffs Site Audit Information Needs for the 

22 Revised Alternative Site Audit and Visit (Accession No. ML092340028). 

23 August 20, 2009 Letter from Mr. Joseph Colaccino, NRC, to Mr. George Vanderheyden, 

24 UniStar, transmitting revised environmental schedule for the combined 

25 license application review for the Calvert Cliffs Nuclear Power Plant, Unit 

26 3 (Accession No. ML092190214). 

27 August 27, 2009 Letter from Ms. Laura Quinn, NRC, to Mr. Greg Gibson, UniStar, 

28 transmitting Request for Additional Information Related to the 

29 Environmental Report for the Calvert Cliffs Combined License Application 

30 – Ozone Air Emissions During Construction and Operation (Accession 

31 No. ML092260454). 
 Appendix C 

April 2010 C-15 Draft NUREG-1936

1 August 29, 2009 Letter from Mr. Greg Gibson, UniStar, to NRC providing revision 1 of the 

2 alternate site evaluation and Environmental Report Chapter 9.3 

3 (Accession No. ML092450557). 

4 September 3, 2009 Letter from Ms. Laura Quinn, NRC, to Mr. Mark Stiffler, Alcoa Corporate 

5 Center, expressing appreciation for site tour of the Alcoa Eastalco Works 

6 Frederick, Maryland site (Accession No. ML092370676). 

7 September 3, 2009 Letter from Ms. Laura Quinn, NRC, to Ms. Donna C. Tapley, Bainbridge 

8 Development Corporation, expressing appreciation for site tour of the 

9 former Bainbridge Naval Training Center site in Port Deposit, Maryland 

10 (Accession No. ML092390270). 

11 September 10, 2009 Letter from Mr. Greg Gibson, UniStar, to NRC providing input/output files 

12 from TRAGIS and RADTRAN programs for alternative sites (Accession 

13 No. ML092570249). 

14 September 16, 2009 Letter from Mr. Robert G. Schaaf, NRC, to Mr. Dimitri Lutchenkov, 

15 UniStar, regarding Calvert Cliffs Nuclear Power Plant combined license 

16 application online reference portal (Accession No. ML092520671). 

17 September 17, 2009 Letter from Mr. Greg Gibson, UniStar, to NRC providing follow-up 

18 response to environmental request for additional information (Accession 

19 No. ML092640140). 

20 September 18, 2009 Letter from Ms. Laura Quinn, NRC, to Mr. Greg Gibson, UniStar, to NRC 

21 transmitting environmental requests for additional information on revised 

22 alternative sites (Accession No. ML092450423). 

23 September 21, 2009 Letter from Mr. Greg Gibson, UniStar, to NRC accepting terms of online 

24 reference portal operation (Accession No. ML092670169). 

25 September 25, 2009 Letter from Mr. Greg Gibson, UniStar, to NRC providing responses to 

26 environmental requests for additional information (Accession No. 

27 ML092730188). 

28 September 25, 2009 Letter from Mr. Greg Gibson, UniStar, to NRC providing response to 

29 environmental requests for additional information (Accession No. 

30 ML092730202). 
Appendix C 

Draft NUREG-1936 C-16 April 2010

1 September 25, 2009 Letter from Mr. Greg Gibson, UniStar, to NRC transmitting the response 

2 to request for additional information number 1019 (Accession No. 

3 ML092730187). 

4 September 25, 2009 Letter from Mr. Greg Gibson, UniStar, to Ms. Beth Bachur, U.S. Army 

5 Corps of Engineers, transmitting the Summary of the Phase I Mitigation 

6 Plan for the Non-Tidal Wetland and Stream Impacts (Accession No. 

7 ML093380280). 

8 September 30, 2009 Letter from Mr. Greg Gibson, UniStar to NRC transmitting Revision 6 of 

9 the Calvert Cliffs Nuclear Power Plant Combined License Application 

10 (Accession No. ML092880200). 

11 October 2, 2009 Letter from Mr. Greg Gibson, UniStar, to NRC providing schedule for 

12 completion of updated construction emissions analysis for Calvert Cliffs 

13 Nuclear Power Plant Unit 3 (Accession No. ML092800159). 

14 October 9, 2009 Letter from Mr. Greg Gibson, UniStar, to Mr. J. Rodney Little, Director and 

15 State Historic Preservation Officer, providing Architectural and Historical 

16 Resources Field Documentation Update (Accession No. ML092870437). 

17 October 14, 2009 Letter from Mr. Greg Gibson, UniStar, to Ms. Marian Honeczy, Maryland 

18 Forest Service, transmitting the Forest Conservation Plan 

19 (ML093380281). 

20 October 15, 2009 Letter from Mr. Greg Gibson, UniStar, to NRC transmitting supplemental 

21 response to Questions No. 1 and No. 5 of the U.S. Army Corps of 

22 Engineers request for additional information No. 1019 (Accession No. 

23 ML092920352). 

24 October 19, 2009 Letter from Mr. Greg Gibson, UniStar, to NRC transmitting Revised 

25 Supplemental Response to request for additional information SE-2 

26 (Accession No. ML092940343). 

27 October 26, 2009 Letter from Mr. Robert G. Schaaf, NRC, to Mr. Douglas Austin, 

28 Pennsylvania Fish and Boat Commission, requesting information on new 

29 alternative sites identified for Calvert Cliffs Nuclear Power Plant Unit 3 

30 (Accession No. ML092660314). 
 Appendix C 

April 2010 C-17 Draft NUREG-1936

1 October 26, 2009 Letter from Mr. Robert G. Schaaf, NRC, to Mr. Steven G. Bowman, 

2 Virginia Marine Resources Commission, requesting information on new 

3 alternative sites identified for Calvert Cliffs Nuclear Power Plant Unit 3 

4 (Accession No. ML092660325). 

5 October 26, 2009 Letter from Mr. Robert G. Schaaf, NRC, to Mr. Robert W. Duncan, 

6 Virginia Department of Game and Inland Fisheries, requesting information 

7 on new alternative sites identified for Calvert Cliffs Nuclear Power Plant 

8 Unit 3 (Accession No. ML092660318). 

9 October 26, 2009 Letter from Mr. Robert G. Schaaf, NRC, to Mr. John R. Griffin, Maryland 

10 Department of Natural Resources, requesting information on new 

11 alternative sites identified for Calvert Cliffs Nuclear Power Plant Unit 3 

12 (Accession No. ML092660202). 

13 October 26, 2009 Letter from Mr. Robert G. Schaaf, NRC, to Ms. Patricia Kurkul, National 

14 Marine Fisheries Service, requesting information on new alternative sites 

15 identified for Calvert Cliffs Nuclear Power Plant Unit 3 (Accession No. 

16 ML092660237). 

17 October 26, 2009 Letter from Mr. Robert G. Schaaf, NRC, to Mr. Leopoldo Miranda, U.S. 

18 Fish & Wildlife Service, requesting information on new alternative sites 

19 identified for Calvert Cliffs Nuclear Power Plant Unit 3 (Accession No. 

20 ML092660268). 

21 October 26, 2009 Letter from Mr. Robert G. Schaaf, NRC, to Mr. Carl Roe, Pennsylvania 

22 Game Commission, requesting information on new alternative sites 

23 identified for Calvert Cliffs Nuclear Power Plant Unit 3 (Accession No. 

24 ML092660259). 

25 October 26, 2009 Letter from Mr. Robert G. Schaaf, NRC, to Mr. Paul Swartz, 

26 Susquehanna River Basin Commission, requesting information on new 

27 alternative sites identified for Calvert Cliffs Nuclear Power Plant Unit 3 

28 (Accession No. ML092660186). 

29 October 26, 2009 Letter from Mr. Robert G. Schaaf, NRC, to Ms. Shari Wilson, Maryland 

30 Department of the Environment, requesting information on new 

31 alternative sites identified for Calvert Cliffs Nuclear Power Plant Unit 3 

32 (Accession No. ML092660193). 
Appendix C 

Draft NUREG-1936 C-18 April 2010

1 October 26, 2009 Letter from Mr. Greg Gibson, UniStar, to NRC, transmitting updated 

2 responses to requests for additional information number 1006 and 1013 

3 (Accession No. ML093020150). 

4 October 29, 2009 Letter from Mr. Greg Gibson, UniStar, to NRC responding to questions on 

5 Combined License Application Revision 5 changes (Accession No. 

6 ML093070286). 

7 November 4, 2009 Email from Dr. Diana Post, Rachel Carson Council, to Ms. Laura Quinn, 

8 NRC, regarding opposition to the Calvert Cliffs Unit 3 Project (Accession 

9 No. ML093550177). 

10 November 4, 2009 Letter from Mr. Greg Gibson, UniStar, to NRC transmitting supplemental 

11 response to Request for Additional Information number 37, “Hydraulic 

12 Dredging” (Accession No. ML093130127). 

13 November 13, 2009 Letter from Ms. Susan T. Gray, Maryland Department of Natural 

14 Resources, to Ms. Laura Quinn, NRC, transmitting the response to the 

15 request for information on the new alternative sites for the Calvert Cliffs 

16 review (Accession No. ML093280756). 

17 November 16, 2009 Letter from Mr. Greg Gibson, UniStar, to NRC transmitting Supplemental 

18 Response to Request for Additional Information Number 124, Estimated 

19 Tax Benefit (Accession No. ML093220193). 

20 November 16, 2009 Email from Mr. Dave Spotts, Pennsylvania Fish and Boat Commission, to 

21 Ms. Laura Quinn, NRC, responding to the information request on the 

22 revised alternative sites (Accession No. ML093290145). 

23 November 20, 2009 Letter from Ms. Deborah E Jennings, DLA Piper on behalf of UniStar, to 

24 Ms. Terry J. Romine, Public Service Commission of Maryland, 

25 transmitting Application of Calvert Cliffs 3 Nuclear Project, LLC and 

26 UniStar Nuclear Operating Services, LLC for a Certificate of Public 

27 Convenience and Necessity Authorizing the Modification of the Calvert 

28 Cliffs Unit 3 Project at Calvert Cliffs in Calvert County, Maryland 

29 (Accession No. ML093380229). 

30 December 3, 2009 Letter from Mr. Greg Gibson, UniStar, to Ms. Kathy Anderson, U.S. Army 

31 Corps of Engineers, transmitting Temporary Impacts to Wetlands and 

32 Streams Associated with Mitigation Construction Activities for Calvert 

33 Cliffs Unit 3 (Accession No. ML093370671). 
 Appendix C 

April 2010 C-19 Draft NUREG-1936

1 December 4, 2009 Letter from Mr. Greg Gibson, UniStar, to NRC transmitting responses to 

2 NRC telecom questions regarding Combined License Application 

3 Revision 6 (Accession No. ML093421232). 

4 December 7, 2009 Email from Mr. Ernie Aschenbach, Virginia Dept. of Game and Inland 

5 Fisheries to Ms. Laura Quinn, NRC, regarding the Information Request on 

6 the New Alternative Sites (Accession No. ML093520692). 

7 December 8, 2009 Letter from Mr. Greg Gibson, UniStar, to Ms. Amanda Sigillito, Maryland 

8 Department of the Environment and Ms. Kathy Anderson, Corps 

9 transmitting the Conceptual Phase II Non-Tidal Wetland and Stream 

10 Mitigation Plan for Calvert Cliffs Unit 3 (Accession No. ML0935206940). 

11 December 9, 2009 Letter from Mr. Greg Gibson, UniStar, to NRC transmitting Low level 

12 Waste Disposal Plans for Calvert Cliffs Unit 3 (Accession No. 

13 ML093480069). 

14 December 10, 2009 Memo from Mr. John Nichols, National Oceanic and Atmospheric 

15 Administration, to Ms. Laura Quinn, NRC, transmitting Calvert Cliffs 

16 Nuclear Power Plant, Unit 3 Alternative Sites Analysis Information 

17 (Accession No. ML093520687). 

18 December 11, 2009 Letter from Mr. Greg Gibson, UniStar, to NRC transmitting RAI No. 1014 

19 NOx and VOC Air Emissions during Construction and Operation 

20 (Accession No. ML093491087). 

21 December 17, 2009 Letter from Mr. Greg Gibson, UniStar, to Kathy Anderson, Corps, 

22 transmitting the Summary of the Conceptual Phase II Non-Tidal Wetland 

23 and Stream Mitigation Plan for Calvert Cliffs Unit 3 (Accession No. 

24 ML093620517). 

25 December 23, 2009 Letter from Mr. Robert Schaaf, NRC, to Dr. Diana Post, Rachel Carson 

26 Council, Inc., regarding Comments on the Environmental Review for the 

27 Combined License Application for Calvert Cliffs (Accession No. 

28 ML093290154). 

29 December 31, 2009 Letter from Mr. Greg Gibson, UniStar, to NRC transmitting Summary - 

30 Refinements between the Phase I Conceptual Phase II Nontidal Wetland 

31 and Stream Cliffs Nuclear Power Plant, Unit 3 (Accession No. 

32 ML100050191) 
Appendix C 

Draft NUREG-1936 C-20 April 2010

1 January 28, 2010 Letter from Mr. Leopoldo Miranda, U.S. Fish and Wildlife Service, to Mr. 

2 Robert Schaaf, NRC, transmitting Information and Consultation request 

3 regarding the combined license application for Calvert Cliffs Nuclear 

4 Power Plant Unit 3 (Accession No. ML100430613). 

5 February 23, 2010 Letter from Mr. Frank Akstulewicz, NRC, to Mr. George Vanderheyden, 

6 UniStar, transmitting Revised Environmental Schedule for the Combined 

7 License Application Review for the Calvert Cliffs Nuclear Power Plant, 

8 Unit 3 (Accession No. ML100540412). 

9 February 25, 2010 Letter from Mr. Leopoldo Miranda, U.S. FWS, to Mr. Robert Schaaf, NRC, 

10 regarding New Alternative Sites in Maryland for Calvert Cliffs Nuclear 

11 Power Plant Unit 3 (Accession No. ML100640429). 

12 March 2, 2010 Memo from Ms. Laura Quinn, NRC, to Mr. Robert Schaaf, NRC, 

13 transmitting the Trip Report to Calvert Cliffs for the Tiger Beetle and 

14 Phase I Mitigation Plan Activities (Accession No. ML100070711). 

15 March 2, 2010 Memo from Ms. Laura Quinn, NRC, to Mr. Robert Schaaf, NRC, 

16 transmitting Trip Report: Interviews with Public Officials regarding 

17 Socioeconomic and Environmental Justice Information for Calvert Cliffs 

18 Unit 3 (Accession No. ML100050174). 

19 March 11, 2010 Letter from Mr. Greg Gibson, UniStar, to Ms. Laura Quinn, NRC, 

20 transmitting UniStar Nuclear Energy, NRC Docket No. 52-016 Calvert 

21 Cliffs Nuclear Power Plant, Unit 3 CZMA Certification (Accession No. 

22 ML100740273). 

23 March 16, 2010 Memo from Ms. Laura Quinn, NRC, to Robert Schaaf, NRC, transmitting 

24 the Calvert Cliffs Site Audit Summary for the Revised Alternative Sites 

25 (Accession No. ML100040227). 

26 March 16, 2010 Letter from Ms. Kathy Anderson, Corps, to Mr. Reid Nelson, ACHP, 

27 transmitting the Memorandum of Agreement for Cultural and Historic 

28 Resources for the Proposed Unit 3 at Calvert Cliffs (Accession No. 

29 ML100810272. 
Appendix D 

Scoping Comments and Responses 

April 2010 D-1 Draft NUREG-1936 

Appendix D 

Scoping Comments and Responses 

1 On February 14, 2008, the U.S. Nuclear Regulatory Commission (NRC) published a Notice of 

2 Intent to Prepare an Environmental Impact Statement and Conduct Scoping Process in the 

3 Federal Register (73 FR 8719) (ML080390115). The Notice of Intent notified the public of the 

4 staff’s intent to prepare an environmental impact statement (EIS) and conduct scoping for the 

5 combined license (COL) application received from UniStar Nuclear Development, LLC (UniStar) 

6 for a new nuclear plant, identified as Calvert Cliffs Unit 3, to be located at the existing Calvert 

7 Cliffs site, located approximately 60 mi south of Baltimore. This EIS has been prepared in 

8 accordance with provisions of the National Environmental Policy Act of 1969, as amended 

9 (NEPA); Council on Environmental Quality guidelines; and Title 10 of the Code of Federal 

10 Regulations (CFR) Parts 51 and 52. As outlined by NEPA, the NRC initiated the scoping 

11 process with the issuance of the Federal Register Notice. The NRC invited the applicant; 

12 Federal, Tribal, State, and local government agencies; local organizations; and individuals to 

13 participate in the scoping process by providing oral comments at two scheduled public meetings 

14 and/or by submitting written suggestions and comments no later than April 14, 2008. 

15 The scoping process provides an opportunity for public participation to identify items to be 

16 addressed in the EIS and highlight public concerns and issues. The Notice of Intent identified 

17 the following objectives of the scoping process: 

18 • Define the proposed action that is to be the subject of the EIS. 

19 • Determine the scope of the EIS and identify significant issues to be analyzed in depth. 

20 • Identify and eliminate from detailed study those issues that are peripheral or that are not 

21 significant. 

22 • Identify any environmental assessments and other EISs that are being prepared or will be 

23 prepared that are related to, but not part of, the scope of the EIS being considered. 

24 • Identify other environmental review and consultation requirements related to the proposed 

25 action. 

26 • Identify parties consulting with the NRC under the NHPA, as set forth in 36 CFR 

27 800.8(c)(1)(i). 

28 • Indicate the relationship between the timing of the preparation of the environmental 

29 analyses and the Commission’s tentative planning and decision-making schedule. 
Appendix D 

Draft NUREG-1936 D-2 April 2010 

1 • Identify any cooperating agencies and, as appropriate, allocate assignments for preparation 

2 and schedules for completing the EIS to the NRC and any cooperating agencies. 

3 • Describe how the EIS will be prepared, and identify any contractor assistance to be used. 

4 Two public scoping meetings were held in Solomons, Maryland, on March 19, 2008. 

5 Approximately 250 people attended the afternoon session, and approximately 225 people 

6 attended the evening session. Each meeting began with NRC staff members providing a brief 

7 overview of NRC’s review process for COL applications and the NEPA process. After the 

8 NRC’s prepared statements, the meetings were opened for public comments. Twenty-seven 

9 (27) afternoon scoping meeting attendees and 21 evening scoping meeting attendees provided 

10 oral comments that were recorded and transcribed by a certified court reporter. Five written 

11 statements were received during the meetings. In addition to the oral and written statements 

12 provided at the public scoping meetings, six letters and 201 emails were received during the 

13 scoping period. 

14 Transcripts for both the afternoon and evening scoping meetings can be found in the NRC’s 

15 Agency Document Access and Management System (ADAMS), under accession numbers 

16 ML081160460 and ML081160468, respectively. ADAMS is accessible from the NRC website at 

17 http://www.nrc.gov/reading-rm/adams/web-based.html (in the Public Electronic Reading Room; 

18 note that the URL is case-sensitive). A meeting summary (ML091690293) was issued May 8, 

19 2008. 

20 At the conclusion of the scoping period, the NRC staff reviewed the scoping meeting transcripts 

21 and all written material received during the comment period and identified individual comments. 

22 These comments were organized according to topic within the proposed EIS or according to the 

23 general topic if outside the scope of the EIS. Once comments were grouped according to 

24 subject area, the staff determined the appropriate response for the comment. The staff made a 

25 determination on each comment that it was one of the following: 

26 • a comment that was actually a question and introduced no new information. 

27 • a comment that was either related to support or opposition of combined licensing in general 

28 (or specifically the Calvert Cliffs COL) or that made a general statement about the COL 

29 process. In addition, it provided no new information and did not pertain to 10 CFR Part 52. 

30 • a comment about an environmental issue that 

31 – provided new information that would require evaluation during the review 

32 – provided no new information. 

33 • a comment that was outside the scope of the COL, which included, but was not limited to, a 

34 comment on the safety of the existing units. 
Appendix D 

April 2010 D-3 Draft NUREG-1936 

1 After comments were grouped according to subject area, the staff prepared responses to the 

2 comments, identifying which were within the scope of the EIS. The Calvert Cliffs Unit 3 

3 Combined License Scoping Summary Report was released in October 2008 and is available in 

4 ADAMS at accession number ML082630585. 

5 Each comment applicable (in scope) to this environmental review is summarized in this 

6 appendix. This information, which was extracted from the Calvert Cliffs Unit 3 Combined 

7 License Scoping Summary Report, is provided for convenience of those interested in the 

8 scoping comments. The comments that are outside of the scope of the environmental review 

9 for the proposed Unit 3 site are not included here. These include comments related to 

10 • Safety 

11 • Emergency preparedness 

12 • NRC oversight for operating plants 

13 • Security and terrorism 

14 • Support or opposition to the licensing action, licensing process, nuclear power, hearing 

15 process, or the existing plant. 

16 Changes to a few of the responses have made since the publication of the Scoping Summary 

17 Report (e.g., revisions to the EIS outline) and are indicated within brackets. Most of these refer 

18 to changes or the addition of EIS chapter or section numbers for the reader’s convenience. 

19 Table D-1 identifies, in alphabetical order, the individuals providing comments during the 

20 scoping period; their affiliation, if given; and the ADAMS accession number that can be used to 

21 locate the correspondence. Although all commenters are listed to maintain consistency with the 

22 scoping summary report numbering system, the comments presented in this appendix are 

23 limited to those within the scope of the environmental review. Table D-2 lists the comment 

24 categories in alphabetical order and commenter names and comment numbers for each 

25 category. The balance of this appendix presents the comments themselves with NRC staff 

26 responses organized by topic category. 

27 Table D-1. Individuals Providing Comments During the Comment Period 

Commenter Affiliation (if stated)

Comment Source and 

ADAMS Accession #

Acevedo, NK Self Email (ML081510581) 

Aitken, Keith Self Email (ML081510623) 

Albright, Evan Self Email (ML081510692) 

Andereson, David Self Email (ML081510716) 
Appendix D 

Draft NUREG-1936 D-4 April 2010 

1 

Table D-1. (contd)

Commenter Affiliation (if stated)

Comment Source and 

ADAMS Accession #

Arist, Phyllis Self Email (ML081510632) 

Armas, Zoe Self Email (ML081510729) 

Arndt, Gunter Self Email (ML081510518) 

Avance, Kenneth Self Email (ML081510635) 

Bainum, Meghan Self Email (ML081510728) 

Bakalian, Craig Self Email (ML081510684) 

Baldwin, Natylie Self Email (ML081510549) 

Barr, Phillip Self Email (ML081510560) 

Bartholomew, Alice Self Email (ML081510640) 

Baummer, Thomas Self Email (ML081510546) 

Be, Maya Self Email (ML081510776) 

Becker, Rochelle Self Email (ML081510698) 

Bedding, Gerhard Self Email (ML081510586) 

Behabadi, Bardia Self Email (ML081510659) 

Benton, Mike Self Meeting Transcript 

(ML081160460) 

Bissonnette, Rick Self Email (ML081510714) 

Black, Monica Latka Self Email (ML081510585) 

Blomstrom, Eric Self Email (ML081510525) 

Borrowman, Ellen Self Email (ML081510711) 

Boswell, William Self Email (ML081510521) 

Boxwell, Bob Self Meeting Transcript 

(ML081160460) 

Briggs, Ruth Self Email (ML081510673) 

Brown, Jr., Edsel NAACP of Calvert County Email (ML081510736) 

Buchanan, Bill Self Meeting Transcript 

(ML081160468) 

Burton, Bob Anne Arundel County Chamber of Commerce Meeting Transcript 
Appendix D 

April 2010 D-5 Draft NUREG-1936 

Table D-1. (contd)

Commenter Affiliation (if stated)

Comment Source and 

ADAMS Accession #

(ML081160460) 

C, Suzy [per email] Self Email (ML081510568) 

Chambers, Bill Self Meeting Transcript 

(ML081160468) 

Chinn, Jason Self Email (ML081510688) 

Clark, Gerald Board Of County Commissioners, Calvert 

County 

Letter (ML081160363) 

Clark, Kevin Self Email (ML081510783) 

Clark, Loralee Self Email (ML081510703) 

Cleaver, Melissa Self Email (ML081510602) 

Coster, Steven Self Email (ML081510519) 

Cox, Duncan Self Email (ML081510667) 

Crawley, Jackie Self Email (ML081510791) 

Crocca, Carol Self Email (ML081510641) 

Culp, Richard Self Email (ML081510672) 

Curington, Diana Self Email (ML081510725) 

Daddy, Big [per email] Self Email (ML081510784) 

Darbyshire, David Self Email (ML081510792) 

DesHarnais, Gaston Self Email (ML081510651) 

Diaz, Lorenzo Self Email (ML081510638) 

Dolly, William Self Email (ML081510637) 

Donn, Marjory Self Letter (ML0808404265) 

Dubois, Gwen Physicians for Social Responsibility Meeting Transcript 

(ML081160468) 

Dufay, Frank Self Email (ML081510627) 

Emmons, Cheryl Self Email (ML081510697) 

Erdesohn, Cynthia Self Email (ML081510721) 

Evans, Michael Self Email (ML081510628) 
Appendix D 

Draft NUREG-1936 D-6 April 2010 

Table D-1. (contd)

Commenter Affiliation (if stated)

Comment Source and 

ADAMS Accession #

Faigle, Susan Self Email (ML081510609) 

Fernow, Geoff Self Email (ML081510679) 

Finnelli, Marilyn and 

Tom 

Self Email (ML081510685) 

Fisher, Allison Self Email (ML081510544) 

Foppe, Paul Self Email (ML081510686) 

Fuller, Alfred Self Email (ML081510539) 

Futterer, Joe Self Email (ML081510524) 

Gaffney-Smith, 

Margaret 

Department of the Army Letter (ML0811302781) 

Gannaway, Gloria Self Email (ML081510526) 

Garbato, Kelly Self Email (ML081510622) 

Garner, Patrick Self Email (ML081510678) 

Garrett, Nick Calvert County Tourism Advisory Commission Meeting Transcript 

(ML081160468) 

Gilpin, John Self Email (ML081510709) 

Good, Riana Self Email (ML081510528) 

Goodrich, Anne Self Email (ML081510536) 

Grad, Robert Self Email (ML081510582) 

Grand, Robert Self Email (ML081510608) 

Grassi, Rosemarie Self Email (ML081510796) 

Gray, Susan Maryland Department of Natural Resources Letter (ML0811302840) 

Green, Bonnie Patuxent Partnership Meeting Transcript 

(ML081160460) 

Guay-Brezner, Colette Self Email (ML081510580) 

Gunter, Paul Nuclear Information and Research Service Meeting Transcript 

(ML081160468) 

Harberson, Laurie Self Email (ML081510639) 

Hauck, Molly Self Email (ML081510587) 
Appendix D 

April 2010 D-7 Draft NUREG-1936 

Table D-1. (contd)

Commenter Affiliation (if stated)

Comment Source and 

ADAMS Accession #

Hedlund, Cara Self Email (ML081510732) 

Helvick, Steven Self Email (ML081510726) 

Henderson, Sherry Self Email (ML081510777) 

Hinton, Georgia Self Email (ML081510574) 

Hodge, Gary Tri-County Council for Southern Maryland Letter (ML081130650) 

Hoffman, Lilli Self Email (ML081510569) 

Holzer, Frederick Self Email (ML081510664) 

Hood, Marilyn Self Email (ML081510605) 

Hooker, Betsy Self Email (ML081510778) 

Huffman, Debbie Self Email (ML081510643) 

Hughey, Patricia Self Email (ML081510648) 

Hung, Shiu Self Email (ML081510541) 

Hunter, Theresa Self Meeting Transcript 

(ML081160460) 

Hutchinson, Richard Self Email (ML081510720) 

Ireland, John Self Email (ML081510694) 

Johnston, Bill Meeting Transcript 

(ML081160460) 

Jones, Hollis Self Email (ML081510572) 

Jones-Giampalo, Mary Self Email (ML081510702) 

Joos, Sandra Self Email (ML081510530) 

Jula, Patty Self Email (ML081510547) 

Kaliski, Raymond Self Email (ML081510590) 

Kamps, Kevin Beyond Nuclear Meeting Transcript 

(ML081160468) 

Kanaley, Mike Clean and Safe Energy Coalition Meeting Transcript 

(ML081160468) 

Kane, Donna Self Email (ML081510588) 

Karbowsky, Brad United Association of Plumbers, Steamfitters, Meeting Transcript 
Appendix D 

Draft NUREG-1936 D-8 April 2010 

Table D-1. (contd)

Commenter Affiliation (if stated)

Comment Source and 

ADAMS Accession #

and Sprinkler fitters (ML081160468) 

Katz, Shari Self Email (ML081510607) 

Kelley, Linda Calvert County Board of Commissioners Letter (ML081160363) 

Kjer, Timothy Self Email (ML081510520) 

Klusman, Eric Self Email (ML081510534) 

Knechel, David Self Email (ML081510550) 

Kramer, Loren Self Email (ML081510657) 

Kuintzle, Gaylene Self Email (ML081510738) 

Lack, Robert Self Email (ML081510537) 

Lallo, Patrick Self Email (ML081510680) 

LaLumia, Anne Marie Self Email (ML081510567) 

LaMonica, Francoise Self Email (ML081510592) 

Latham, Rhonda Self Email (ML081510789) 

LaVigne, Carole Self Email (ML081510625) 

Lee, Angela Self Email (ML081510674) 

Loew, Brenda Self Email (ML081510774) 

Luczkowiak, 

Christopher 

Self Email (ML081510645) 

M, Crystal [per email] Self Email (ML081510781) 

Mackall, Kimberly The Concerned Black Women of Calvert 

County, Inc. 

Email (ML081510770) 

MacNulty, Joy Self Email (ML081510675) 

Magee, L Self Email (ML081510730) 

Manske, Jill Self Email (ML081510646) 

Marcus, Jack David Self Email (ML081510797) 

Mariotte, Michael Nuclear Information and Resource Service for 

Chesapeake Safe Energy Coalition 

Meeting Transcript 

(ML081160460) 

Mariotte, Michael Nuclear Information and Resource Service for 

Chesapeake Safe Energy Coalition 

Email (ML081510772) 
Appendix D 

April 2010 D-9 Draft NUREG-1936 

Table D-1. (contd)

Commenter Affiliation (if stated)

Comment Source and 

ADAMS Accession #

Marks, John Self Email (ML081510689) 

Marsh, Rauni Self Email (ML081510603) 

Martins, Darren Calvert County Chamber of Commerce Meeting Transcript 

(ML081160460) 

Massey, Tom Self Email (ML081510671) 

McAndrew-Benevides, 

Elizabeth 

North American Young Generation in Nuclear Meeting Transcript 

(ML081160468) 

McArthur, Richard Self Email (ML081510676) 

McClure, Matthew Self Email (ML081510647) 

McCoy, Timothy Self Email (ML081510734) 

McGarvey, Sean Building and Construction Trades Department, 

AFL-CIO 

Meeting Transcript 

(ML081160460) 

McGough, Mike Self Meeting Transcript 

(ML081160460) 

McKenna, Chris Self Email (ML081510611) 

McKenna, Kathy Self Email (ML081510619) 

McKenna, Lauren Self Email (ML081510614) 

McKenna, Rick Self Email (ML081510615) 

Meadow, Karen Maryland Conservation Council Meeting Transcript 

(ML081160460) 

Meadow, Norman Maryland Conservation Council Email (ML081510706) 

Metz, Richard Self Email (ML081510629) 

Minault, Kent Self Email (ML081510690) 

Miranda, Tina Self Email (ML081510687) 

Moore, Kerry Self Email (ML081510773) 

Mostov, Liz Self Email (ML081510696) 

Munson, Clarence 

William 

Self Email (ML081510565) 

Nagle, Thomas Self Email (ML081510691) 
Appendix D 

Draft NUREG-1936 D-10 April 2010 

Table D-1. (contd)

Commenter Affiliation (if stated)

Comment Source and 

ADAMS Accession #

Nanfra, Freya Self Email (ML081510794) 

Nash, James Self Email (ML081510583) 

Nerode, Gregory Self Email (ML081510786) 

Neumann, Johanna Maryland Public Interest Group Meeting Transcript 

(ML081160468) 

Novick, Wesley Self Email (ML081510624) 

Nunez, Albert Self Email (ML081510571) 

Nunez, Carlos Self Email (ML081510559) 

Oakes, Bonnie Self Email (ML081510561) 

O'Donnell, Anthony The Maryland House of Delegates Letter (ML081160364) 

Olmstead, Harry Self Email (ML081510707) 

O'Meara, Patrick Self Email (ML081510682) 

Pacheco-Theard, 

Lauren 

Self Email (ML081510700) 

Paquet, Kevin Self Email (ML081510633) 

Parran, Wilson Calvert County Board of Commissioners Meeting Transcript 

(ML081160468) 

Parsons, Barry Self Email (ML081510718) 

Paul, Georgia Self Email (ML081510782) 

Pedraza-Tucker, Liette Self Email (ML081510535) 

Petkiewicz, Margaret Self Email (ML081510553) 

Phipps, Donald Self Email (ML081510548) 

Piner, Lisa Self Email (ML081510542) 

Piser, Daniel Self Email (ML081510538) 

Polya, Lance Self Email (ML081510681) 

Pope, Nate Calvert County Economic Development 

Commission 

Meeting Transcript 

(ML081160468) 

Pretto-Simmons, 

Nancy 

Self Meeting Transcript 

(ML081160460) 
Appendix D 

April 2010 D-11 Draft NUREG-1936 

Table D-1. (contd)

Commenter Affiliation (if stated)

Comment Source and 

ADAMS Accession #

Putney, Louis Self Email (ML081510564) 

Rader, Nancy Self Email (ML081510555) 

Radford Jr., Roger Self Email (ML081510556) 

Raines, Mary Self Email (ML081510636) 

Ramstrom, Eric G and 

Shirley S 

Self Email (ML081510658) 

Randall, David Self Email (ML081510665) 

Rankin, Susan Self Email (ML081510670) 

Reidenbach, Gregory Self Email (ML081510790) 

Rosenblum, Stephen Self Email (ML081510699) 

Ross, Anne Self Email (ML081510788) 

Rudy, Mike Self Email (ML081510522) 

Russell, Jack St. Mary's County Commissioners Meeting Transcript 

(ML081160460) 

Sather, Alice Self Email (ML081510708) 

Sauer, Elizabeth Self Email (ML081510563) 

Scarafia, Bill St. Mary's County Chamber of Commerce Meeting Transcript 

(ML081160460) 

Schlager, Robert Calvert Memorial Hospital Meeting Transcript 

(ML081160468) 

Schmidt, Jason Self Email (ML081510531) 

Schopp, Ricky Self Email (ML081510787) 

Schwarz, Walter Self Email (ML081510626) 

See, Bud Self Email (ML081510660) 

Shafer, Scott Self Email (ML081510606) 

Shannahan, Brittany Self Email (ML081510545) 

Shashani, Linda Self Email (ML081510662) 

Shaw, Susan Board of County Commissioners, Calvert 

County 

Letter (ML081160363) 
Appendix D 

Draft NUREG-1936 D-12 April 2010 

Table D-1. (contd)

Commenter Affiliation (if stated)

Comment Source and 

ADAMS Accession #

Sherrow, Sarah Self Email (ML081510655) 

Shively, Daniel Self Email (ML081510731) 

Siecke, Martin Self Email (ML081510557) 

Simila, Owen Self Email (ML081510653) 

Sinclair, Jim Self Meeting Transcript 

(ML081160460) 

Skercevic, Maria Self Email (ML081510558) 

Smith, Enoch Self Email (ML081510552) 

Smith, Martha Self Email (ML081510656) 

Snowden, Patricia Self Email (ML081510570) 

Sorin, Susanna Self Email (ML081510597) 

Soroos, Marvin S Self Email (ML081510663) 

Soto, Yvonne Self Email (ML081510733) 

Stevens, Denise Self Email (ML081510723) 

Stilwell, Lisa Self Email (ML081510722) 

Stinnett, Barbara Board of County Commissioners, Calvert 

County 

Letter (ML081160363) 

Strange, Linda Self Email (ML081510540) 

Tarhan, Diane Solomons Business Association Meeting Transcript 

(ML081160460) 

Theil, Tony Self Email (ML081510620) 

Thiele, Abhaya Self Email (ML081510576) 

Tornatore, James Self Email (ML081510683) 

Trenholme, Art Self Email (ML081510669) 

Tucker, Dawn Calvert County Minority Business Alliance Email (ML081510768) 

Turner, Tamisha Self Email (ML081510589) 

Valliere, Cliff Self Email (ML081510737) 

Vanderheyden, 

George 

Unistar Nuclear Energy Meeting Transcript 

(ML081160468) 
Appendix D 

April 2010 D-13 Draft NUREG-1936 

Table D-1. (contd)

Commenter Affiliation (if stated)

Comment Source and 

ADAMS Accession #

VanEtten, Margot Self Email (ML081510701) 

Vieg, Jeannette Self Email (ML081510573) 

Voeller, Estelle Self Email (ML081510577) 

Vogt, Peter Self Email (ML081510516) 

Wadkins, Melanie Self Email (ML081510551) 

Waldman, Sam Self Email (ML081510529) 

Walker-Meere, Susan Self Email (ML081510724) 

Walsh, Donald Self Email (ML081510533) 

Walters, Betty Self Email (ML081510719) 

Walther, Robert Clean and Safe Energy Coalition Meeting Transcript 

(ML081160460) 

Wanner, Gabrielle Self Email (ML081510523) 

Ward, John Self Email (ML081510727) 

Welch, Irene Self Email (ML081510775) 

Wilkins, Paul Self Email (ML081510584) 

Willoughby, CaraLea Self Email (ML081510566) 

Wilson, Deb Self Email (ML081510710) 

Yeatts, Jordan Self Email (ML081510780) 

Zahniser, Albert Self Letter (ML081160362) 

Zastawecky, Margaret Self Email (ML081510769) 

Zelikson, Linda Self Email (ML081510644) 
Appendix D 

Draft NUREG-1936 D-14 April 2010 

1 Table D-2. Comment Categories 

Comment 

Category Commenter (Comment ID)

Accidents • Acevedo, NK (0008-3) 

• Aitken, Keith (0008-3) 

• Albright, Evan (0008-3) 

• Andereson, David (0008-3) 

• Arist, Phyllis (0008-3) 

• Armas, Zoe (0008-3) 

• Avance, Kenneth (0008-3) 

• Bainum, Meghan (0008-3) 

• Bakalian, Craig (0008-3) 

• Baldwin, Natylie (0008-3) 

• Barr, Phillip (0008-3) 

• Bartholomew, Alice (0008-3) 

• Be, Maya (0008-3) 

• Becker, Rochelle (0008-3) 

• Bedding, Gerhard (0008-3) 

• Behabadi, Bardia (0008-3) 

• Bissonnette, Rick (0008-3) 

• Black, Monica Latka (0008-3) 

• Blomstrom, Eric (0008-3) 

• Borrowman, Ellen (0008-3) 

• Briggs, Ruth (0008-3) 

• C, Suzy (0008-3) 

• Chinn, Jason (0008-3) 

• Clark, Kevin (0008-3) 

• Clark, Loralee (0008-3) 

• Cleaver, Melissa (0008-3) 

• Cox, Duncan (0008-3) 

• Crawley, Jackie (0008-3) 

• Crocca, Carol (0008-3) 

• Culp, Richard (0008-3) 

• Curington, Diana (0008-3) 

• Daddy, Big (0008-3) 

• Darbyshire, David (0008-3) 

• DesHarnais, Gaston (0008-3) 

• Diaz, Lorenzo (0008-3) 

• Dolly, William (0008-3) 

2 
Appendix D 

April 2010 D-15 Draft NUREG-1936 

Table D-2. (contd) 

Comment 

Category Commenter (Comment ID)

• Emmons, Cheryl (0008-3) 

• Erdesohn, Cynthia (0008-3) 

• Evans, Michael (0008-3) 

• Faigle, Susan (0008-3) 

• Fernow, Geoff (0008-3) 

• Finnelli, Marilyn and Tom (0008-3) 

• Fisher, Allison (0008-3) 

• Foppe, Paul (0008-3) 

• Fuller, Alfred (0008-3) 

• Futterer, Joe (0008-3) 

• Gannaway, Gloria (0008-3) 

• Garbato, Kelly (0008-3) 

• Garner, Patrick (0008-3) 

• Gilpin, John (0008-3) 

• Good, Riana (0008-3) 

• Goodrich, Anne (0008-3) 

• Grad, Robert (0008-3) 

• Grand, Robert (0008-3) 

• Grassi, Rosemarie (0008-3) 

• Guay-Brezner, Colette (0008-3) 

• Harberson, Laurie (0008-3) 

• Hauck, Molly (0008-3) 

• Hedlund, Cara (0008-3) 

• Helvick, Steven (0008-3) 

• Henderson, Sherry (0008-3) 

• Hinton, Georgia (0008-3) 

• Hoffman, Lilli (0008-3) 

• Holzer, Frederick (0008-3) 

• Hood, Marilyn (0008-3) 

• Hooker, Betsy (0008-3) 

• Huffman, Debbie (0008-3) 

• Hughey, Patricia (0008-3) 

• Hung, Shiu (0008-3) 

• Hutchinson, Richard (0008-3) 

• Jones, Hollis (0008-3) 

• Jones-Giampalo, Mary (0008-3) 

• Joos, Sandra (0008-3) 

• Jula, Patty (0008-3) 
Appendix D 

Draft NUREG-1936 D-16 April 2010 

Table D-2. (contd) 

Comment 

Category Commenter (Comment ID)

• Kaliski, Raymond (0008-3) 

• Kamps, Kevin (0024-76) (0024-77) (0024-79) (0024-84) 

• Kane, Donna (0008-3) 

• Katz, Shari (0008-3) 

• Klusman, Eric (0008-3) 

• Knechel, David (0008-3) 

• Kramer, Loren (0008-3) 

• Kuintzle, Gaylene (0008-3) 

• Lack, Robert (0008-3) 

• Lallo, Patrick (0008-3) 

• LaLumia, Anne Marie (0008-3) 

• LaMonica, Francoise (0008-3) 

• Latham, Rhonda (0008-3) 

• LaVigne, Carole (0008-3) 

• Lee, Angela (0008-3) 

• Loew, Brenda (0008-3) 

• Luczkowiak, Christopher (0008-3) 

• M, Crystal (0008-3) 

• Mackall, Kimberly (0018-1) (0018-9) 

• MacNulty, Joy (0008-3) 

• Magee, L (0008-3) 

• Manske, Jill (0008-3) 

• Marcus, Jack David (0008-3) 

• Mariotte, Michael (0019-7) (0019-8) 

• Mariotte, Michael (0019-18) (0019-19) (0019-23) (0025-43) 

• Marks, John (0008-3) 

• Marsh, Rauni (0008-3) (0026-3) 

• Massey, Tom (0008-3) 

• McArthur, Richard (0008-3) 

• McClure, Matthew (0008-3) 

• McCoy, Timothy (0008-3) 

• McKenna, Chris (0008-3) 

• McKenna, Kathy (0008-3) 

• McKenna, Lauren (0008-3) 

• McKenna, Rick (0008-3) 

• Metz, Richard (0008-3) 

• Minault, Kent (0008-3) 

• Miranda, Tina (0008-3) 
Appendix D 

April 2010 D-17 Draft NUREG-1936 

Table D-2. (contd) 

Comment 

Category Commenter (Comment ID)

• Moore, Kerry (0008-3) 

• Mostov, Liz (0008-3) 

• Munson, Clarence William (0008-3) 

• Nagle, Thomas (0008-3) 

• Nanfra, Freya (0008-3) 

• Nash, James (0008-3) 

• Nerode, Gregory (0008-3) 

• Novick, Wesley (0008-3) 

• Nunez, Albert (0008-3) 

• Nunez, Carlos (0008-3) 

• Oakes, Bonnie (0008-3) 

• Olmstead, Harry (0008-3) 

• O'Meara, Patrick (0008-3) 

• Pacheco-Theard, Lauren (0008-3) 

• Paquet, Kevin (0008-3) 

• Parsons, Barry (0008-3) 

• Paul, Georgia (0008-3) 

• Pedraza-Tucker, Liette (0008-3) 

• Petkiewicz, Margaret (0008-3) 

• Phipps, Donald (0008-3) 

• Piner, Lisa (0008-3) 

• Piser, Daniel (0008-3) 

• Putney, Louis (0008-3) 

• Rader, Nancy (0008-3) 

• Radford Jr., Roger (0008-3) 

• Raines, Mary (0008-3) 

• Ramstrom, Eric G and Shirley S (0008-3) 

• Randall, David (0008-3) 

• Rankin, Susan (0008-3) 

• Reidenbach, Gregory (0008-3) 

• Rosenblum, Stephen (0008-3) 

• Ross, Anne (0008-3) 

• Sather, Alice (0008-3) 

• Sauer, Elizabeth (0008-3) 

• Schmidt, Jason (0008-3) 

• Schopp, Ricky (0008-3) 

• Schwarz, Walter (0008-3) 

• See, Bud (0008-3) 
Appendix D 

Draft NUREG-1936 D-18 April 2010 

Table D-2. (contd) 

Comment 

Category Commenter (Comment ID)

• Shafer, Scott (0008-3) 

• Shashani, Linda (0008-3) 

• Sherrow, Sarah (0008-3) 

• Shively, Daniel (0008-3) 

• Siecke, Martin (0008-3) 

• Simila, Owen (0008-3) 

• Skercevic, Maria (0008-3) 

• Smith, Enoch (0008-3) 

• Smith, Martha (0008-3) 

• Snowden, Patricia (0008-3) 

• Sorin, Susanna (0008-3) 

• Soroos, Marvin S (0008-3) 

• Soto, Yvonne (0008-3) 

• Stevens, Denise (0008-3) 

• Stilwell, Lisa (0008-3) 

• Strange, Linda (0008-3) 

• Theil, Tony (0008-3) 

• Thiele, Abhaya (0008-3) 

• Tornatore, James (0008-3) 

• Trenholme, Art (0008-3) 

• Turner, Tamisha (0008-3) 

• Valliere, Cliff (0008-3) 

• VanEtten, Margot (0008-3) 

• Vieg, Jeannette (0008-3) 

• Voeller, Estelle (0008-3) 

• Wadkins, Melanie (0008-3) 

• Waldman, Sam (0008-3) 

• Walker-Meere, Susan (0008-3) 

• Walsh, Donald (0008-3) 

• Walters, Betty (0008-3) 

• Wanner, Gabrielle (0008-3) 

• Ward, John (0008-3) 

• Welch, Irene (0008-3) 

• Wilkins, Paul (0008-3) 

• Willoughby, CaraLea (0008-3) 

• Wilson, Deb (0008-3) 

• Yeatts, Jordan (0008-3) 

• Zastawecky, Margaret (0008-3) 
Appendix D 

April 2010 D-19 Draft NUREG-1936 

Table D-2. (contd) 

Comment 

Category Commenter (Comment ID)

• Zelikson, Linda (0008-3) 

AlternativesEnergy 

• Donn, Marjory (0020-1) (0020-8) 

• Dubois, Gwen (0024-60) 

• Hunter, Theresa (0025-160) (0025-161) 

• Johnston, Bill (0025-109) (0025-110) (0025-113) 

• Kamps, Kevin (0024-80) (0024-81) (0024-82) 

• Kanaley, Mike (0024-22) 

• Mariotte, Michael (0019-4) 

• Marsh, Rauni (0026-2) (0026-5) 

• McGarvey, Sean (0025-145) 

• Meadow, Karen (0025-65) (0025-67) (0025-68) (0025-69) (0025-70) 

(0025-71) (0025-72) (0025-73) 

• Meadow, Norman (0028-1) (0028-4) (0028-6) (0028-7) (0028-9) (0028-

10) (0028-11) (0028-12) (0028-13) (0028-14) (0028-15) (0028-16) (0028-

17) (0028-18) (0028-19) (0028-20) (0028-21) (0028-34) 

• Neumann, Johanna (0024-34) (0024-36) 

• Parran, Wilson (0024-9) (0024-10) (0025-11) (0025-12) 

• Shannahan, Brittany (0007-5) 

• Sinclair, Jim (0025-140) (0025-141) 

• Vogt, Peter (0005-19) (0005-23) (0005-25) (0005-26) (0005-27) (0005-

29) 

• Walther, Robert (0025-120) 

Alternatives-NoAction 

• Mariotte, Michael (0019-5) (0025-47) 

• McGarvey, Sean (0025-146) (0025-147) 

Benefit-Cost 

Balance 

• Donn, Marjory (0020-3) 

• Fisher, Allison (0025-91) 

• Kamps, Kevin (0024-78) (0024-89) (0024-90) 

• Mariotte, Michael (0019-1) (0019-2) (0019-3) (0025-48) (0025-49) 

• Meadow, Karen (0025-66) 

• Meadow, Norman (0028-26) (0028-27) 

• Neumann, Johanna (0024-37) 

• Vanderheyden, George (0024-116) 

• Vogt, Peter (0005-28) 

Cumulative 

Impacts 

• Buchanan, Bill (0024-109) 

Ecology-Terrestrial • Meadow, Norm (0025-59) (0028-2) 
Appendix D 

Draft NUREG-1936 D-20 April 2010 

Table D-2. (contd) 

Comment 

Category Commenter (Comment ID)

• Vogt, Peter (0005-13) 

Environmental 

Justice 

• Mackall, Kimberly (0018-2) (0018-3) 

Geology • Mariotte, Michael (0019-35) 

Health-Radiological • Dubois, Gwen (0024-68) 

• Mackall, Kimberly (0018-10) 

• Mariotte, Michael (0019-17) (0019-22) (0025-53) 

• Meadow, Norm (0025-57) (0025-58) (0028-5) (0028-28) (0028-29) (0028-

30) (0028-31) (0028-32) (0028-33) 

• Shannahan, Brittany (0007-3) 

Historic and 

Cultural Resources 

• Fisher, Allison (0025-94) 

Hydrology-Surface 

Water 

• Baummer, Thomas (0006-4) (0006-7) 

• Buchanan, Bill (0024-110) (0024-110) 

• Fisher, Allison (0025-93) 

Land Use-Site and 

vicinity 

• Baummer, Thomas (0006-8) 

Land UseTransmission lines 

• Clark, Gerald (0014-2) 

• Kelley, Linda (0014-2) 

• Parran, Wilson (0014-2) (0024-4) (0025-5) 

• Shaw, Susan (0014-2) 

• Stinnett, Barbara (0014-2) 

• Vogt, Peter (0005-14) (0005-15) (0005-16) (0005-17) 

Meteorology and 

Air Quality 

• Baummer, Thomas (0006-5) (0006-6) 

• Mariotte, Michael (0019-29) (0019-30) (0019-31) (0025-45) (0025-46) 

Need for Power • Arndt, Gunter (0004-3) 

• Burton, Bob (0025-32) 

• Clark, Gerald (0014-3) 

• Green, Bonnie (0025-128) 

• Green, Joseph (0025-86) 

• Hodge, Gary (0023-3) 

• Hunter, Theresa (0025-162) 

• Kanaley, Mike (0024-21) 

• Kelley, Linda (0014-3) 
Appendix D 

April 2010 D-21 Draft NUREG-1936 

Table D-2. (contd) 

Comment 

Category Commenter (Comment ID)

• Meadow, Karen (0025-74) (0025-75) (0028-8) 

• Meadow, Norman (0028-22) (0028-23) (0028-24) 

• O'Donnell, Anthony (0015-2) 

• Parran, Wilson (0014-3) (0024-8) (0025-7) (0025-10) 

• Pretto-Simmons, Nancy (0025-166) 

• Russell, Jack (0025-22) 

• Scarafia, Bill (0025-83) 

• Shaw, Susan (0014-3) 

• Sinclair, Jim (0025-139) 

• Stinnett, Barbara (0014-3) 

• Vogt, Peter (0005-20) (0005-21) (0005-22) 

• Walther, Robert (0025-118) (0025-119) 

• Zahniser, Albert (0016-3) 

Process-ESP-COL • Baummer, Thomas (0006-2) (0006-3) 

• Brown, Jr., Edsel (0017-1) 

• Coster, Steven (0003-1) 

• Fisher, Allison (0025-88) (0025-89) (0025-90) 

• Gaffney-Smith, Margaret (0021-1) (0021-2) 

• Gray, Susan (0022-1) 

• Hodge, Gary (0024-15) (0025-107) 

• Kamps, Kevin (0024-88) 

• Kjer, Timothy (0003-1) 

• Mackall, Kimberly (0018-14) 

• Mariotte, Michael (0019-20) (0025-41) 

• Martins, Darren (0025-26) (0024-3) (0024-13) (0025-3) (0025-17) 

• Shannahan, Brittany (0003-1) 

Site Layout and 

Design 

• Parran, Wilson (0024-2) (0025-2) 

• Scarafia, Bill (0024-96) 

• Sinclair, Jim (0025-133) 

• Vanderheyden, George (0024-113) (0024-115) (0024-118) (0024-119) 

(0025-168) (0025-169) (0025-171) (0025-172) (0025-173) 

Socioeconomics • Boswell, William (0002-2) 

• Brown, Jr., Edsel (0017-7) (0017-9) 

• Burton, Bob (0025-35) (0025-36) (0025-37) (0025-38) 

• Chambers, Bill (0024-42) (0024-43) (0024-44) 

• Kanaley, Mike (0024-26) 

• Karbowsky, Brad (0024-107) (0025-78) (0025-80) 
Appendix D 

Draft NUREG-1936 D-22 April 2010 

Table D-2. (contd) 

Comment 

Category Commenter (Comment ID)

• McClure, Deborah (0024-29) 

• O'Donnell, Anthony (0015-5) 

• Parran, Wilson L. (0024-56) 

• Scarafia, Bill (0024-93) (0024-94) (0025-82) 

• Sinclair, Jim (0025-137) (0025-138) 

• Tarhan, Diane (0025-175) (0005-4) (0005-6) (0005-8) (0005-9) 

• Vogt, Peter (0005-10) (0005-11) (0005-12) 

• Walther, Robert (0025-123) 

Transportation • Acevedo, NK (0008-5) 

• Aitken, Keith (0008-5) 

• Albright, Evan (0008-5) 

• Andereson, David (0008-5) 

• Arist, Phyllis (0008-5) 

• Armas, Zoe (0008-5) 

• Avance, Kenneth (0008-5) 

• Bainum, Meghan (0008-5) 

• Bakalian, Craig (0008-5) 

• Baldwin, Natylie (0008-5) 

• Barr, Phillip (0008-5) 

• Bartholomew, Alice (0008-5) 

• Be, Maya (0008-5) 

• Becker, Rochelle (0008-5) 

• Bedding, Gerhard (0008-5) 

• Behabadi, Bardia (0008-5) 

• Bissonnette, Rick (0008-5) 

• Black, Monica Latka (0008-5) 

• Blomstrom, Eric (0008-5) 

• Borrowman, Ellen (0008-5) 

• Briggs, Ruth (0008-5) 

• Brown, Jr., Edsel (0017-2) 

• C, Suzy (0008-5) 

• Chinn, Jason (0008-5) 

• Clark, Kevin (0008-5) 

• Clark, Loralee (0008-5) 

• Cleaver, Melissa (0008-5) 

• Cox, Duncan (0008-5) 

• Crawley, Jackie (0008-5) 
Appendix D 

April 2010 D-23 Draft NUREG-1936 

Table D-2. (contd) 

Comment 

Category Commenter (Comment ID)

• Crocca, Carol (0008-5) 

• Culp, Richard (0008-5) 

• Curington, Diana (0008-5) 

• Daddy, Big (0008-5) 

• Darbyshire, David (0008-5) 

• DesHarnais, Gaston (0008-5) 

• Diaz, Lorenzo (0008-5) 

• Dolly, William (0008-5) 

• Donn, Marjory (0020-6) 

• Emmons, Cheryl (0008-5) 

• Erdesohn, Cynthia (0008-5) 

• Evans, Michael (0008-5) 

• Faigle, Susan (0008-5) 

• Fernow, Geoff (0008-5) 

• Finnelli, Marilyn and Tom (0008-5) 

• Fisher, Allison (0008-5) 

• Foppe, Paul (0008-5) 

• Fuller, Alfred (0008-5) 

• Futterer, Joe (0008-5) 

• Gannaway, Gloria (0008-5) 

• Garbato, Kelly (0008-5) 

• Garner, Patrick (0008-5) 

• Gilpin, John (0008-5) 

• Good, Riana (0008-5) 

• Goodrich, Anne (0008-5) 

• Grad, Robert (0008-5) 

• Grand, Robert (0008-5) 

• Grassi, Rosemarie (0008-5) 

• Guay-Brezner, Colette (0008-5) 

• Harberson, Laurie (0008-5) 

• Hauck, Molly (0008-5) 

• Hedlund, Cara (0008-5) 

• Helvick, Steven (0008-5) 

• Henderson, Sherry (0008-5) 

• Hinton, Georgia (0008-5) 

• Hoffman, Lilli (0008-5) 

• Holzer, Frederick (0008-5) 

• Hood, Marilyn (0008-5) 
Appendix D 

Draft NUREG-1936 D-24 April 2010 

Table D-2. (contd) 

Comment 

Category Commenter (Comment ID)

• Hooker, Betsy (0008-5) 

• Huffman, Debbie (0008-5) 

• Hughey, Patricia (0008-5) 

• Hung, Shiu (0008-5) 

• Hutchinson, Richard (0008-5) 

• Jones, Hollis (0008-5) 

• Jones-Giampalo, Mary (0008-5) 

• Joos, Sandra (0008-5) 

• Jula, Patty (0008-5) 

• Kaliski, Raymond (0008-5) 

• Kamps, Kevin (0025-100) (0025-101) (0025-102) 

• Kane, Donna (0008-5) 

• Katz, Shari (0008-5) 

• Klusman, Eric (0008-5) 

• Knechel, David (0008-5) 

• Kramer, Loren (0008-5) 

• Kuintzle, Gaylene (0008-5) 

• Lack, Robert (0008-5) 

• Lallo, Patrick (0008-5) 

• LaLumia, Anne Marie (0008-5) 

• LaMonica, Francoise (0008-5) 

• Latham, Rhonda (0008-5) 

• LaVigne, Carole (0008-5) 

• Lee, Angela (0008-5) 

• Loew, Brenda (0008-5) 

• Luczkowiak, Christopher (0008-5) 

• M, Crystal (0008-5) 

• MacNulty, Joy (0008-5) 

• Magee, L (0008-5) 

• Manske, Jill (0008-5) 

• Marcus, Jack David (0008-5) 

• Mariotte, Michael (0019-10) (0019-12) 

• Marks, John (0008-5) 

• Marsh, Rauni (0008-5) 

• Massey, Tom (0008-5) 

• McArthur, Richard (0008-5) 

• McClure, Matthew (0008-5) 

• McCoy, Timothy (0008-5) 
Appendix D 

April 2010 D-25 Draft NUREG-1936 

Table D-2. (contd) 

Comment 

Category Commenter (Comment ID)

• McKenna, Chris (0008-5) 

• McKenna, Kathy (0008-5) 

• McKenna, Lauren (0008-5) 

• McKenna, Rick (0008-5) 

• Meadow, Norm (0025-63) 

• Meadow, Norman (0028-37) (0028-38) 

• Metz, Richard (0008-5) 

• Minault, Kent (0008-5) 

• Miranda, Tina (0008-5) 

• Moore, Kerry (0008-5) 

• Mostov, Liz (0008-5) 

• Munson, Clarence William (0008-5) 

• Nagle, Thomas (0008-5) 

• Nanfra, Freya (0008-5) 

• Nash, James (0008-5) 

• Nerode, Gregory (0008-5) 

• Novick, Wesley (0008-5) 

• Nunez, Albert (0008-5) 

• Nunez, Carlos (0008-5) 

• Oakes, Bonnie (0008-5) 

• Olmstead, Harry (0008-5) 

• O'Meara, Patrick (0008-5) 

• Pacheco-Theard, Lauren (0008-5) 

• Paquet, Kevin (0008-5) 

• Parsons, Barry (0008-5) 

• Paul, Georgia (0008-5) 

• Pedraza-Tucker, Liette (0008-5) 

• Petkiewicz, Margaret (0008-5) 

• Phipps, Donald (0008-5) 

• Piner, Lisa (0008-5) 

• Piser, Daniel (0008-5) 

• Putney, Louis (0008-5) 

• Rader, Nancy (0008-5) 

• Radford Jr., Roger (0008-5) 

• Raines, Mary (0008-5) 

• Ramstrom, Eric G and Shirley S (0008-5) 

• Randall, David (0008-5) 

• Rankin, Susan (0008-5) 
Appendix D 

Draft NUREG-1936 D-26 April 2010 

Table D-2. (contd) 

Comment 

Category Commenter (Comment ID)

• Reidenbach, Gregory (0008-5) 

• Rosenblum, Stephen (0008-5) 

• Ross, Anne (0008-5) 

• Sather, Alice (0008-5) 

• Sauer, Elizabeth (0008-5) 

• Schmidt, Jason (0008-5) 

• Schopp, Ricky (0008-5) 

• Schwarz, Walter (0008-5) 

• See, Bud (0008-5) 

• Shafer, Scott (0008-5) 

• Shashani, Linda (0008-5) 

• Sherrow, Sarah (0008-5) 

• Shively, Daniel (0008-5) 

• Siecke, Martin (0008-5) 

• Simila, Owen (0008-5) 

• Skercevic, Maria (0008-5) 

• Smith, Enoch (0008-5) 

• Smith, Martha (0008-5) 

• Snowden, Patricia (0008-5) 

• Sorin, Susanna (0008-5) 

• Soroos, Marvin S (0008-5) 

• Soto, Yvonne (0008-5) 

• Stevens, Denise (0008-5) 

• Stilwell, Lisa (0008-5) 

• Strange, Linda (0008-5) 

• Theil, Tony (0008-5) 

• Thiele, Abhaya (0008-5) 

• Tornatore, James (0008-5) 

• Trenholme, Art (0008-5) 

• Turner, Tamisha (0008-5) 

• Valliere, Cliff (0008-5) 

• VanEtten, Margot (0008-5) 

• Vieg, Jeannette (0008-5) 

• Voeller, Estelle (0008-5) 

• Wadkins, Melanie (0008-5) 

• Waldman, Sam (0008-5) 

• Walker-Meere, Susan (0008-5) 

• Walsh, Donald (0008-5) 
Appendix D 

April 2010 D-27 Draft NUREG-1936 

Table D-2. (contd) 

Comment 

Category Commenter (Comment ID)

• Walters, Betty (0008-5) 

• Wanner, Gabrielle (0008-5) 

• Ward, John (0008-5) 

• Welch, Irene (0008-5) 

• Wilkins, Paul (0008-5) 

• Willoughby, CaraLea (0008-5) 

• Wilson, Deb (0008-5) 

• Yeatts, Jordan (0008-5) 

• Zastawecky, Margaret (0008-5) 

• Zelikson, Linda (0008-5) 

Uranium Fuel 

Cycle 

• Acevedo, NK (0008-1) (0008-2) (0008-4) (0008-6) 

• Aitken, Keith (0008-1) (0008-2) (0008-4) (0008-6) 

• Albright, Evan (0008-1) (0008-2) (0008-4) (0008-6) 

• Andereson, David (0008-1) (0008-2) (0008-4) (0008-6) 

• Arist, Phyllis (0008-1) (0008-2) (0008-4) (0008-6) 

• Armas, Zoe (0008-1) (0008-2) (0008-4) (0008-6) 

• Arndt, Gunter (0004-5) 

• Avance, Kenneth (0008-1) (0008-2) (0008-4) (0008-6) 

• Bainum, Meghan (0008-1) (0008-2) (0008-4) (0008-6) 

• Bakalian, Craig (0008-1) (0008-2) (0008-4) (0008-6) 

• Baldwin, Natylie (0008-1) (0008-2) (0008-4) (0008-6) 

• Barr, Phillip (0008-1) (0008-2) (0008-4) (0008-6) 

• Bartholomew, Alice (0008-1) (0008-2) (0008-4) (0008-6) 

• Be, Maya (0008-1) (0008-2) (0008-4) (0008-6) 

• Becker, Rochelle (0008-1) (0008-2) (0008-4) (0008-6) 

• Bedding, Gerhard (0008-1) (0008-2) (0008-4) (0008-6) 

• Behabadi, Bardia (0008-1) (0008-2) (0008-4) (0008-6) 

• Bissonnette, Rick (0008-1) (0008-2) (0008-4) (0008-6) 

• Black, Monica Latka (0008-1) (0008-2) (0008-4) (0008-6) 

• Blomstrom, Eric (0008-1) (0008-2) (0008-4) (0008-6) 

• Borrowman, Ellen (0008-1) (0008-2) (0008-4) (0008-6) 

• Boxwell, Bob (0025-159) 

• Briggs, Ruth (0008-1) (0008-2) (0008-4) (0008-6) 

• C, Suzy (0008-1) (0008-2) (0008-4) (0008-6) 

• Chinn, Jason (0008-1) (0008-2) (0008-4) (0008-6) 

• Clark, Kevin (0008-1) (0008-2) (0008-4) (0008-6) 

• Clark, Loralee (0008-1) (0008-2) (0008-4) (0008-6) 
Appendix D 

Draft NUREG-1936 D-28 April 2010 

Table D-2. (contd) 

Comment 

Category Commenter (Comment ID)

• Cleaver, Melissa (0008-1) (0008-2) (0008-4) (0008-6) 

• Cox, Duncan (0008-1) (0008-2) (0008-4) (0008-6) 

• Crawley, Jackie (0008-1) (0008-2) (0008-4) (0008-6) 

• Crocca, Carol (0008-1) (0008-2) (0008-4) (0008-6) 

• Culp, Richard (0008-1) (0008-2) (0008-4) (0008-6) 

• Curington, Diana (0008-1) (0008-2) (0008-4) (0008-6) 

• Daddy, Big (0008-1) (0008-2) (0008-4) (0008-6) 

• Darbyshire, David (0008-1) (0008-2) (0008-4) (0008-6) 

• DesHarnais, Gaston (0008-1) (0008-2) (0008-4) (0008-6) 

• Diaz, Lorenzo (0008-1) (0008-2) (0008-4) (0008-6) 

• Dolly, William (0008-1) (0008-2) (0008-4) (0008-6) 

• Donn, Marjory (0020-2) (0020-5) 

• Emmons, Cheryl (0008-1) (0008-2) (0008-4) (0008-6) 

• Erdesohn, Cynthia (0008-1) (0008-2) (0008-4) (0008-6) 

• Evans, Michael (0008-1) (0008-2) (0008-4) (0008-6) 

• Faigle, Susan (0008-1) (0008-2) (0008-4) (0008-6) 

• Fernow, Geoff (0008-1) (0008-2) (0008-4) (0008-6) 

• Finnelli, Marilyn and Tom (0008-1) (0008-2) (0008-4) (0008-6) 

• Fisher, Allison (0008-1) (0008-2) (0008-4) (0008-6) 

• Foppe, Paul (0008-1) (0008-2) (0008-4) (0008-6) 

• Fuller, Alfred (0008-1) (0008-2) (0008-4) (0008-6) 

• Futterer, Joe (0008-1) (0008-2) (0008-4) (0008-6) 

• Gannaway, Gloria (0008-1) (0008-2) (0008-4) (0008-6) 

• Garbato, Kelly (0008-1) (0008-2) (0008-4) (0008-6) 

• Garner, Patrick (0008-1) (0008-2) (0008-4) (0008-6) 

• Gilpin, John (0008-1) (0008-2) (0008-4) (0008-6) 

• Good, Riana (0008-1) (0008-2) (0008-4) (0008-6) 

• Goodrich, Anne (0008-1) (0008-2) (0008-4) (0008-6) 

• Grad, Robert (0008-1) (0008-2) (0008-4) (0008-6) 

• Grand, Robert (0008-1) (0008-2) (0008-4) (0008-6) 

• Grassi, Rosemarie (0008-1) (0008-2) (0008-4) (0008-6) 

• Guay-Brezner, Colette (0008-1) (0008-2) (0008-4) (0008-6) 

• Harberson, Laurie (0008-1) (0008-2) (0008-4) (0008-6) 

• Hauck, Molly (0008-1) (0008-2) (0008-4) (0008-6) 

• Hedlund, Cara (0008-1) (0008-2) (0008-4) (0008-6) 

• Helvick, Steven (0008-1) (0008-2) (0008-4) (0008-6) 

• Henderson, Sherry (0008-1) (0008-2) (0008-4) (0008-6) 

• Hinton, Georgia (0008-1) (0008-2) (0008-4) (0008-6) 
Appendix D 

April 2010 D-29 Draft NUREG-1936 

Table D-2. (contd) 

Comment 

Category Commenter (Comment ID)

• Hoffman, Lilli (0008-1) (0008-2) (0008-4) (0008-6) 

• Holzer, Frederick (0008-1) (0008-2) (0008-4) (0008-6) 

• Hood, Marilyn (0008-1) (0008-2) (0008-4) (0008-6) 

• Hooker, Betsy (0008-1) (0008-2) (0008-4) (0008-6) 

• Huffman, Debbie (0008-1) (0008-2) (0008-4) (0008-6) 

• Hughey, Patricia (0008-1) (0008-2) (0008-4) (0008-6) 

• Hung, Shiu (0008-1) (0008-2) (0008-4) (0008-6) 

• Hutchinson, Richard (0008-1) (0008-2) (0008-4) (0008-6) 

• Ireland, John (0012-1) 

• Johnston, Bill (0025-111) 

• Jones, Hollis (0008-1) (0008-2) 0008-4) (0008-6) 

• Jones-Giampalo, Mary (0008-1) (0008-2) (0008-4) (0008-6) 

• Joos, Sandra (0008-1) (0008-2) (0008-4) (0008-6) 

• Jula, Patty (0008-1) (0008-2) (0008-4) (0008-6) 

• Kaliski, Raymond (0008-1) (0008-2) (0008-4) (0008-6) 

• Kamps, Kevin (0024-85) (0024-86) (0025-95) (0025-96) (0025-98) 

• Kane, Donna (0008-1) (0008-2) (0008-4) (0008-6) 

• Katz, Shari (0008-1) (0008-2) (0008-4) (0008-6) 

• Klusman, Eric (0008-1) Eric (0008-2) (0008-4) (0008-6) 

• Knechel, David (0008-1) (0008-2) (0008-4) (0008-6) 

• Kramer, Loren (0008-1) (0008-2) (0008-4) (0008-6) 

• Kuintzle, Gaylene (0008-1) (0008-2) (0008-4) (0008-6) 

• Lack, Robert (0008-1) (0008-2) (0008-4) (0008-6) 

• Lallo, Patrick (0008-1) (0008-2) (0008-4) (0008-6) 

• LaLumia, Anne Marie (0008-1) (0008-2) (0008-4) (0008-6) 

• LaMonica, Francoise (0008-1) (0008-2) (0008-4) (0008-6) 

• Latham, Rhonda (0008-1) (0008-2) (0008-4) (0008-6) 

• LaVigne, Carole (0008-1) (0008-2) (0008-4) (0008-6) 

• Lee, Angela (0008-1) (0008-2) (0008-4) (0008-6) 

• Loew, Brenda (0008-1) (0008-2) (0008-4) (0008-6) 

• Luczkowiak, Christopher (0008-1) (0008-2) (0008-4) (0008-6) 

• M, Crystal (0008-1) (0008-2) (0008-4) (0008-6) 

• Mackall, Kimberly (0018-4) 

• MacNulty, Joy (0008-1) (0008-2) (0008-4) (0008-6) 

• Magee, L (0008-1) (0008-2) (0008-4) (0008-6) 

• Manske, Jill (0008-1) (0008-2) (0008-4) (0008-6) 

• Marcus, Jack David (0008-1) (0008-2) (0008-4) (0008-6) (0019-6) 

• Mariotte, Michael (0019-9) (0019-13) (0019-14) (0019-15) (0019-16) 
Appendix D 

Draft NUREG-1936 D-30 April 2010 

Table D-2. (contd) 

Comment 

Category Commenter (Comment ID)

(0025-50) (0025-51) (0025-52) 

• Marks, John (0008-1) (0008-2) (0008-4) (0008-6) 

• Marsh, Rauni (0008-1) (0008-2) (0008-4) (0008-6) (0026-1) (0026-4) 

• Massey, Tom (0008-1) (0008-2) (0008-4) (0008-6) 

• McArthur, Richard (0008-1) (0008-2) (0008-4) (0008-6) 

• McClure, Matthew (0008-1) (0008-2) (0008-4) (0008-6) 

• McCoy, Timothy (0008-1) (0008-2) (0008-4) (0008-6) 

• McGough, Mike (0024-103) 

• McKenna, Chris (0008-1) (0008-2) (0008-4) (0008-6) 

• McKenna, Kathy (0008-1) (0008-2) (0008-4) (0008-6) 

• McKenna, Lauren (0008-1) (0008-2) (0008-4) (0008-6) 

• McKenna, Rick (0008-1) (0008-2) (0008-4) (0008-6) 

• Meadow, Norm (0025-61) (0025-62) 

• Meadow, Norman (0028-35) (0028-36) 

• Metz, Richard (0008-1) (0008-2) (0008-4) (0008-6) 

• Minault, Kent (0008-1) (0008-2) (0008-4) (0008-6) 

• Miranda, Tina (0008-1) (0008-2) (0008-4) (0008-6) 

• Moore, Kerry (0008-1) (0008-2) (0008-4) (0008-6) 

• Mostov, Liz (0008-1) (0008-2) (0008-4) (0008-6) 

• Munson, Clarence William (0008-1) (0008-2) (0008-4) (0008-6) 

• Nagle, Thomas (0008-1) (0008-2) (0008-4) (0008-6) 

• Nanfra, Freya (0008-1) (0008-2) (0008-4) (0008-6) 

• Nash, James (0008-1) (0008-2) (0008-4) (0008-6) 

• Nerode, Gregory (0008-1) (0008-2) (0008-4) (0008-6) 

• Novick, Wesley (0008-1) (0008-2) (0008-4) (0008-6) 

• Nunez, Albert (0008-1) (0008-2) (0008-4) (0008-6) 

• Nunez, Carlos (0008-1) (0008-2) (0008-4) (0008-6) 

• Oakes, Bonnie (0008-1) (0008-2) (0008-4) (0008-6) 

• Olmstead, Harry (0008-1) (0008-2) (0008-4) (0008-6) 

• O'Meara, Patrick (0008-1) (0008-2) (0008-4) (0008-6) 

• Pacheco-Theard, Lauren (0008-1) (0008-2) (0008-4) (0008-6) 

• Paquet, Kevin (0008-1) (0008-2) (0008-4) (0008-6) 

• Parsons, Barry (0008-1) (0008-2) (0008-4) (0008-6) 

• Paul, Georgia (0008-1) (0008-2) (0008-4) (0008-6) 

• Pedraza-Tucker, Liette (0008-1) (0008-2) (0008-4) (0008-6) 

• Petkiewicz, Margaret (0008-1) (0008-2) (0008-4) (0008-6) 

• Phipps, Donald (0008-1) (0008-2) (0008-4) (0008-6) 

• Piner, Lisa (0008-1) (0008-2) (0008-4) (0008-6) 
Appendix D 

April 2010 D-31 Draft NUREG-1936 

Table D-2. (contd) 

Comment 

Category Commenter (Comment ID)

• Piser, Daniel (0008-1) (0008-2) (0008-4) (0008-6) 

• Polya, Lance (0010-1) 

• Putney, Louis (0008-1) (0008-2) (0008-4) (0008-6) 

• Rader, Nancy (0008-1) (0008-2) (0008-4) (0008-6) 

• Radford Jr., Roger (0008-1) (0008-2) (0008-4) (0008-6) 

• Raines, Mary (0008-1) (0008-2) (0008-4) (0008-6) 

• Ramstrom, Eric G and Shirley S (0008-1) (0008-2) (0008-4) (0008-6) 

• Randall, David (0008-1) (0008-2) (0008-4) (0008-6) 

• Rankin, Susan (0008-1) (0008-2) (0008-4) (0008-6) 

• Reidenbach, Gregory (0008-1) (0008-2) (0008-4) (0008-6) 

• Rosenblum, Stephen (0008-1) (0008-2) (0008-4) (0008-6) 

• Ross, Anne (0008-1) (0008-2) (0008-4) (0008-6) 

• Sather, Alice (0008-1) (0008-2) (0008-4) (0008-6) 

• Sauer, Elizabeth (0008-1) (0008-2) (0008-4) (0008-6) 

• Schmidt, Jason (0008-1) (0008-2) (0008-4) (0008-6) 

• Schopp, Ricky (0008-1) (0008-2) (0008-4) (0008-6) 

• Schwarz, Walter (0008-1) (0008-2) (0008-4) (0008-6) 

• See, Bud (0008-1) (0008-2) (0008-4) (0008-6) 

• Shafer, Scott (0008-1) (0008-2) (0008-4) (0008-6) 

• Shannahan, Brittany (0007-2) 

• Shashani, Linda (0008-1) (0008-2) (0008-4) (0008-6) 

• Sherrow, Sarah (0008-1) (0008-2) (0008-4) (0008-6) 

• Shively, Daniel (0008-1) (0008-2) (0008-4) (0008-6) 

• Siecke, Martin (0008-1) (0008-2) (0008-4) (0008-6) 

• Simila, Owen (0008-1) (0008-2) (0008-4) (0008-6) 

• Skercevic, Maria (0008-1) (0008-2) (0008-4) (0008-6) 

• Smith, Enoch (0008-1) (0008-2) (0008-4) (0008-6) 

• Smith, Martha (0008-1) (0008-2) (0008-4) (0008-6) 

• Snowden, Patricia (0008-1) (0008-2) (0008-4) (0008-6) 

• Sorin, Susanna (0008-1) (0008-2) (0008-4) (0008-6) 

• Soroos, Marvin S (0008-1) (0008-2) (0008-4) (0008-6) 

• Soto, Yvonne (0008-1) (0008-2) (0008-4) (0008-6) 

• Stevens, Denise (0008-1) (0008-2) (0008-4) (0008-6) 

• Stilwell, Lisa (0008-1) (0008-2) (0008-4) (0008-6) 

• Strange, Linda (0008-1) (0008-2) (0008-4) (0008-6) 

• Theil, Tony (0008-1) (0008-2) (0008-4) (0008-6) 

• Thiele, Abhaya (0008-1) (0008-2) (0008-4) (0008-6) (0009-1) 

• Tornatore, James (0008-1) (0008-2) 
Appendix D 

Draft NUREG-1936 D-32 April 2010 

Table D-2. (contd) 

Comment 

Category Commenter (Comment ID)

• Tornatore, James (0008-4) 

• Tornatore, James (0008-6) 

• Trenholme, Art (0008-1) (0008-2) (0008-4) (0008-6) (0011-1) 

• Turner, Tamisha (0008-1) (0008-2) (0008-4) (0008-6) 

• Valliere, Cliff (0008-1) (0008-2) (0008-4) (0008-6) 

• VanEtten, Margot (0008-1) (0008-2) (0008-4) (0008-6) 

• Vieg, Jeannette (0008-1) (0008-2) (0008-4) (0008-6) 

• Voeller, Estelle (0008-1) (0008-2) (0008-4) (0008-6) 

• Wadkins, Melanie (0008-1) (0008-2) (0008-4) (0008-6) 

• Waldman, Sam (0008-1) (0008-2) (0008-4) (0008-6) 

• Walker-Meere, Susan (0008-1) (0008-2) (0008-4) (0008-6) 

• Walsh, Donald (0008-1) (0008-2) (0008-4) (0008-6) 

• Walters, Betty (0008-1) (0008-2) (0008-4) (0008-6) 

• Wanner, Gabrielle (0008-1) (0008-2) (0008-4) (0008-6) 

• Ward, John (0008-1) (0008-2) (0008-4) (0008-6) 

• Welch, Irene (0008-1) (0008-2) (0008-4) (0008-6) 

• Wilkins, Paul (0008-1) (0008-2) (0008-4) (0008-6) 

• Willoughby, CaraLea (0008-1) (0008-2) (0008-4) (0008-6) 

• Wilson, Deb (0008-1) (0008-2) (0008-4) (0008-6) 

• Yeatts, Jordan (0008-1) (0008-2) (0008-4) (0008-6) 

• Zastawecky, Margaret (0008-1) (0008-2) (0008-4) (0008-6) 

• Zelikson, Linda (0008-1) (0008-2) (0008-4) (0008-6) 
Appendix D 

April 2010 D-33 Draft NUREG-1936 

1 D.1 In-Scope Comments and Responses 

2 The in-scope comments are listed by their categories and associated page numbers in Table 

3 D-3 in the order that they are presented in this EIS. Parenthetical numbers after each comment 

4 refer to the Comment Identification (ID) number (document number-comment number) and the 

5 commenter name. 

6 Table D-3. Comment Categories 

Topic Page # 

 1. COL Process D-33 

 2. Site Layout and Design D-38 

 3. Land Use – Site and Vicinity D-40 

 4. Land Use – Transmission Lines D-40 

 5. Meteorology and Air Quality D-41 

 6. Geology D-42 

 7. Water Resources D-43 

 8. Ecology D-44 

 9. Socioeconomics D-44 

10. Historic and Cultural Resources D-49 

11. Environmental Justice D-49 

12. Health – Radiological D-50 

13. Accidents D-52 

14. The Uranium Fuel Cycle D-55 

15. Transportation D-63 

16. Cumulative Impacts D-66 

17. The Need for Power D-66 

18. Alternatives – No Action D-69 

19. Alternatives – Energy D-70 

20. Benefit – Cost Balance D-77 

7 

8 

9 1. Comments Concerning the COL Process

10 Comment: The proposed project is located in the Chesapeake Bay and unnamed tributaries to 

11 the Chesapeake Bay, forested nontidal wetlands, Johns Creek and Goldstein Branch and their 

12 unnamed tributaries at UniStar’s Calvert Cliffs site near Lusby, Calvert County, Maryland. The 

13 Corps is responsible for making decisions pursuant to Section 10 of the Rivers and Harbors Act 
Appendix D 

Draft NUREG-1936 D-34 April 2010 

1 and Section 404 of the Clean Water Act. It is our understanding that the NRC final rule 

2 governing Limited Work Authorizations (LWA) for Nuclear Power Plants (10 CFR Parts 2, 50, 

3 51, 52, and 100) allows certain construction activities on production and utilization facilities to 

4 commence before a construction permit or combined license is issued. We believe that because 

5 our authority to regulate work in jurisdictional waters of the U.S., including wetlands, is a smaller 

6 component of the overall project, that the NRC has greater Federal control, responsibility and 

7 expertise for evaluating the effects of this proposed action on the environment, and therefore it 

8 is appropriate that the NRC be the lead agency for compliance with the National Environmental 

9 Policy Act (NEPA) for the proposed action. It would be inappropriate for the Corps to segment 

10 the limited infrastructure components associated with, the overall Calvert Cliffs Nuclear Power 

11 Plant Unit 3 expansion where the NRC possesses the expertise in determining the 

12 environmental consequences associated with the proposed construction of the AREVA EPR 

13 and has the ultimate approval/disapproval authority for the proposal. However, given our 

14 responsibility for regulating work which is proposed for the LWA and/or license, we request to 

15 serve as a cooperating agency in the preparation of the EIS for the Calvert Cliffs Nuclear Power 

16 Plant Unit-3 project. (0021-1 [Gaffney-Smith, Margaret])

17 Comment: The Corps has the responsibility and authority to regulate portions of the proposal 

18 that affect waters of the U.S., including jurisdictional wetlands, and has the expertise necessary 

19 to assist the NRC with meeting its statutory requirements. Therefore, in accordance with the 

20 CEQ regulations we [the Corps of Engineers] are requesting to be designated as a cooperating 

21 agency for the EIS for this project. (0021-2 [Gaffney-Smith, Margaret])

22 Response: The NRC received official notice of the U.S. Army Corps of Engineers' interest in 

23 becoming a cooperating agency for the Calvert Cliffs COL EIS. The NRC has agreed by letter 

24 dated June 11, 2008 (ML081570139), to invite the U.S. Army Corps of Engineers to serve as a 

25 cooperating agency in the preparation of the EIS for this licensing action.

26 Comment: The environmental impact statement scoping process should factor in long-term 

27 and short term impacts of the proposed new reactor at Calvert Cliffs. I urge NRC to include 

28 researching alternatives to a new reactor, a comprehensive cost-benefit analysis, a study of 

29 high and low level radioactive waste, safety and emergency planning into its scoping process.

30 (0003-1 [Coster, Steven] [Kjer, Timothy] [Shannahan, Brittany])

31 Response: The NRC staff will prepare an Environmental Impact Statement (EIS) in 

32 accordance with its regulatory requirements. In its review, the staff will focus on the 

33 environmental effects of construction and operation of the proposed reactor and associated 

34 facilities and equipment. Alternative energy sources, a benefit-cost analysis, onsite treatment 

35 and handling of radiological waste, and short-term and long-term impacts are within the scope 

36 of this licensing action and will be addressed in the EIS. Safety and emergency planning are 

37 not within the scope of the EIS but are addressed in separate NRC reviews. 
Appendix D 

April 2010 D-35 Draft NUREG-1936 

1 Comment: I understand that the new NRC rules do not consider certain site-preparation 

2 activities as construction and therefore allow these activities to occur before the final 

3 Environmental Impact Study is issued. Nonetheless, I urge you to consider the impact of these 

4 activities in the EIS so that changes can be made to the work in progress if necessary. (0006-3

5 [Baummer, Thomas])

6 Comment: The NRC under a recently promulgated change to its regulations has redefined 

7 what the word "construction" means and effectively 90 percent of the construction of this new 

8 reactor, NRC no longer considers falling under the National Environmental Policy Act. They can 

9 do a lot of construction at the Calvert Cliffs 3 site without doing an environmental assessment of 

10 the environmental impacts, and I just ask how does that comport with protecting the coastline of 

11 the Chesapeake? (0024-88 [Kamps, Kevin])

12 Comment: [A]bout a year ago the nuclear industry was able to successfully convince the NRC 

13 to redefine, as Jim said, the word "construction." Redefining this word effectively circumvents 

14 the 1971 court decision. So while they are not technically violating this law, they are certainly 

15 violating the spirit of NEPA, the National Environmental Protection [Policy] Act that mandates 

16 that they prepare an EIS. (0025-88 [Fisher, Allison])

17 Comment: I’d like you to consider the following for your EIS – to assure that these [LWA 

18 construction] activities are being conducted in an environmentally responsible manner, and to 

19 restore the NRC’s compliance responsibilities, not to mention to restore the appearance of 

20 being overseers rather than promoters of nuclear power. (0025-89 [Fisher, Allison])

21 Comment: You should consider all construction activities in the EIS, especially the before22 mentioned, and withhold permission from Constellation, who is intending to take advantage of 

23 this new construction rule, until you have issued your final EIS. (0025-90 [Fisher, Allison])

24 Response: These comments refer to the NRC’s change in the definition of “construction” 

25 based on its regulatory authority. As authorized by the Atomic Energy Act of 1954, as 

26 amended, NRC is charged with protecting the public health and safety with regard to the civilian 

27 use of nuclear material. As defined in 10 CFR 51.4, construction now refers to building safety28 related structures, systems, or components (SSCs) necessary for power plant construction. 

29 Construction also includes SSCs required to provide physical protection and onsite emergency 

30 planning. Activities such as clearing and grading; excavating; building transmission lines; and 

31 erecting support buildings that are not required for nuclear safety, physical protection, or 

32 emergency planning are now considered “preconstruction” activities. Most of these activities 

33 are regulated by other agencies and require permits to proceed. For example, the Maryland 

34 Power Plant Research Program conducts its own environmental review and makes 

35 recommendations for the issuance of a Certificate of Public Convenience and Necessity. 

36 Activities affecting wetlands and navigable waters of the United States require permits from the 

37 U.S. Army Corps of Engineers (Army Corps). The Army Corps will participate as a cooperating 
Appendix D 

Draft NUREG-1936 D-36 April 2010 

1 agency with the NRC in the preparation of the EIS. The NRC will consider the environmental 

2 impacts of preconstruction activities in the context of cumulative impacts. These impacts will be 

3 evaluated in Chapter 4 [and 7] of the EIS.

4 Comment: I am also a member of the local community and an advocate of the environment, so 

5 I want to ensure that the construction and operation of Unit 3 is done in a way that will have 

6 minimal impact on the environment. (0006-2 [Baummer, Thomas])

7 Comment: NAACPCCB [National Association for the Advancement of Colored People Calvery 

8 County Branch] would like the NRC to conduct a comprehensive analysis of the potential 

9 environmental impact of a 3rd reactor at Calvert Cliffs. This impact study should not only 

10 consider the impact of the new reactor itself but the potential impact it will have in concert with 

11 the other two reactors. (0017-1 [Brown, Jr., Edsel])

12 Comment: [W]e again request that you continue to provide an open and transparent public 

13 process where everyone has an opportunity to ask questions, express their opinions and learn 

14 more about the regulatory process. (0024-13 [Parran, Wilson])

15 Comment: We trust the NRC’s open process and respectfully request that the NRC keep 

16 public comment for the draft environmental impact statement specific to the environmental 

17 report findings. (0024-15 [Hodge, Gary])

18 Comment: We understand that there will be environmental impacts during construction, 

19 several of which have been identified by Unistar. We ask that the NRC look into the identified 

20 impacts and during your independent review determine the most appropriate mitigation 

21 measures where needed. (0024-3 [Parran, Wilson])

22 Comment: We encourage and trust the NRC’s open process, and respectfully request that the 

23 NRC keep public comment for the draft environmental impact statement specific to the 

24 environmental report findings. (0025-107 [Hodge, Gary])

25 Comment: [W]e again request that you continue to provide an open, transparent public 

26 process where everyone has an opportunity to ask questions, express their opinions, and learn 

27 more about the regulatory process. (0025-17 [Parran, Wilson])

28 Comment: Last August I asked that the NRC provide assurance that Calvert Cliffs and their 

29 partners be given fair regulatory treatment regardless of opposition. (0025-26 [Martins, Darren])

30 Comment: We ask that the NRC look into the identified impacts and, during your independent 

31 review, determine the most appropriate mitigation measures when needed. (0025-3 [Parran, 

32 Wilson])
Appendix D 

April 2010 D-37 Draft NUREG-1936 

1 Comment: Any shortcomings and deficiencies in this EIS will be protested, will be litigated, and 

2 will be legislated. (0025-41 [Mariotte, Michael])

3 Response: The NRC reviews the plans for construction and operation of a proposed unit and 

4 evaluates the impacts and mitigation measures. As part of the NRC process, it seeks public 

5 comment through the public scoping meetings and the scoping period. Impacts of construction 

6 and operation including cumulative impacts with the existing Units 1 and 2 will be described in 

7 the EIS. 

8 Comment: It is our expectation that all of the questions and concerns noted in this letter will be 

9 answered by the NRC and Calvert Cliffs Nuclear Power Plant. We hope that your desire is not 

10 just to build a nuclear reactor but assist in rebuilding the community and improving the quality of 

11 life for the people in the community. (0018-14 [Mackall, Kimberly])

12 Response: The NRC has an obligation under NEPA to identify and disclose the socioeconomic 

13 impacts of major Federal actions it undertakes. Socioeconomic impacts will be analyzed in the 

14 EIS. However, NRC’s authority is limited to regulating the civilian use of nuclear materials. 

15 Community and quality of life issues that do not affect nuclear safety are more appropriately 

16 addressed by local authorities and the applicant.

17 Comment: The Draft and Final EIS—as well as public hearings—must await certification of the 

18 EPR reactor design. (0019-20 [Mariotte, Michael])

19 Response: The Design Certification Documentation for the AREVA U.S. Evolutionary Power 

20 Reactor proposed for the Calvert Cliffs Unit 3 was submitted to the NRC in December 

21 2007. The review of the design is ongoing. The submitted documentation provided sufficient 

22 details to evaluate issues relevant to the EIS. If substantive changes to the design are made as 

23 a result of the review, the changes will be evaluated to determine whether a supplement to the 

24 EIS will be needed. 

25 Comment: PPRP attended the NRC public scoping meeting on 19 March 2008, as well as 

26 portions of the site audit tour and meetings held on 17 and 18 March 2008. We appreciated the 

27 opportunity to meet the NRC staff and to share information about the State-level reviews taking 

28 place concurrently with the Federal-level evaluation. We look forward to a continuing open 

29 dialogue with the staff on issues important to Maryland. We have no specific input to the NRC’s 

30 environmental impact statement (EIS) scoping process at this time. PPRP plans to thoroughly 

31 review the draft EIS when it is issued and will submit comments as appropriate. We welcome 

32 the opportunity to participate in the NRC licensing process for Calvert Cliffs Unit 3 and look 

33 forward to further interaction in the NRC’s development of the EIS. (0022-1 [Gray, Susan])
Appendix D 

Draft NUREG-1936 D-38 April 2010 

1 Response: The NRC appreciates the opportunity to include the State of Maryland among the 

2 stakeholders participating in the licensing process for the proposed Unit 3 at the Calvert Cliffs 

3 facility. 

4 2. Comments Concerning Site Layout and Design

5 Comment: When UniStar Nuclear picked this design, we picked this design because of the two 

6 containments, the four safety trains, the amount of concrete and steel that is in this design.

7 (0024-113 [Vanderheyden, George])

8 Comment: [O]ur design is being constructed all over the world. It has already been approved 

9 by two regulatory agencies in two different countries, Finland and France. Our hope is, is that, 

10 as we go through this extensive open process with the NRC, that the U.S. Government and the 

11 Nuclear Regulatory Commission will be the third country and third regulatory agent to fully 

12 review and approve this design. (0024-115 [Vanderheyden, George])

13 Comment: This design that we will produce is also going to have a very small environmental 

14 impact. We’re the ones that are going to build a cooling tower that’s not 5[00] or 600 feet like 

15 most people are used to seeing in the press, I mean in pictures. It’s a 168 feet. It’s going to have 

16 plume abatement on the cooling towers which means that vapor trail that people see that goes 

17 up into the air, you won’t see that from our power plant. (0024-118 [Vanderheyden, George])

18 Comment: [W]e’re going to put a desalinization plant in. We’re going to take a small amount of 

19 the Chesapeake Bay water, remove the salt, make fresh water with it and use it to provide the 

20 power plant systems. (0024-119 [Vanderheyden, George])

21 Comment: UniStar has taken several additional key steps to minimize the environmental 

22 impact by selecting a hybrid cooling tower designed much lower to the ground and one that will 

23 take in approximately 98 percent less water from the Chesapeake Bay than the existing Calvert 

24 Cliffs Units 1 and 2, and a desalination plant that eliminates the need to use area groundwater 

25 sources once the plant is operational. (0024-2 [Parran, Wilson])

26 Comment: I trust that since this may be the first design of this type in the United States but it’s 

27 not just being reviewed by the NRC, it’s being reviewed by other nations as well. (0024-96

28 [Scarafia, Bill])

29 Comment: [W]e are the design that has the double containment building. The containment 

30 building, of course, is what houses the nuclear reactor subject to many of people’s points. It is 

31 typically that four- to seven-foot thick concrete dome around it. Well, we have a second dome 

32 around ours. We have double containments. (0025-168 [Vanderheyden, George])
Appendix D 

April 2010 D-39 Draft NUREG-1936 

1 Comment: Our design – and we will prove it in our safety analysis – is capable of handling a 

2 direct impact from a military aircraft, a personal aircraft, and a large commercial aircraft. (0025-

3 169 [Vanderheyden, George])

4 Comment: We are the design that will have 99 percent less heat input into the Chesapeake 

5 Bay. We will use 98 percent less cooling water than the existing two units use at Calvert Cliffs. 

6 We are going to do that through a new hybrid cooling tower. (0025-171 [Vanderheyden, George])

7 Comment: It’s a low cooling tower, only 168 feet, not 600 feet that you see at many of these 

8 power plants. And it’s even going to have plume abatement on it, so you don’t see that vapor 

9 trail going up into the sky. (0025-172 [Vanderheyden, George])

10 Comment: I am well aware of the concerns of the quality of our groundwater and the amount of 

11 groundwater we have left in our aquifers here because of the continued population growth we 

12 are all seeing. So we decided to spend an additional $47 million to put a desalinization plant in, 

13 so that the plant will draw water from the Chesapeake, desalinate it, it turns out to be a small 

14 amount of water, and not use the groundwater. (0025-173 [Vanderheyden, George])

15 Comment: UniStar has taken several additional key steps to minimize the environmental 

16 impact by selecting a hybrid cooling tower designed much lower to the ground and one that will 

17 take in approximately 98 percent less water from the Chesapeake Bay than the existing Calvert 

18 Cliffs Units 1 and 2, and a desalination plant that eliminates the need to use area groundwater 

19 sources once the plant is operational. (0025-2 [Parran, Wilson])

20 Response: These comments relate to UniStar’s proposed plant design, cooling system, and 

21 plume abatement measures. Some, like the plan to build a desalination plant for cooling the 

22 reactor, relate to design measures intended to minimize resource use. The site layout, the 

23 reactor type, and the cooling water systems will be described in Chapter 3 of the EIS. 

24 Comment: I drive past the plant on Route 2/4 every day on my way back and forth to work. 

25 There are no visible clues that there is any kind of industrial activity there, except the signs at 

26 the entrance of the plant. No smokestacks, no smoke, no railway cars, no lines of trucks in and 

27 out, and no pipelines. (0025-133 [Sinclair, Jim])

28 Response: This comment reflects the lack of visible indications of industrial activity when 

29 viewing the plant entrance and surrounding site from the highway. An aesthetics evaluation of 

30 the proposed plant siting will be discussed as part of the socioeconomics analysis in the EIS. 
Appendix D 

Draft NUREG-1936 D-40 April 2010 

1 3. Comments Concerning Land Use – Site and Vicinity

2 Comment: How will clearing of additional land and any changes to the shoreline and cliffs 

3 impact the environment immediately surrounding the plant? (0006-8 [Baummer, Thomas])

4 Response: The land use and ecological impacts of constructing and operating the proposed 

5 new nuclear unit will be examined in Chapters 4 and 5 in the EIS. 

6 4. Comments Concerning Land Use – Transmission Lines

7 Comment: Constellation representatives have not to my knowledge explained to Calvert 

8 County how they will export the additional 1600 MW out of the County and into "the grid". 

9 Supporters of the new reactor seem to believe that Unistar will be able to upgrade the existing 

10 corridor, without having to condemn additional land from adjacent property owners. In contrast 

11 to Constellation/Unistar, representatives of the MAPP project have indicated that they do not 

12 intend to widen their 500 kV connector from Calvert Cliffs to Chalk Point—rather, they intend to 

13 upgrade the cables and towers. MAPP also plans to embed a 500 kV connector at shallow 

14 subbottom depth under the Chesapeake, thereby creating a connection with the Eastern Shore.

15 (0005-14 [Vogt, Peter])

16 Comment: [A]ny widening of the transmission corridor would have extremely negative effects 

17 on adjacent homeowners and on land owners who have gone the extra mile to preserve their 

18 land privately, thinking it would be ‘in perpetuity’. Perhaps the worst impacts would fall on the 

19 large area of nature preserve in the watersheds of Parkers Creek and Governors Run. The 

20 environmental viability of this preserve area is already negatively impacted by the existing 

21 corridors, which fragment the forested preserve. (0005-15 [Vogt, Peter])

22 Comment: The EIS needs to require any new reactor to export its power within the existing 

23 corridor. If necessary, pay the price of undergrounding—it’s possible but costs more. (0005-16

24 [Vogt, Peter])

25 Response: The possible need for any additional land for transmission will be addressed in 

26 Chapter 4 of the EIS. If new land is needed, associated environmental impacts will also be 

27 addressed in the EIS. 

28 Comment: [W]hen comparing the impact of generating new power at Calvert Cliffs vs. at other 

29 potential sites, the EIS needs to compare the lengths of transmission corridor required to get the 

30 power into the grid. This would include the added line losses, transmission line and tower 

31 construction and maintenance costs for a longer corridor, as well as the environmental costs of 

32 keeping natural forest from reclaiming the corridors. (0005-17 [Vogt, Peter])
Appendix D 

April 2010 D-41 Draft NUREG-1936 

1 Comment: We would like to make certain that our citizens understand one key construction 

2 fact: there are no new transmission corridors necessary to build Unit 3. It is important to note 

3 that Unit 3 not be confused with other proposed utility improvement projects in Calvert County. 

4 The 500kv transmission line currently serving Calvert Cliffs will accommodate the expansion 

5 with some upgrades to substations. (0014-2 [Clark, Gerald] [Kelley, Linda] [Parran, Wilson] [Shaw, 

6 Susan] [Stinnett, Barbara])

7 Comment: [N]o new transmission corridors are needed to build Unit 3. We note this because it 

8 is important not to confuse the construction of Unit 3 with the other proposed utility improvement 

9 projects in Calvert County and we have several other projects in Calvert County that are not 

10 related to the building of Unit 3. (0024-4 [Parran, Wilson])

11 Comment: [I]t is important not to confuse the construction of the Unit 3 and other proposed 

12 utility improvement projects in Calvert County. The 500-kilovolt transmission line currently 

13 serving Calvert Cliffs will accommodate the expansion with some upgrades to the substation

14 (0025-5 [Parran, Wilson])

15 Response: The environmental impacts associated with transmitting power from the proposed 

16 new unit to the grid will be addressed in the EIS. 

17 5. Comments Concerning Meteorology and Air Quality

18 Comment: Will the water circulating in the cooling tower be raw bay water or treated or 

19 desalinated water? Any chemicals in this water, as well as salt and other minerals, are likely to 

20 be carried into the air and the local environment. The effect of this should be evaluated. (0006-5

21 [Baummer, Thomas])

22 Comment: Is the plume abatement system on the cooling tower likely to work effectively 

23 throughout the plant’s life? Or will a certain level of effectiveness be required? Legionnaire’s 

24 disease and particulate salt emissions (with its effects on the local ecology and on nearby cars 

25 and equipment through corrosion) are two significant concerns. (0006-6 [Baummer, Thomas])

26 Response: The reactor cooling system including the water source and treatment and its 

27 operation will be discussed in Chapter 3 of the staff’s EIS. The potential impacts of the cooling 

28 system operation will be addressed in several sections of Chapter 5 of the EIS. For example, 

29 impacts of drift on vegetation will be addressed in the section on terrestrial ecology, the potential 

30 impacts on human health will be addressed in the section on non-radiological health effects, and 

31 the aesthetics of cooling tower plumes will be addressed in the section on socioeconomic 

32 impacts. 

33 Comment: The EIS should fully examine the potential effects of climate change on the Calvert 

34 Cliffs 3 facility, including the possibility of severe weather-induced accidents. For example, 
Appendix D 

Draft NUREG-1936 D-42 April 2010 

1 tornados are occurring with greater frequency in the region and a strong tornado nearly hit the 

2 Calvert Cliffs site just a few years ago, whereas 30 years ago tornados were a rarity in the mid3 Atlantic region. The EIS should consider the effect of stronger and more frequent tornados 

4 hitting the Calvert Cliffs site directly. (0019-29 [Mariotte, Michael])

5 Comment: The EIS should address the effects of larger and more frequent hurricanes directly 

6 hitting the Calvert Cliffs site. (0019-30 [Mariotte, Michael])

7 Comment: What is the effect of climate change on the operations of this plant? This plant 

8 would operate for at least 40 years, perhaps 60 years. It won’t be online for another 10 years, so 

9 we are really projecting late this century the impacts of this plant. (0025-45 [Mariotte, Michael])

10 Comment: What are the effects of the increasing likelihood of increasingly strong storms, 

11 tornadoes, on this plant? Is this plant being built to accommodate that? (0025-46 [Mariotte, 

12 Michael])

13 Response: The comments express concern over the effects of the environment on the 

14 operation of the plant. Evaluation of the design to withstand severe weather conditions is part of 

15 the licensing process, but outside the scope of the EIS. Wind loadings, tornados, and floods will 

16 be considered in the staff’s safety evaluation report. 

17 Comment: The EIS should address the possible impacts of climate change on the 

18 Chesapeake Bay and the water supply for Calvert Cliffs-3. (0019-31 [Mariotte, Michael])

19 Response: The comment expresses concern over the effects of the environment on the 

20 operation of the plant. Evaluation of the water requirements to maintain the plant in a safe 

21 condition is part of the licensing process, but outside the scope of the EIS. The capability of the 

22 water supply source to provide necessary cooling of the reactor and essential equipment will be 

23 evaluated in the staff’s safety evaluation report. 

24 6. Comments Concerning Geology

25 Comment: Careful mapping of the Miocene-aged sediment layers outcropping along the 

26 Calvert Cliffs has been done and published subsequent to the construction of the existing power 

27 plant in the mid-1970s. This new mapping shows--more accurately than was known before– he 

28 layers to be gently dipping (tilted) down to the southeast, and not disrupted by faults—except at 

29 one site, located about 1 mile south of the Calvert Cliffs Nuclear Power Plant, just north of 

30 Rocky Point. At this place along the cliffs, the layers appear to be offset a couple meters—that 

31 is, the layers are not continuous. The offset is such that the layers to the south are higher than 

32 those on the north. Detailed geological examination is needed to prove that the offset is not due 

33 to mapping errors--unlikely--, and, if a fault is indicated, boreholes will be needed to establish its 

34 strike (trend) and dip. (0019-35 [Mariotte, Michael])
Appendix D 

April 2010 D-43 Draft NUREG-1936 

1 Response: The EIS will contain a short description of local geology. Geotechnical and seismic 

2 issues are addressed in Chapter 2.5 [Section 2.8] of the staff's Safety Evaluation Report. 

3 7. Comments Concerning Water Resources

4 Comment: What will be done with the salt and other minerals extracted by the desalination 

5 plant? Returning these to the bay will have a disturbing effect on the salinity and ecology of the 

6 area. (0006-4 [Baummer, Thomas])

7 Response: Water quality impacts of operation of the plant will be evaluated by the staff and 

8 described in Chapter 5 of the EIS. This assessment will include consideration of the impacts of 

9 the effluents from the desalination system and its effect on aquatic ecology. 

10 Comment: How will sediment and chemical runoff be controlled during construction? (0006-7

11 [Baummer, Thomas])

12 Response: Water quality issues associated with construction activities will be assessed by the 

13 staff and discussed in Chapters 4 and 7 of the EIS. Control of pollutants in runoff is regulated 

14 by the State. 

15 Comment: You should address what effect runoff from the pre-construction activities will have 

16 on the Bay. (0025-93 [Fisher, Allison])

17 Response: The impacts of preconstruction activities will be considered in the staff’s review of 

18 cumulative impacts. The assessment of cumulative impacts will be discussed in Chapters 4 

19 and 7 of the EIS. 

20 Comment: [W]hat benchmarking can we do with regard to effluents to the Bay when we 

21 compare it to non-nuclear power plants that use the same water supply? (0024-110 [Buchanan, 

22 Bill])

23 Response: It is unclear whether this question refers to general or radiological 

24 effluents. General effluents are largely related to the amount of water used in the cooling 

25 system, its temperatures, and any water treatment chemicals used. Liquid effluents are 

26 regulated through the facility’s National Pollutant Discharge Elimination System (NPDES) 

27 permit. Aside from the cooling system, the primary feature distinguishing the liquid effluents 

28 from a nuclear power plant with a non-nuclear power plant is that a nuclear plant discharges a 

29 small quantity of radionuclides into the normal effluent, and this quantity is limited by NRC 

30 regulation. Ambient radiological monitoring is conducted in the Bay to verify its quality. Current 

31 surface water quality and proposed impacts to the surface water from construction and 

32 operation of a new unit will be discussed in the EIS. 
Appendix D 

Draft NUREG-1936 D-44 April 2010 

1 8. Comments Concerning Ecology

2 Comment: According to Constellation sources, ca. 300 acres will have to be cleared of forest 

3 for new reactor construction. This forest forms part of the two remaining Calvert County areas of 

4 relatively contiguous forest, which represent “bioreserves”, for example for successful 

5 reproduction of numerous neotropical migrant bird species, whose populations have been 

6 steadily declining (at rates from ca. 1 to several % per year, depending on species) throughout 

7 the eastern US for some decades. One of the two areas extends from Flag Ponds Nature Park 

8 across through the Constellation forest buffer zone, and down into the Calvert Cliffs State Park 

9 and the buffer zone around the Dominion LNG terminal area. The Calvert Cliffs forest buffer 

10 zone, managed for wildlife under the WHIP program by the operator, is actually better for Forest 

11 Interior Dwelling species (FIDs) than parks opened to the public, which are more prone to 

12 disturbance. [The] 300 contiguous acres of forest lost to the new reactor would probably 

13 comprise the biggest single loss of contiguous forest (the ecologically valuable type) in Calvert 

14 County for decades, if not ever. The EIS needs to estimate the resulting loss of nesting sites 

15 etc. from the clearing of these 300 forested acres. (0005-13 [Vogt, Peter])

16 Response: Impacts to terrestrial resources from construction of the proposed unit, including 

17 changes in the landscape, will be discussed in Chapters 4 and 7 of the EIS. 

18 Comment: [T]he damage to wildlife from small releases should be contrasted with the damage 

19 to habitat that would result from the construction of thousands of wind turbines, either on or 

20 offshore, or the conversion of thousands of square miles of farm and forest to bioenergy 

21 production. (0025-59 [Meadow, Norm])

22 Response: Impacts of the construction and operation of the proposed unit on environmental 

23 resources will be discussed in Chapters 4 and 5 of the EIS. Impacts of alternative energy 

24 sources will be discussed in Chapter 9. 

25 Comment: [The EIS] must assign considerable importance to damage to habitat which 

26 diminishes both biological diversity and complexity. (0028-2 [Meadow, Norman])

27 Response: A discussion of the impacts of construction and operation of the proposed units and 

28 their impact on the environment will be discussed in Chapters 4 and 5 of the EIS. 

29 9. Comments Concerning Socioeconomics

30 Comment: I’ve lived here in Calvert for 25 years. All the farms are gone. They want to build 

31 new schools. Subdivisions are everyw[h]ere. But I guess no one thought about that. Calvert 

32 County Commissioners are not for the quality of life for this county. All they can think of is the 

33 next dollar in their pocket. (0002-2 [Boswell, William])
Appendix D 

April 2010 D-45 Draft NUREG-1936 

1 Response: Socioeconomic issues including existing land development and regional schools 

2 and changes resulting from the addition of the proposed new unit will be discussed in 

3 Chapters 4 and 5 of the EIS. 

4 Comment: The EIS needs to estimate the likely number of new children added to the school 

5 system as a result of a new reactor- and take into consideration that the new employees will 

6 likely be in their prime child-producing years. (0005-11 [Vogt, Peter])

7 Comment: Your risk assessment must consider rapid population growth in the Calvert Cliffs 

8 Nuclear Power plant region. Calvert County itself has grown from ca. 20,000 when the first two 

9 units went online, to nearly 90,000 today. (0005-4 [Vogt, Peter])

10 Comment: Constellation must demonstrate that its staff will have access to reasonable 

11 housing. Since Calvert County has limited apartment availability, plans must be established to 

12 ensure that the staff of the new reactor can acquire living quarters in the county. Over the last 

13 several years there have been major issues with healthcare, law enforcement, and other key 

14 professionals finding it difficult to acquire housing in the county. (0017-9 [Brown, Jr., Edsel])

15 Response: Socioeconomic impacts such as impacts on population, schools, public services, 

16 and housing associated with the construction and operation of a new unit at Calvert Cliffs will be 

17 considered in Chapters 4 and 5 of the EIS. 

18 Comment: EIS statisticians should be able to estimate, with some range of 

19 caveats/assumptions, the probable mean traffic delay imposed by reactor construction and 

20 operation, and what a mean 1 minute daily traffic delay would cost annually, as well as the likely 

21 number of additional accidents per year. Even neglecting the delays and cost due to increased 

22 accidents, I roughly estimate the total annual cost for every 1 min traffic delay at from $5 million 

23 to $50 million. It is unacceptable that this cost is ignored just because it is (like investor risk) 

24 dispersed among many thousands of people. (0005-10 [Vogt, Peter])

25 Comment: Constellation states that the proposed third reactor would provide several thousand 

26 construction jobs and several hundred permanent jobs. Many of these new jobs, as well as 

27 visitors, and delivery trucks, will add substantial traffic to MD 2/4, which at present is a 

28 congested and dangerous highway. (0005-6 [Vogt, Peter])

29 Comment: Traffic on this highway has been increasing even faster than the population-and 

30 Calvert has been at or near the top of population growth rates among Maryland counties for 

31 decades: Your estimate needs to consider the trend when you estimate traffic impact when 

32 reactor construction might begin. (0005-8 [Vogt, Peter])

33 Comment: MD 2/4 is currently near failure (categories D or worse), especially during rush 

34 hour. The counter near Prince Frederick has reached 40,000 vehicles per day, and much of the 
Appendix D 

Draft NUREG-1936 D-46 April 2010 

1 new reactor traffic would have to pass through Prince Frederick. Your assessment needs to 

2 acknowledge the ‘stutter-step’ response of infrastructure (e.g., roads, schools, airports, etc.) to 

3 growth. (0005-9 [Vogt, Peter])

4 Comment: [With regard] to the potential impact on traffic patterns in Calvert County as a result 

5 of the new reactor. With increased staff, deliveries, and related businesses to support the site 

6 expansion, what plans are being put in place to assure that the expansion will have little or no 

7 impact on travel. (0017-7 [Brown, Jr., Edsel])

8 Response: Socioeconomic impacts such as impacts on transportation and local infrastructure 

9 associated with the construction and operation of the Unit 3 will be considered in Chapters 4 

10 and 5 of the EIS. 

11 Comment: The EIS process should include impartial estimates showing a breakdown of job 

12 and pay categories, in terms of the % likely filled by county residents. (0005-12 [Vogt, Peter])

13 Response: Socioeconomic impacts such as labor impacts associated with the construction and 

14 operation of Unit 3 will be considered in Chapters 4 and 5 of the EIS. 

15 Comment: Calvert Cliffs has served the citizens of Calvert County well over the past decades 

16 as the leading employer in our county. Additionally, Calvert Cliffs has contributed sixteen million 

17 dollars annually in taxes, which accounts for nine percent of the county’s total revenue. Calvert 

18 Cliffs has assisted the county in numerous donations to various organizations and countless 

19 students. I have seen many positive results from their presence in Southern Maryland. I can 

20 truly say that Calvert Cliffs has greatly enriched our county and allowed for a better quality of life 

21 while meeting the energy needs of Maryland. (0015-5 [O’Donnell, Anthony])

22 Comment: The reality of the fact is that nuclear power plants are going to be built in this 

23 country somewhere and at some time and there’s no reason why this county and this region 

24 should not enjoy those economic benefits that I talked about earlier today and if it’s job creation 

25 in this county that are good paying jobs with good benefits that aren’t necessarily when we talk 

26 about the construction jobs as temporary jobs, those are not temporary jobs. They will afford — 

27 with the rising costs of college education today many people will not be able to viably afford to 

28 go to college and our young people will have an opportunity to enter into the trade, learn a skill, 

29 get educated while they earn money and have a lifelong career with benefits, a defined benefit 

30 plan, and a health and welfare plan where they can take care of their needs. (0024-107

31 [Karbowsky, Brad])

32 Comment: [A] nuclear plant makes a good neighbor, as many people here tonight have 

33 already indicated. It supports high-paying jobs directly at the plant, generates additional jobs in 
Appendix D 

April 2010 D-47 Draft NUREG-1936 

1 the community where it is located, and contributes by helping build good schools, roads, and 

2 other civic improvements. (0024-26 [Kanaley, Mike])

3 Comment: We must seek and support development that will stimulate our economy, provide 

4 jobs, additional tax revenue, and new business opportunities. We have to be open-minded and 

5 flexible when considering what we’re up against. We have to keep an eye on the important role 

6 that Calvert Cliffs plays in our economy. (0024-29 [McClure, Deborah])

7 Comment: I read a letter to the editor recently blasting this potential expansion as related to a 

8 number of items, including job growth, the limited availability of labor and the fact that most of 

9 the higher-paying jobs related to the plant expansion would be highly specialized, with the 

10 eligible employee pool mostly trained on Navy nuclear submarines. Not only is this not true, I 

11 couldn’t disagree more with that premise. It is true that the Navy trains many, many nuclear 

12 workers, but the fact is that universities across the United States, almost 900 of them, offer 

13 fields of study in undergraduate nuclear energy programs. (0024-42 [Chambers, Bill])

14 Comment: [B]ecause job creation is critical here locally in Calvert County, an expanded 

15 Calvert Cliffs would be a huge economic and socioeconomic boon for Calvert County and the 

16 State of Maryland. (0024-43 [Chambers, Bill])

17 Comment: So I ask the NRC to review the impact an expanded Calvert Cliffs may have on 

18 education and this request is not meant to be negative at all. In fact, I’d like this raised because I 

19 believe that creating opportunity for our local youth will allow our children to live and work in the 

20 community in which they are raised. (0024-44 [Chambers, Bill])

21 Comment: The economy is in an area right now where we need jobs such as the third reactor 

22 coming to Calvert Cliffs. We as union employees are in a turmoil right now. That plant alone 

23 would bring most crafts back up to standards and that's what we are looking forward to. (0024-56

24 [Parran, Wilson L.])

25 Comment: When we look at the potential for this new facility and the 2,000 on up construction 

26 jobs, another economic benefit. When we look at the 400 potential permanent jobs after 

27 completion, high-paying technically advanced jobs. (0024-93 [Scarafia, Bill])

28 Comment: Our communities throughout Southern Maryland have all collaborated to build a 

29 feeder system throughout our public schools and our higher education in the areas of science, 

30 technology, engineering and math, what everybody in the country is calling STEM, so that our 

31 citizens will be able to produce the kind of workers that they will need and as one speaker said 

32 earlier, we will now have another opportunity for our local graduates to live and work here.

33 (0024-94 [Scarafia, Bill])
Appendix D 

Draft NUREG-1936 D-48 April 2010 

1 Comment: A nuclear power plant also makes a good neighbor. It supports high-paying jobs 

2 directly at the plant. It generates additional jobs in the community, and I have been told, and I 

3 have read, that for every job created at a plant three jobs are created in the community. And I 

4 believe it is 400 jobs that are going to be created, so that's 1,200 additional jobs in the 

5 community. (0025-123 [Walther, Robert])

6 Comment: The community will benefit from the many construction jobs created over the near 

7 term, and permanent jobs long into the future, once the plant becomes operational. (0025-137

8 [Sinclair, Jim])

9 Comment: The new plant will also make a significant contribution to the Calvert County tax 

10 base, which is already greatly supported by the existing units, reducing the burden on individual 

11 taxpayers. (0025-138 [Sinclair, Jim])

12 Comment: In these tough economic times, it is economic development like the construction of 

13 a third reactor at Calvert Cliffs that will help provide the socioeconomic push many of our small 

14 businesses need to stay afloat and prosper. Solomons Business Association welcomes that 

15 development and looks forward to the new jobs, new businesses, and new visitors that it will 

16 bring to our region. (0025-175 [Tarhan, Diane])

17 Comment: [T]he positive economic benefit that will come from the expansion and adding this 

18 third reactor at Calvert Cliffs, some $20 million in new revenue resources that would come just 

19 to Calvert County alone. (0025-35 [Burton, Bob])

20 Comment: And let me just say that the environmental impact can be positive not only during 

21 and after the new reactor is put into place, but these additional monies that will come into 

22 Calvert County will be used to improve, upgrade, and expand infrastructure, public education, 

23 and public safety. (0025-36 [Burton, Bob])

24 Comment: [W]hen we have the opportunity in our local jurisdictions, and the funding, to be 

25 able to go in there and upgrade this infrastructure, it will have to meet the new environmental 

26 standards, which will help create a cleaner environment for our communities when we begin 

27 upgrading this infrastructure. (0025-37 [Burton, Bob])

28 Comment: When we begin putting additional monies into public education, we can expand the 

29 program offerings, as it was noted here earlier, in the area of math and science and 

30 engineering. (0025-38 [Burton, Bob])

31 Comment: [W]e are talking about an infusion of jobs to this region of 2,000 construction jobs, 

32 many of which whom the last time there was a construction plant built in this county stayed 

33 here, with high-paying jobs that have high paying benefits that do not take from the county and 

34 the region’s government, but actually give back to those positions. (0025-78 [Karbowsky, Brad])
Appendix D 

April 2010 D-49 Draft NUREG-1936 

1 Comment: It brings forth the ability of our young people to enter into the construction trade, as 

2 an alternative to going to college, for those who can’t go to college with the skyrocketing costs 

3 of college, and provide opportunities for our residents to have jobs and stay in this county and 

4 live in this county. (0025-80 [Karbowsky, Brad])

5 Comment: The estimated 2,000 to 4,000 construction jobs will be an economic boost to our 

6 region, but then the subsequent 400 permanent jobs will be well placed here, because in St. 

7 Mary’s County and the rest of our region you will see that we have developed a huge 

8 technology base where people will be able to come with their expertise and blend and feel 

9 comfortable in this community. (0025-82 [Scarafia, Bill])

10 Response: These comments generally express support for the Calvert Cliffs Unit 3, based on 

11 the potential positive socioeconomic impacts it would be expected to bring to the 

12 region. Socioeconomic impacts of construction and operation will be discussed in Chapters 4 

13 and 5 of the EIS. 

14 10. Comments Concerning Historic and Cultural Resources

15 Comment: [I]n the environmental report submitted by Unistar, they identify parcels within the 

16 proposed project area that is potentially eligible for the national registry of historic places. Since 

17 they’re a moderate to high potential for containing archaeological resources in this general area, 

18 what mitigation measures will be required in order to protect the integrity of these resources, 

19 especially since they are no longer considered within the purview of the EIS? (0025-94 [Fisher, 

20 Allison])

21 Response: The NRC will comply with the National Historic Preservation Act (NHPA) through 

22 its normal NEPA process. Impacts to historical resources and possible mitigation measures will 

23 be discussed in Chapters 4 and 5 of the EIS. Then NHPA does not grant the authority to 

24 impose mitigation to the NRC. The applicant will need to work with the Maryland Historical 

25 Trust to identify any necessary mitigation measures. 

26 11. Comments Concerning Environmental Justice

27 Comment: African Americans make up about 13% of the population of Calvert County. A 

28 majority of African Americans live within 1 to 10 miles away from the nuclear power plant. There 

29 are several schools in close vicinity to the nuclear power plant and will be effected by the 

30 decision of the NRC. History tells us that prior to the new concepts of environmental justice and 

31 racism the African American neighborhoods have been recipients of toxic landfills and other 

32 hazardous materials. Due to the negative historical data throughout the country and potential of 

33 an emergency CBW would like to ask the following questions [all but the one below which are 

34 listed in the sections based on subject matter]. (0018-2 [Mackall, Kimberly])
Appendix D 

Draft NUREG-1936 D-50 April 2010 

1 Comment: How are you implementing Environmental Justice Executive Order 12898 at the 

2 Calvert Cliffs Nuclear Power Plant? (0018-3 [Mackall, Kimberly])

3 Response: The NRC Environmental Justice Policy is available in the NRC Electronic Reading 

4 Room at http://www.nrc.gov/reading-rm/doc-collections/commission/policy/69fr52040.pdf. The 

5 policy states that NRC will identify and disclose disproportionately high and adverse impacts 

6 that fall heavily on a particular community as a result of a proposed agency action. The NRC 

7 will perform its environmental justice analysis through its NEPA review process. Environmental 

8 justice is evaluated on a plant-specific basis and will be addressed in Chapters 4 and 5 of the 

9 EIS.

10 12. Comments Concerning Health – Radiological 

11 Comment: I took a course in the history of the nuclear industry at university, studying under 

12 one of the most respected academic specialists on the subject. He says that there is no real 

13 ‘safe’ level of radiation for humans to be exposed to. All radiation is damaging, no matter what 

14 the nuclear companies say. (0007-3 [Shannahan, Brittany])

15 Comment: What are your clean up standards? What are the standards for air quality and 

16 water quality? (0018-10 [Mackall, Kimberly])

17 Comment: The EIS should address the additional cumulative effects of routine radiation 

18 releases on nearby populations and on aquatic life in and around the Chesapeake Bay from 

19 Calvert Cliffs-3, given 11 nuclear reactors (Susquehanna 1 & 2, Three Mile Island 1, Peach 

20 Bottom 2& 3, Calvert Cliffs-1 & 2, North Anna 1& 2, Surry 1& 2) already releasing radiation into 

21 the Bay. (0019-22 [Mariotte, Michael])

22 Comment: [W]ith an accident at a nuclear power plant, it’s, of course, different than an 

23 accident elsewhere. There is radioactive material that would be dispersed and citizens are at 

24 risk of ingestion and inhalation. Radioactive iodine can be a cause of thyroid cancer and then 

25 the other radioactive material can be risk factors down the line for cancers in the future. (0024-68

26 [Dubois, Gwen])

27 Comment: [T]he scientific requirements for valid analysis of risk are clearly described in the 

28 publications of the National Research Council, known as the BEIR reports, B-E-I-R. And these 

29 should be carefully considered. The reports clearly state that the best estimates of risk are from 

30 studies for which there are data on individual dose, and for which an appropriate control 

31 population is available. (0025-57 [Meadow, Norm])

32 Comment: The scientific requirements for valid analysis of risk are clearly described in 

33 publications of the National Research Council known as the BEIR Reports, which should be 

34 considered carefully. These reports clearly state that the best estimates of risk are from studies 
Appendix D 

April 2010 D-51 Draft NUREG-1936 

1 for which there are data on individual dose, and for which appropriate control populations are 

2 available. (0028-28 [Meadow, Norman])

3 Comment: When evaluating risk from accidents of the magnitude of that at Three Mile Island 

4 (TMI), the quality of the available studies should be evaluated by the criteria in the BEIR 

5 Reports. (0028-29 [Meadow, Norman])

6 Comment: The results most often given to the public are from weak, ecological studies; the 

7 paper most frequently cited by opponents of nuclear power as demonstrating that the releases 

8 at TMI2 caused damage to health is an ecological study. Two other groups of qualified 

9 researchers have not found evidence of cancer caused by TMI. (0028-30 [Meadow, Norman])

10 Comment: The rate of incidence of cancer proposed by Wing, et al. is inconsistently high when 

11 compared to the rates that have been reported from exposures that were orders of magnitude 

12 higher than those which occurred at TMI [Three Mile Island]. ... This is one of the more 

13 convincing pieces of evidence that caused the MCC to conclude that there is no credible 

14 evidence that accidents at water moderated reactors have caused harm to health. (0028-31

15 [Meadow, Norman])

16 Comment: Virtually all oncologists believe that solid tumors do not become clinically manifest 

17 until at least 5 years, and more often at least 10 years after the event that turns a cell malignant.

18 (0028-32 [Meadow, Norman])

19 Comment: [W]e believe that the potential for harm from commercial water-moderated nuclear 

20 reactors has been unjustifiably exaggerated, and that there is no credible evidence for death or 

21 cancer attributable to their operation. (0028-5 [Meadow, Norman])

22 Response: The NRC’s regulatory limits for radiological protection are set to protect workers 

23 and the public from the harmful health effects of radiation on humans. These limits are 

24 presented in 10 CFR Part 20, “Standards for Protection Against Radiation” and are based on 

25 recommendations of national and international standards-setting organizations and the National 

26 Research Council’s committee reports on the Biological Effects of Ionizing Radiation (the BEIR 

27 reports). The effects on workers and the public and environment from cumulative radiological 

28 releases from the proposed Unit 3, including those from Calvert Cliffs Units 1 and 2, will be 

29 described in Chapter 7 of the EIS. 

30 Comment: [W]hen investigating the environmental consequences of an accident at the 

31 proposed reactor, the EIS should consider many reports on the effects of radioactivity on 

32 wildlife, some of which are from carefully controlled experiments. Humans appear to be among 

33 the species most sensitive to radioactivity, which means that most other things out there are 

34 less sensitive. (0025-58 [Meadow, Norm])
Appendix D 

Draft NUREG-1936 D-52 April 2010 

1 Comment: When evaluating the environmental consequences of an accident (environmental in 

2 the context of the preservation of nature) at the proposed reactor, the EIS should consider many 

3 reports on the effects of radioactivity on wildlife [footnote 5] and not gratuitous statements that 

4 extrapolate exaggerated claims of health damage from humans to the rest of the biological 

5 world. Humans appear to be among the species most sensitive to radioactivity. (0028-33

6 [Meadow, Norman])

7 Response: The radiological impacts of reactor operation, including impacts to biota, will be 

8 addressed in Chapter 5 of the EIS. 

9 Comment: The EIS must fully address the impact on flora and fauna in the Chesapeake Bay 

10 caused by Calvert Cliffs-3’s planned release of 525,000 gallons per year of radioactive waste 

11 into the Bay, as indicated by Constellation Energy’s Response to Question 1-13 of the Maryland 

12 Public Service Commission. (0019-17 [Mariotte, Michael])

13 Comment: [A]ccording to documents filed with the Maryland Public Service Commission, this 

14 plant is going to dump 525,000 gallons per year of liquid radioactive waste into the Chesapeake 

15 Bay. What are the effects on the flora and fauna of that dumping? That is something that has to 

16 be looked at in the EIS and addressed carefully. (0025-53 [Mariotte, Michael])

17 Response: These comments concern the environmental impacts of liquid radioactive effluents 

18 on aquatic ecology during normal operations. The NRC staff will discuss such impacts in 

19 Chapter 5 of the EIS. 

20 13. Comments Concerning Accidents

21 Comment: While the nuclear reactor is said to stimulate the economy within Calvert County, 

22 CBW's [Concerned Black Women of Calvert County] primary concern is regarding the quality of 

23 life of the people who live near and are at risk if an accident occurs. CBW believes that the 

24 family is the foundation and core of the community. In order for the family to be viable the 

25 people must have the right to a clean, safe, just, healthy, and sustainable environment. (0018-1

26 [Mackall, Kimberly])

27 Comment: What is your worst case scenario for a potential accident? What preventative 

28 measures will you put in place? (0018-9 [Mackall, Kimberly])

29 Comment: I would even point out if an evacuation is carried out without a hitch, what does that 

30 mean if there’s a major radioactivity release from Calvert Cliffs? That could mean that people 

31 can never come back. (0024-84 [Kamps, Kevin])

32 Comment: One melt down of one of those plants – it’s sci fi horror films manifested! (0026-3

33 [Marsh, Rauni])
Appendix D 

April 2010 D-53 Draft NUREG-1936 

1 Response: The staff’s EIS will address the potential impacts of operation of the proposed 

2 reactor on public health and safety in Chapter 5. There will be sections on potential radiological 

3 and nonradiological impacts of normal reactor operation on public health. There will also be a 

4 section on the potential impacts of postulated reactor accidents on public health and the 

5 environment. 

6 Comment: The EIS should describe and address the potential consequences of a beyond 

7 design basis accident at Calvert Cliffs-3 and should address potential additional risks of its First8 of-a-Kind reactor design. (0019-18 [Mariotte, Michael])

9 Comment: Because the scoping period of this EIS is occurring well in advance—literally, years 

10 in advance—of certification of the EPR design chosen for this reactor site, we have to defer 

11 additional comments on the safety issues related to this project. However, we fail to understand 

12 how the EIS can possibly address the fundamental issue of the environmental consequences of 

13 a severe accident without knowing the specific vulnerabilities of the chosen reactor design.

14 (0019-19 [Mariotte, Michael])

15 Comment: This design does not exist anywhere in the world. There are no operating EPRs 

16 anywhere in the world. And one of the most important things that an EIS does is examine the 

17 potential environmental consequences of a severe accident. But until you know the design 

18 strengths and weaknesses, and how they will be implemented, you don't know what the 

19 potential accident is. (0025-43 [Mariotte, Michael])

20 Response: The staff's EIS will address the potential environmental impacts of postulated 

21 design-basis and severe accidents in Chapter 5. The U.S. EPR was selected as the design for 

22 the proposed Calvert Cliffs Unit 3. In a separate action, the staff is evaluating the potential 

23 consequences of design-basis accidents and the probability and consequences of severe 

24 accidents for the U.S. EPR as part of its review of the application for certification of the reactor 

25 design. A detailed description of the design certification review is beyond the scope of the EIS. 

26 However, the staff uses well-established methods to analyze a new design to determine the 

27 potential consequences of accidents. The results of the certification review process will be 

28 compared to the results of the evaluation of the environmental impacts of potential radiological 

29 releases to assure consistency. 

30 Comment: The EIS should address the potential adverse environmental impacts of an accident 

31 involving a significant release of radiation from at Units 1 & 2 on the safe operation of the new 

32 co-located unit. (0019-23 [Mariotte, Michael])

33 Comment: The EIS must address possible consequences to Unit-3 of an accident at the Units 

34 1 & 2 fuel pools and/or at their dry cask storage units. (0019-8 [Mariotte, Michael])
Appendix D 

Draft NUREG-1936 D-54 April 2010 

1 Comment: I just wanted to point out the risks that will come with having two old reactors at 

2 Calvert Cliffs combined with having a new reactor at Calvert Cliffs. (0024-76 [Kamps, Kevin])

3 Comment: The most recent such report that the agency has done way back in 1982, and the 

4 peak early fatalities that they estimated for Calvert Cliffs 1 and 2 were 5,600 peak early fatalities 

5 at each reactor in a major accident. The peak early injuries were 15,000 at each reactor. The 

6 peak cancer deaths were 23,000. So that's a lot of injuries and deaths. A grand total of 87,200 

7 deaths and injuries if there's a major accident involving both reactors at that site right now. 

8 Adding a third reactor would add more risk there. (0024-77 [Kamps, Kevin])

9 Response: In Chapter 5 of the EIS, the staff will address risks associated with both normal 

10 operation of the proposed reactor and postulated severe accidents. The staff will also address 

11 the cumulative risks of operation of the existing reactors and the proposed new reactor. 

12 Comment: The EIS should address potential consequences of a serious accident in the 

13 irradiated fuel pool at new sites and in other potential high-level radioactive waste storage 

14 facilities. (0008-3 [Acevedo, NK] [Aitken, Keith] [Albright, Evan] [Andereson, David] [Arist, Phyllis] 

15 [Armas, Zoe] [Avance, Kenneth] [Bainum, Meghan] [Bakalian, Craig] [Baldwin, Natylie] [Barr, Phillip] 

16 [Bartholomew, Alice] [Becker, Rochelle] [Bedding, Gerhard] [Behabadi, Bardia] [Be, Maya] [Bissonnette, 

17 Rick] [Black, Monica Latka] [Blomstrom, Eric] [Borrowman, Ellen] [Briggs, Ruth] [Chinn, Jason] [Clark, 

18 Kevin] [Clark, Loralee] [Cleaver, Melissa] [Cox, Duncan] [Crawley, Jackie] [Crocca, Carol] [C, Suzy] [Culp, 

19 Richard] [Curington, Diana] [Daddy, Big] [Darbyshire, David] [DesHarnais, Gaston] [Diaz, Lorenzo] [Dolly, 

20 William] [Emmons, Cheryl] [Erdesohn, Cynthia] [Evans, Michael] [Faigle, Susan] [Fernow, Geoff] [Finnelli, 

21 Marilyn and Tom] [Fisher, Allison] [Foppe, Paul] [Fuller, Alfred] [Futterer, Joe] [Gannaway, Gloria] 

22 [Garbato, Kelly] [Garner, Patrick] [Gilpin, John] [Good, Riana] [Goodrich, Anne] [Grad, Robert] [Grand, 

23 Robert] [Grassi, Rosemarie] [Guay-Brezner, Colette] [Harberson, Laurie] [Hauck, Molly] [Hedlund, Cara] 

24 [Helvick, Steven] [Henderson, Sherry] [Hinton, Georgia] [Hoffman, Lilli] [Holzer, Frederick] [Hood, Marilyn] 

25 [Hooker, Betsy] [Huffman, Debbie] [Hughey, Patricia] [Hung, Shiu] [Hutchinson, Richard] [Jones26 Giampalo, Mary] [Jones, Hollis] [Joos, Sandra] [Jula, Patty] [Kaliski, Raymond] [Kane, Donna] [Katz, 

27 Shari] [Klusman, Eric] [Knechel, David] [Kramer, Loren] [Kuintzle, Gaylene] [Lack, Robert] [Lallo, Patrick] 

28 [LaLumia, Anne Marie] [LaMonica, Francoise] [Latham, Rhonda] [LaVigne, Carole] [Lee, Angela] [Loew, 

29 Brenda] [Luczkowiak, Christopher] [MacNulty, Joy] [Magee, L] [Manske, Jill] [Marcus, Jack David] [Marks, 

30 John] [Marsh, Rauni] [Massey, Tom] [McArthur, Richard] [McClure, Matthew] [McCoy, Timothy] 

31 [McKenna, Chris] [McKenna, Kathy] [McKenna, Lauren] [McKenna, Rick] [M, Crystal] [Metz, Richard] 

32 [Minault, Kent] [Miranda, Tina] [Moore, Kerry] [Mostov, Liz] [Munson, Clarence William] [Nagle, Thomas] 

33 [Nanfra, Freya] [Nash, James] [Nerode, Gregory] [Novick, Wesley] [Nunez, Albert] [Nunez, Carlos] 

34 [Oakes, Bonnie] [Olmstead, Harry] [O'Meara, Patrick] [Pacheco-Theard, Lauren] [Paquet, Kevin] 

35 [Parsons, Barry] [Paul, Georgia] [Pedraza-Tucker, Liette] [Petkiewicz, Margaret] [Phipps, Donald] [Piner, 

36 Lisa] [Piser, Daniel] [Putney, Louis] [Rader, Nancy] [Radford Jr., Roger] [Raines, Mary] [Ramstrom, Eric G 

37 and Shirley S] [Randall, David] [Rankin, Susan] [Reidenbach, Gregory] [Rosenblum, Stephen] [Ross, 

38 Anne] [Sather, Alice] [Sauer, Elizabeth] [Schmidt, Jason] [Schopp, Ricky] [Schwarz, Walter] [See, Bud] 

39 [Shafer, Scott] [Shashani, Linda] [Sherrow, Sarah] [Shively, Daniel] [Siecke, Martin] [Simila, Owen] 

40 [Skercevic, Maria] [Smith, Enoch] [Smith, Martha] [Snowden, Patricia] [Sorin, Susanna] [Soroos, Marvin 

41 S] [Soto, Yvonne] [Stevens, Denise] [Stilwell, Lisa] [Strange, Linda] [Theil, Tony] [Thiele, Abhaya] 
Appendix D 

April 2010 D-55 Draft NUREG-1936 

1 [Tornatore, James] [Trenholme, Art] [Turner, Tamisha] [Valliere, Cliff] [VanEtten, Margot] [Vieg, 

2 Jeannette] [Voeller, Estelle] [Wadkins, Melanie] [Waldman, Sam] [Walker-Meere, Susan] [Walsh, Donald] 

3 [Walters, Betty] [Wanner, Gabrielle] [Ward, John] [Welch, Irene] [Wilkins, Paul] [Willoughby, CaraLea] 

4 [Wilson, Deb] [Yeatts, Jordan] [Zastawecky, Margaret] [Zelikson, Linda])

5 Comment: The EIS must address potential consequences (on the Bay, on people, on flora and 

6 fauna in the region) of a serious accident in the irradiated fuel pool at Calvert Cliffs-3, and in 

7 other potential high-level radioactive waste storage facilities. (0019-7 [Mariotte, Michael])

8 Response: The staff will assess the impacts of postulated fuel handling accidents in the spent 

9 fuel pool in Chapter 5 of the EIS. Evaluation of the consequences of postulated accidents at the 

10 Calvert Cliffs Independent Spent Fuel Storage Installation, which is licensed separately, is 

11 outside the scope of the environmental review for the proposed reactors.

12 Comment: I would point out that if there's an accident at Calvert Cliffs, even a minor one, that 

13 there will be radiological stigma associated with that. The NRC should consider that in its 

14 socioeconomic analysis. The impact on tourism, the impact on fisheries, the impact on all 

15 aspects of the economy in this region, if there's even a small accident at Calvert Cliffs, let alone 

16 a major one. (0024-79 [Kamps, Kevin])

17 Response: The environmental review focuses on the radioactive material releases and 

18 radiation doses and risks to humans from postulated accidents. The results of the accident 

19 evaluation will be presented in Chapter 5 of the EIS. However, environmental impacts related to 

20 “radiological stigma” are outside the scope of the review. 

21 14. Comments Concerning the Uranium Fuel Cycle

22 Comment: Spent reactor fuel, which some call high level waste, is not a problem. It is easily 

23 sealed from the biosphere and stored. Do not succumb to rants and raves. Future generations 

24 will much more easily cope with stored spent fuel than with the consequences of global climate 

25 change. (0012-1 [Ireland, John])

26 Response: This comment does not provide specific information relating to the environmental 

27 effects of the proposed action. It is outside the scope of the EIS and is listed to compile a 

28 complete record of the comments received. 

29 Comment: While I favor increased nuclear power development I am very concerned about the 

30 disposal or re-processing of waste. The best idea seems to me to be reprocessing it. We would 

31 need to repeal the presidential directive against this but the directive is very out of date with 

32 current technology. Be that as it may, we must deal with the waste disposal issue up front!

33 (0011-1 [Trenholme, Art])
Appendix D 

Draft NUREG-1936 D-56 April 2010 

1 Comment: [T]he EIS should consider recent proposals that storage of spent fuel for several 

2 hundred years will reduce its radioactivity to the point where reprocessing will be far less difficult 

3 than if it were reprocessed a few years after removal from the reactor. Such intermediate term 

4 storage would eliminate the necessity for materials stored in Yucca Mountain to remain 

5 physically and chemically stable for hundreds of millennia. (0025-61 [Meadow, Norm]) (0028-36

6 [Meadow, Norman])

7 Response: Federal policy no longer prohibits reprocessing. The Energy Policy Act of 2005, 

8 P.L. 109-58, authorized the DOE to conduct an advanced fuel recycling technology research 

9 and development program to evaluate proliferation-resistant fuel recycling and transmutation 

10 technologies that minimize environmental or public health and safety impacts. Additional work 

11 is needed before commercial reprocessing and recycling of spent fuel produced in the 

12 U.S. commercial nuclear power program is likely. Reprocessing as part of the fuel cycle and 

13 waste management will be discussed in Chapter 6. 

14 Comment: There is going to have to be a method obtained for storage of low-level waste or 

15 you are going to shut down a lot of very valuable medical diagnoses, because diagnostic 

16 procedures and therapeutic procedures all involve the production of what's known as low-level 

17 waste. (0025-62 [Meadow, Norm])

18 Response: This comment expresses the concern for storage and disposal of medical low-level 

19 waste. Although waste disposal issues are similar, because medical waste is not generated 

20 from nuclear power production, this comment is outside the scope of this EIS. 

21 Comment: The EIS should address the possible effects of new reactors on existing dry cask 

22 irradiated fuel storage units at the plant, including their potential degradation over time as well 

23 as the potential impacts of a large expansion of the dry cask units to store high-level radioactive 

24 waste from new reactors. (0008-4 [Acevedo, NK] [Aitken, Keith] [Albright, Evan] [Andereson, David] 

25 [Arist, Phyllis] [Armas, Zoe] [Avance, Kenneth] [Bainum, Meghan] [Bakalian, Craig] [Baldwin, Natylie] 

26 [Barr, Phillip] [Bartholomew, Alice] [Becker, Rochelle] [Bedding, Gerhard] [Behabadi, Bardia] [Be, Maya] 

27 [Bissonnette, Rick] [Black, Monica Latka] [Blomstrom, Eric] [Borrowman, Ellen] [Briggs, Ruth] [Chinn, 

28 Jason] [Clark, Kevin] [Clark, Loralee] [Cleaver, Melissa] [Cox, Duncan] [Crawley, Jackie] [Crocca, Carol] 

29 [C, Suzy] [Culp, Richard] [Curington, Diana] [Daddy, Big] [Darbyshire, David] [DesHarnais, Gaston] [Diaz, 

30 Lorenzo] [Dolly, William] [Emmons, Cheryl] [Erdesohn, Cynthia] [Evans, Michael] [Faigle, Susan] [Fernow, 

31 Geoff] [Finnelli, Marilyn and Tom] [Fisher, Allison] [Foppe, Paul] [Fuller, Alfred] [Futterer, Joe] [Gannaway, 

32 Gloria] [Garbato, Kelly] [Garner, Patrick] [Gilpin, John] [Good, Riana] [Goodrich, Anne] [Grad, Robert] 

33 [Grand, Robert] [Grassi, Rosemarie] [Guay-Brezner, Colette] [Harberson, Laurie] [Hauck, Molly] [Hedlund, 

34 Cara] [Helvick, Steven] [Henderson, Sherry] [Hinton, Georgia] [Hoffman, Lilli] [Holzer, Frederick] [Hood, 

35 Marilyn] [Hooker, Betsy] [Huffman, Debbie] [Hughey, Patricia] [Hung, Shiu] [Hutchinson, Richard] [Jones36 Giampalo, Mary] [Jones, Hollis] [Joos, Sandra] [Jula, Patty] [Kaliski, Raymond] [Kane, Donna] [Katz, 

37 Shari] [Klusman, Eric] [Knechel, David] [Kramer, Loren] [Kuintzle, Gaylene] [Lack, Robert] [Lallo, Patrick] 

38 [LaLumia, Anne Marie] [LaMonica, Francoise] [Latham, Rhonda] [LaVigne, Carole] [Lee, Angela] [Loew, 

39 Brenda] [Luczkowiak, Christopher] [MacNulty, Joy] [Magee, L] [Manske, Jill] [Marcus, Jack David] [Marks, 
Appendix D 

April 2010 D-57 Draft NUREG-1936 

1 John] [Marsh, Rauni] [Massey, Tom] [McArthur, Richard] [McClure, Matthew] [McCoy, Timothy] 

2 [McKenna, Chris] [McKenna, Kathy] [McKenna, Lauren] [McKenna, Rick] [M, Crystal] [Metz, Richard] 

3 [Minault, Kent] [Miranda, Tina] [Moore, Kerry] [Mostov, Liz] [Munson, Clarence William] [Nagle, Thomas] 

4 [Nanfra, Freya] [Nash, James] [Nerode, Gregory] [Novick, Wesley] [Nunez, Albert] [Nunez, Carlos] 

5 [Oakes, Bonnie] [Olmstead, Harry] [O'Meara, Patrick] [Pacheco-Theard, Lauren] [Paquet, Kevin] 

6 [Parsons, Barry] [Paul, Georgia] [Pedraza-Tucker, Liette] [Petkiewicz, Margaret] [Phipps, Donald] [Piner, 

7 Lisa] [Piser, Daniel] [Putney, Louis] [Rader, Nancy] [Radford Jr., Roger] [Raines, Mary] [Ramstrom, Eric G 

8 and Shirley S] [Randall, David] [Rankin, Susan] [Reidenbach, Gregory] [Rosenblum, Stephen] [Ross, 

9 Anne] [Sather, Alice] [Sauer, Elizabeth] [Schmidt, Jason] [Schopp, Ricky] [Schwarz, Walter] [See, Bud] 

10 [Shafer, Scott] [Shashani, Linda] [Sherrow, Sarah] [Shively, Daniel] [Siecke, Martin] [Simila, Owen] 

11 [Skercevic, Maria] [Smith, Enoch] [Smith, Martha] [Snowden, Patricia] [Sorin, Susanna] [Soroos, Marvin 

12 S] [Soto, Yvonne] [Stevens, Denise] [Stilwell, Lisa] [Strange, Linda] [Theil, Tony] [Thiele, Abhaya] 

13 [Tornatore, James] [Trenholme, Art] [Turner, Tamisha] [Valliere, Cliff] [VanEtten, Margot] [Vieg, 

14 Jeannette] [Voeller, Estelle] [Wadkins, Melanie] [Waldman, Sam] [Walker-Meere, Susan] [Walsh, Donald] 

15 [Walters, Betty] [Wanner, Gabrielle] [Ward, John] [Welch, Irene] [Wilkins, Paul] [Willoughby, CaraLea] 

16 [Wilson, Deb] [Yeatts, Jordan] [Zastawecky, Margaret] [Zelikson, Linda])

17 Comment: The EIS must address the possible effects of Calvert Cliffs-3 on the existing dry 

18 cask irradiated fuel storage units at the Calvert Cliffs site, including their potential degradation 

19 over time as well as the potential impacts of a large expansion of the dry cask units to store 

20 high-level radioactive waste from Calvert Cliffs-3. (0019-9 [Mariotte, Michael])

21 Comment: I just want to touch, before I close, on the risks that high-level radioactive waste 

22 presents to the Chesapeake Bay and to local residents and residents who live as far away as 

23 Prince George's County where I live. There is the risks of storage. The wastes are stored in the 

24 indoor pool and the outdoor dry casks. These wastes in the pool and in the dry casks are 

25 vulnerable to accidents, they are vulnerable to attacks. (0025-96 [Kamps, Kevin])

26 Comment: We are really looking at this dilemma of what to do. We're looking at a century or 

27 more of dry cask storage, and people should just remember that these containers are made out 

28 of concrete and steel, both of which deteriorate with age and with exposure to the elements.

29 (0025-98 [Kamps, Kevin])

30 Comment: The MCC [Maryland Conservation Council] believes that current methods for on31 site storage of spent fuel have proven adequate and safe for several decades. (0028-35

32 [Meadow, Norman])

33 Response: The safety and environmental effects of long-term storage of spent fuel onsite has 

34 been evaluated by the NRC, and, as set forth in the Waste Confidence Rule, the NRC 

35 generically determined that such storage can be accomplished without significant environmental 

36 impact. In the Waste Confidence Rule, the Commission determined that spent fuel can be 

37 stored onsite for at least 30 years beyond the licensed operating life, which includes the term of 

38 a renewed license. The NRC has a certification process for casks, regulated by 10 CFR Part 
Appendix D 

Draft NUREG-1936 D-58 April 2010 

1 72. Such wastes are under continual licensing control. The uranium fuel cycle will be 

2 discussed in Chapter 6 of the EIS. 

3 Comment: [T]o be more accepted by the US society, the nuclear industry must solve the 

4 nuclear waste disposal issue, its most prominent Achilles heel. Any attempt at renewing or 

5 expanding nuclear power as a source of electricity would be greatly advanced if this issue finally 

6 were settled after decades of debate without resolution. If the industry is to renew or expand, 

7 now is the time to finally settle the waste disposal issue, both technically and socially. (0004-5

8 [Arndt, Gunter])

9 Comment: Nuclear waste is dangerous and there is no permanent destination where it can be 

10 stored safely. Although nuclear power stations provide energy to millions of people in various 

11 countries worldwide, no one has come up with a clean and safe solution for what to do with 

12 nuclear waste. It will only build up, and should anything happen to it, it will be nightmarish for the 

13 local councils to deal with. (0007-2 [Shannahan, Brittany])

14 Comment: The Nuclear Waste Confidence Decision provides little solace to the nuclear waste 

15 management issue. In the nearly thirty years since the decision was issued we have gotten no 

16 closer to licensing a geologic repository. In the meanwhile, high-level radioactive waste is 

17 mounting up at 104 reactors sites throughout the country. If the nuclear industry wants to 

18 seriously consider moving forward with a new generation of nuclear reactors, then the true cost 

19 of waste issues must be evaluated accordingly. (0008-1 [Acevedo, NK] [Aitken, Keith] [Albright, 

20 Evan] [Andereson, David] [Arist, Phyllis] [Armas, Zoe] [Avance, Kenneth] [Bainum, Meghan] [Bakalian, 

21 Craig] [Baldwin, Natylie] [Barr, Phillip] [Bartholomew, Alice] [Becker, Rochelle] [Bedding, Gerhard] 

22 [Behabadi, Bardia] [Be, Maya] [Bissonnette, Rick] [Black, Monica Latka] [Blomstrom, Eric] [Borrowman, 

23 Ellen] [Briggs, Ruth] [Chinn, Jason] [Clark, Kevin] [Clark, Loralee] [Cleaver, Melissa] [Cox, Duncan] 

24 [Crawley, Jackie] [Crocca, Carol] [C, Suzy] [Culp, Richard] [Curington, Diana] [Daddy, Big] [Darbyshire, 

25 David] [DesHarnais, Gaston] [Diaz, Lorenzo] [Dolly, William] [Emmons, Cheryl] [Erdesohn, Cynthia] 

26 [Evans, Michael] [Faigle, Susan] [Fernow, Geoff] [Finnelli, Marilyn and Tom] [Fisher, Allison] [Foppe, Paul] 

27 [Fuller, Alfred] [Futterer, Joe] [Gannaway, Gloria] [Garbato, Kelly] [Garner, Patrick] [Gilpin, John] [Good, 

28 Riana] [Goodrich, Anne] [Grad, Robert] [Grand, Robert] [Grassi, Rosemarie] [Guay-Brezner, Colette] 

29 [Harberson, Laurie] [Hauck, Molly] [Hedlund, Cara] [Helvick, Steven] [Henderson, Sherry] [Hinton, 

30 Georgia] [Hoffman, Lilli] [Holzer, Frederick] [Hood, Marilyn] [Hooker, Betsy] [Huffman, Debbie] [Hughey, 

31 Patricia] [Hung, Shiu] [Hutchinson, Richard] [Jones-Giampalo, Mary] [Jones, Hollis] [Joos, Sandra] [Jula, 

32 Patty] [Kaliski, Raymond] [Kane, Donna] [Katz, Shari] [Klusman, Eric] [Knechel, David] [Kramer, Loren] 

33 [Kuintzle, Gaylene] [Lack, Robert] [Lallo, Patrick] [LaLumia, Anne Marie] [LaMonica, Francoise] [Latham, 

34 Rhonda] [LaVigne, Carole] [Lee, Angela] [Loew, Brenda] [Luczkowiak, Christopher] [MacNulty, Joy] 

35 [Magee, L] [Manske, Jill] [Marcus, Jack David] [Marks, John] [Marsh, Rauni] [Massey, Tom] [McArthur, 

36 Richard] [McClure, Matthew] [McCoy, Timothy] [McKenna, Chris] [McKenna, Kathy] [McKenna, Lauren] 

37 [McKenna, Rick] [M, Crystal] [Metz, Richard] [Minault, Kent] [Miranda, Tina] [Moore, Kerry] [Mostov, Liz] 

38 [Munson, Clarence William] [Nagle, Thomas] [Nanfra, Freya] [Nash, James] [Nerode, Gregory] [Novick, 

39 Wesley] [Nunez, Albert] [Nunez, Carlos] [Oakes, Bonnie] [Olmstead, Harry] [O'Meara, Patrick] [Pacheco40 Theard, Lauren] [Paquet, Kevin] [Parsons, Barry] [Paul, Georgia] [Pedraza-Tucker, Liette] [Petkiewicz, 
Appendix D 

April 2010 D-59 Draft NUREG-1936 

1 Margaret] [Phipps, Donald] [Piner, Lisa] [Piser, Daniel] [Putney, Louis] [Rader, Nancy] [Radford Jr., 

2 Roger] [Raines, Mary] [Ramstrom, Eric G and Shirley S] [Randall, David] [Rankin, Susan] [Reidenbach, 

3 Gregory] [Rosenblum, Stephen] [Ross, Anne] [Sather, Alice] [Sauer, Elizabeth] [Schmidt, Jason] [Schopp, 

4 Ricky] [Schwarz, Walter] [See, Bud] [Shafer, Scott] [Shashani, Linda] [Sherrow, Sarah] [Shively, Daniel] 

5 [Siecke, Martin] [Simila, Owen] [Skercevic, Maria] [Smith, Enoch] [Smith, Martha] [Snowden, Patricia] 

6 [Sorin, Susanna] [Soroos, Marvin S] [Soto, Yvonne] [Stevens, Denise] [Stilwell, Lisa] [Strange, Linda] 

7 [Theil, Tony] [Thiele, Abhaya] [Tornatore, James] [Trenholme, Art] [Turner, Tamisha] [Valliere, Cliff] 

8 [VanEtten, Margot] [Vieg, Jeannette] [Voeller, Estelle] [Wadkins, Melanie] [Waldman, Sam] [Walker9 Meere, Susan] [Walsh, Donald] [Walters, Betty] [Wanner, Gabrielle] [Ward, John] [Welch, Irene] [Wilkins, 

10 Paul] [Willoughby, CaraLea] [Wilson, Deb] [Yeatts, Jordan] [Zastawecky, Margaret] [Zelikson, Linda])

11 Comment: The Environmental Impact Statements (EIS) should fully address the potential 

12 consequences of permanent storage of high-level radioactive waste. Because there is no 

13 permanent storage facility for high-level radioactive waste, and it appears increasingly unlikely 

14 that there will be one during the lifetime of a new generation of reactors, the EIS should address 

15 how and where all of the high-level radioactive waste will be stored. (0008-2 [Acevedo, NK] [Aitken, 

16 Keith] [Albright, Evan] [Andereson, David] [Arist, Phyllis] [Armas, Zoe] [Avance, Kenneth] [Bainum, 

17 Meghan] [Bakalian, Craig] [Baldwin, Natylie] [Barr, Phillip] [Bartholomew, Alice] [Becker, Rochelle] 

18 [Bedding, Gerhard] [Behabadi, Bardia] [Be, Maya] [Bissonnette, Rick] [Black, Monica Latka] [Blomstrom, 

19 Eric] [Borrowman, Ellen] [Briggs, Ruth] [Chinn, Jason] [Clark, Kevin] [Clark, Loralee] [Cleaver, Melissa] 

20 [Cox, Duncan] [Crawley, Jackie] [Crocca, Carol] [C, Suzy] [Culp, Richard] [Curington, Diana] [Daddy, Big] 

21 [Darbyshire, David] [DesHarnais, Gaston] [Diaz, Lorenzo] [Dolly, William] [Emmons, Cheryl] [Erdesohn, 

22 Cynthia] [Evans, Michael] [Faigle, Susan] [Fernow, Geoff] [Finnelli, Marilyn and Tom] [Fisher, Allison] 

23 [Foppe, Paul] [Fuller, Alfred] [Futterer, Joe] [Gannaway, Gloria] [Garbato, Kelly] [Garner, Patrick] [Gilpin, 

24 John] [Good, Riana] [Goodrich, Anne] [Grad, Robert] [Grand, Robert] [Grassi, Rosemarie] [Guay-Brezner, 

25 Colette] [Harberson, Laurie] [Hauck, Molly] [Hedlund, Cara] [Helvick, Steven] [Henderson, Sherry] [Hinton, 

26 Georgia] [Hoffman, Lilli] [Holzer, Frederick] [Hood, Marilyn] [Hooker, Betsy] [Huffman, Debbie] [Hughey, 

27 Patricia] [Hung, Shiu] [Hutchinson, Richard] [Jones-Giampalo, Mary] [Jones, Hollis] [Joos, Sandra] [Jula, 

28 Patty] [Kaliski, Raymond] [Kane, Donna] [Katz, Shari] [Klusman, Eric] [Knechel, David] [Kramer, Loren] 

29 [Kuintzle, Gaylene] [Lack, Robert] [Lallo, Patrick] [LaLumia, Anne Marie] [LaMonica, Francoise] [Latham, 

30 Rhonda] [LaVigne, Carole] [Lee, Angela] [Loew, Brenda] [Luczkowiak, Christopher] [MacNulty, Joy] 

31 [Magee, L] [Manske, Jill] [Marcus, Jack David] [Marks, John] [Marsh, Rauni] [Massey, Tom] [McArthur, 

32 Richard] [McClure, Matthew] [McCoy, Timothy] [McKenna, Chris] [McKenna, Kathy] [McKenna, Lauren] 

33 [McKenna, Rick] [M, Crystal] [Metz, Richard] [Minault, Kent] [Miranda, Tina] [Moore, Kerry] [Mostov, Liz] 

34 [Munson, Clarence William] [Nagle, Thomas] [Nanfra, Freya] [Nash, James] [Nerode, Gregory] [Novick, 

35 Wesley] [Nunez, Albert] [Nunez, Carlos] [Oakes, Bonnie] [Olmstead, Harry] [O'Meara, Patrick] [Pacheco36 Theard, Lauren] [Paquet, Kevin] [Parsons, Barry] [Paul, Georgia] [Pedraza-Tucker, Liette] [Petkiewicz, 

37 Margaret] [Phipps, Donald] [Piner, Lisa] [Piser, Daniel] [Putney, Louis] [Rader, Nancy] [Radford Jr., 

38 Roger] [Raines, Mary] [Ramstrom, Eric G and Shirley S] [Randall, David] [Rankin, Susan] [Reidenbach, 

39 Gregory] [Rosenblum, Stephen] [Ross, Anne] [Sather, Alice] [Sauer, Elizabeth] [Schmidt, Jason] [Schopp, 

40 Ricky] [Schwarz, Walter] [See, Bud] [Shafer, Scott] [Shashani, Linda] [Sherrow, Sarah] [Shively, Daniel] 

41 [Siecke, Martin] [Simila, Owen] [Skercevic, Maria] [Smith, Enoch] [Smith, Martha] [Snowden, Patricia] 

42 [Sorin, Susanna] [Soroos, Marvin S] [Soto, Yvonne] [Stevens, Denise] [Stilwell, Lisa] [Strange, Linda] 

43 [Theil, Tony] [Thiele, Abhaya] [Tornatore, James] [Trenholme, Art] [Turner, Tamisha] [Valliere, Cliff] 

44 [VanEtten, Margot] [Vieg, Jeannette] [Voeller, Estelle] [Wadkins, Melanie] [Waldman, Sam] [Walker-
Appendix D 

Draft NUREG-1936 D-60 April 2010 

1 Meere, Susan] [Walsh, Donald] [Walters, Betty] [Wanner, Gabrielle] [Ward, John] [Welch, Irene] [Wilkins, 

2 Paul] [Willoughby, CaraLea] [Wilson, Deb] [Yeatts, Jordan] [Zastawecky, Margaret] [Zelikson, Linda])

3 Comment: We cannot begin to consider the expansion of nuclear power, while the issues of 

4 the previous generation remain unresolved. (0008-6 [Acevedo, NK] [Aitken, Keith] [Albright, Evan] 

5 [Andereson, David] [Arist, Phyllis] [Armas, Zoe] [Avance, Kenneth] [Bainum, Meghan] [Bakalian, Craig] 

6 [Baldwin, Natylie] [Barr, Phillip] [Bartholomew, Alice] [Becker, Rochelle] [Bedding, Gerhard] [Behabadi, 

7 Bardia] [Be, Maya] [Bissonnette, Rick] [Black, Monica Latka] [Blomstrom, Eric] [Borrowman, Ellen] 

8 [Briggs, Ruth] [Chinn, Jason] [Clark, Kevin] [Clark, Loralee] [Cleaver, Melissa] [Cox, Duncan] [Crawley, 

9 Jackie] [Crocca, Carol] [C, Suzy] [Culp, Richard] [Curington, Diana] [Daddy, Big] [Darbyshire, David] 

10 [DesHarnais, Gaston] [Diaz, Lorenzo] [Dolly, William] [Emmons, Cheryl] [Erdesohn, Cynthia] [Evans, 

11 Michael] [Faigle, Susan] [Fernow, Geoff] [Finnelli, Marilyn and Tom] [Fisher, Allison] [Foppe, Paul] [Fuller, 

12 Alfred] [Futterer, Joe] [Gannaway, Gloria] [Garbato, Kelly] [Garner, Patrick] [Gilpin, John] [Good, Riana] 

13 [Goodrich, Anne] [Grad, Robert] [Grand, Robert] [Grassi, Rosemarie] [Guay-Brezner, Colette] [Harberson, 

14 Laurie] [Hauck, Molly] [Hedlund, Cara] [Helvick, Steven] [Henderson, Sherry] [Hinton, Georgia] [Hoffman, 

15 Lilli] [Holzer, Frederick] [Hood, Marilyn] [Hooker, Betsy] [Huffman, Debbie] [Hughey, Patricia] [Hung, Shiu] 

16 [Hutchinson, Richard] [Jones-Giampalo, Mary] [Jones, Hollis] [Joos, Sandra] [Jula, Patty] [Kaliski, 

17 Raymond] [Kane, Donna] [Katz, Shari] [Klusman, Eric] [Knechel, David] [Kramer, Loren] [Kuintzle, 

18 Gaylene] [Lack, Robert] [Lallo, Patrick] [LaLumia, Anne Marie] [LaMonica, Francoise] [Latham, Rhonda] 

19 [LaVigne, Carole] [Lee, Angela] [Loew, Brenda] [Luczkowiak, Christopher] [MacNulty, Joy] [Magee, L] 

20 [Manske, Jill] [Marcus, Jack David] [Marks, John] [Marsh, Rauni] [Massey, Tom] [McArthur, Richard] 

21 [McClure, Matthew] [McCoy, Timothy] [McKenna, Chris] [McKenna, Kathy] [McKenna, Lauren] [McKenna, 

22 Rick] [M, Crystal] [Metz, Richard] [Minault, Kent] [Miranda, Tina] [Moore, Kerry] [Mostov, Liz] [Munson, 

23 Clarence William] [Nagle, Thomas] [Nanfra, Freya] [Nash, James] [Nerode, Gregory] [Novick, Wesley] 

24 [Nunez, Albert] [Nunez, Carlos] [Oakes, Bonnie] [Olmstead, Harry] [O'Meara, Patrick] [Pacheco-Theard, 

25 Lauren] [Paquet, Kevin] [Parsons, Barry] [Paul, Georgia] [Pedraza-Tucker, Liette] [Petkiewicz, Margaret] 

26 [Phipps, Donald] [Piner, Lisa] [Piser, Daniel] [Putney, Louis] [Rader, Nancy] [Radford Jr., Roger] [Raines, 

27 Mary] [Ramstrom, Eric G and Shirley S] [Randall, David] [Rankin, Susan] [Reidenbach, Gregory] 

28 [Rosenblum, Stephen] [Ross, Anne] [Sather, Alice] [Sauer, Elizabeth] [Schmidt, Jason] [Schopp, Ricky] 

29 [Schwarz, Walter] [See, Bud] [Shafer, Scott] [Shashani, Linda] [Sherrow, Sarah] [Shively, Daniel] [Siecke, 

30 Martin] [Simila, Owen] [Skercevic, Maria] [Smith, Enoch] [Smith, Martha] [Snowden, Patricia] [Sorin, 

31 Susanna] [Soroos, Marvin S] [Soto, Yvonne] [Stevens, Denise] [Stilwell, Lisa] [Strange, Linda] [Theil, 

32 Tony] [Thiele, Abhaya] [Tornatore, James] [Trenholme, Art] [Turner, Tamisha] [Valliere, Cliff] [VanEtten, 

33 Margot] [Vieg, Jeannette] [Voeller, Estelle] [Wadkins, Melanie] [Waldman, Sam] [Walker-Meere, Susan] 

34 [Walsh, Donald] [Walters, Betty] [Wanner, Gabrielle] [Ward, John] [Welch, Irene] [Wilkins, Paul] 

35 [Willoughby, CaraLea] [Wilson, Deb] [Yeatts, Jordan] [Zastawecky, Margaret] [Zelikson, Linda])

36 Comment: The Environmental Impact Statements (EIS) should fully address the potential 

37 consequences of permanent storage of high-level radioactive waste. The EIS should address 

38 how and where all of the high-level radioactive waste will be stored. (0009-1 [Thiele, Abhaya])

39 Comment: The Environmental Impact Statements (EIS) should fully address the potential 

40 consequences of permanent storage of high-level radioactive waste. Because there is no 

41 permanent storage facility for high-level radioactive waste, and it appears increasingly unlikely 
Appendix D 

April 2010 D-61 Draft NUREG-1936 

1 that there will be one during the lifetime of a new generation of reactors, the EIS should address 

2 how and where all of the high-level radioactive waste will be stored. (0010-1 [Polya, Lance])

3 Comment: How and where will you dispose of hazardous waste material? Where do you 

4 currently dispose of waste? How will you manage debris from building the reactor? How much 

5 waste do you currently dispose and how much will this increase with the new reactor? What 

6 qualifies as hazardous by the regulatory committee? (0018-4 [Mackall, Kimberly])

7 Comment: The EIS must address how and where all of the "low-level" radioactive waste 

8 Calvert Cliffs-3 can be expected to generate during its lifetime will be stored. (0019-13 [Mariotte, 

9 Michael])

10 Comment: [T]he EIS should assume that all Class B and above "low-level" radioactive waste 

11 generated by Calvert Cliffs-3 will be stored on-site for its licensed lifetime and describe how this 

12 material will remain isolated from the environment in perpetuity. (0019-14 [Mariotte, Michael])

13 Comment: [T]he EIS should report the amount of "low-level" nuclear waste, in volume and 

14 radioactivity, that Calvert Cliffs' operators plan to treat as if not radioactive--that is, plan to send 

15 to facilities without specific licenses for nuclear waste. These include solid and hazardous 

16 treatment, processing and disposal facilities as well as recyclers whose materials are released 

17 for restricted or unrestricted use, and should be identified and the radiological impacts and risks 

18 identified. (0019-15 [Mariotte, Michael])

19 Comment: Since radioactive waste could remain onsite forever, the site should be evaluated 

20 under 10 CFR 61, which include NRC's regulations for the disposal of radioactive waste. (0019-

21 16 [Mariotte, Michael])

22 Comment: The EIS must fully address the potential consequences of permanent storage of 

23 high- level radioactive waste adjacent to the Chesapeake Bay. There is no currently no 

24 permanent storage facility for high-level radioactive waste. Even if the proposed Yucca 

25 Mountain site opens during the operating lifetime of Calvert Cliffs-3, this reactor will, by law, not 

26 be eligible to have its high-level waste stored there. Thus, the EIS must assume that there will 

27 be no available high-level radioactive waste repository for the full operating lifetime (plus 

28 possible license extension) of this unit, and the EIS must fully address how and where all of the 

29 high-level radioactive waste generated by Calvert Cliffs-3 will be stored on-site, and what 

30 measures will be taken to ensure that the radioactivity from this waste remains permanently 

31 isolated from the environment. (0019-6 [Mariotte, Michael])

32 Comment: [P]lease look carefully and impartially at the problems entailed in dealing with 

33 radioactive waste. (0020-2 [Donn, Marjory])
Appendix D 

Draft NUREG-1936 D-62 April 2010 

1 Comment: [W]e still do not have good ways to deal with the radioactive material that nuclear 

2 power produces. I do not believe there is any good way to store it, yet we keep on producing it, 

3 poisoning the earth that we will pass on to future generations. (0020-5 [Donn, Marjory])

4 Comment: It is true that the Barnwell facility in South Carolina will be closed to low-level waste 

5 from the State of Maryland scheduled for June of this year. However, a very large majority, I 

6 think it's upward of 75 percent, of the low-level waste generated at commercial nuclear plants in 

7 the United States are shipped and disposed of in Clive, Utah, near Salt Lake City. (0024-103

8 [McGough, Mike])

9 Comment: I would point out that Yucca Mountain is looking more and more likely to never 

10 open which means that Calvert Cliffs will sit on thousands of tons of radioactive waste if that 

11 dump never opens. It already has a thousand tons. It will double or triple or quadruple that 

12 amount as time goes on. (0024-85 [Kamps, Kevin])

13 Comment: [T]he place where Calvert Cliffs has for decades dumped its so-called low level 

14 wastes, Barnwell, South Carolina, is closing for business, at least to the State of Maryland, June 

15 30th of this year. So not only is the high-level waste going to build but so will the low-level waste 

16 at Calvert Cliffs. A radioactive waste dilemma with no solution. (0024-86 [Kamps, Kevin])

17 Comment: I, as a resident of this state, don't want to be creating a waste product that has to 

18 be forced down the throats of the people in another state, especially if there is a reasonable 

19 alternative ... You know, we are just now becoming aware of the fact that we are releasing a lot 

20 of pollutants into the environment. We are changing the basic biochemistry and the biology and 

21 physics of the planet at an ever-accelerating rate, and we are starting to lose the species. (0025-

22 111 [Johnston, Bill])

23 Comment: The storage of the radiation, that's an amazing amount of radiation that is already 

24 here, radioactive material that is already here. We're not even going to get to put it into Yucca; 

25 we're going to have to come up with another place. Think about this, people: this stuff is going 

26 to be here forever. (0025-159 [Boxwell, Bob])

27 Comment: [E]ven if the proposed Yucca Mountain, Nevada waste dump were to open, and 

28 that seems increasingly unlikely, Calvert Cliffs 3 would not be eligible to put its waste there. So 

29 the high-level waste from this plant has nowhere to go until and unless the United States builds 

30 not the first one, which it has been trying to do for 30 years, but a second radioactive waste 

31 dump. (0025-50 [Mariotte, Michael])

32 Comment: This EIS has to consider the very real possibility that the waste generated at this 

33 facility will stay on the shores of the Chesapeake Bay in perpetuity, and what are the 

34 environmental impacts of that. (0025-51 [Mariotte, Michael])
Appendix D 

April 2010 D-63 Draft NUREG-1936 

1 Comment: [C]urrently, Calvert Cliffs is allowed to send its low-level waste to Barnwell, South 

2 Carolina for disposal. That ends this June. Barnwell is closing to outside waste. There are no 

3 plans to build a low-level waste facility to handle Maryland's waste. That means the low-level 

4 waste is going to have to stay onsite for the foreseeable future. The EIS has to look at the 

5 implications of 40, 60 years of generation of low level waste. Where is that going to go onsite? 

6 How is that going to be protected from the environment? (0025-52 [Mariotte, Michael])

7 Comment: [E]very pound of high-level waste that is generated by Calvert Cliffs 3 will be excess 

8 to Yucca's capacity. (0025-95 [Kamps, Kevin])

9 Comment: If you don't have an immediate solution to dealing with waste, then what makes you 

10 think one will be forthcoming in the future? (0026-1 [Marsh, Rauni]) 

11 Comment: Additionally, our plant in AZ has to store those waste rods in cool water until such 

12 time, that it's our turn to dispose of them. Water, Cool water, here in the Blatant hot dry desert.

13 (0026-4 [Marsh, Rauni])

14 Response: The NRC staff will evaluate the environmental impacts of the uranium fuel cycle 

15 including the impacts of fuel manufacturing, waste, transportation, and the onsite storage and 

16 eventual disposal of spent fuel. The results of this analysis will be presented in Chapter 6 of the 

17 EIS. 

18 15. Comments Concerning Transportation

19 Comment: The EIS should address possible effects of transportation of radioactive waste 

20 generated at the sites, in the unlikely event a waste repository ever will be built. This should 

21 include road, rail and barge transportation. (0008-5 [Acevedo, NK] [Aitken, Keith] [Albright, Evan] 

22 [Andereson, David] [Arist, Phyllis] [Armas, Zoe] [Avance, Kenneth] [Bainum, Meghan] [Bakalian, Craig] 

23 [Baldwin, Natylie] [Barr, Phillip] [Bartholomew, Alice] [Becker, Rochelle] [Bedding, Gerhard] [Behabadi, 

24 Bardia] [Be, Maya] [Bissonnette, Rick] [Black, Monica Latka] [Blomstrom, Eric] [Borrowman, Ellen] 

25 [Briggs, Ruth] [Chinn, Jason] [Clark, Kevin] [Clark, Loralee] [Cleaver, Melissa] [Cox, Duncan] [Crawley, 

26 Jackie] [Crocca, Carol] [C, Suzy] [Culp, Richard] [Curington, Diana] [Daddy, Big] [Darbyshire, David] 

27 [DesHarnais, Gaston] [Diaz, Lorenzo] [Dolly, William] [Emmons, Cheryl] [Erdesohn, Cynthia] [Evans, 

28 Michael] [Faigle, Susan] [Fernow, Geoff] [Finnelli, Marilyn and Tom] [Fisher, Allison] [Foppe, Paul] [Fuller, 

29 Alfred] [Futterer, Joe] [Gannaway, Gloria] [Garbato, Kelly] [Garner, Patrick] [Gilpin, John] [Good, Riana] 

30 [Goodrich, Anne] [Grad, Robert] [Grand, Robert] [Grassi, Rosemarie] [Guay-Brezner, Colette] [Harberson, 

31 Laurie] [Hauck, Molly] [Hedlund, Cara] [Helvick, Steven] [Henderson, Sherry] [Hinton, Georgia] [Hoffman, 

32 Lilli] [Holzer, Frederick] [Hood, Marilyn] [Hooker, Betsy] [Huffman, Debbie] [Hughey, Patricia] [Hung, Shiu] 

33 [Hutchinson, Richard] [Jones-Giampalo, Mary] [Jones, Hollis] [Joos, Sandra] [Jula, Patty] [Kaliski, 

34 Raymond] [Kane, Donna] [Katz, Shari] [Klusman, Eric] [Knechel, David] [Kramer, Loren] [Kuintzle, 

35 Gaylene] [Lack, Robert] [Lallo, Patrick] [LaLumia, Anne Marie] [LaMonica, Francoise] [Latham, Rhonda] 

36 [LaVigne, Carole] [Lee, Angela] [Loew, Brenda] [Luczkowiak, Christopher] [MacNulty, Joy] [Magee, L] 

37 [Manske, Jill] [Marcus, Jack David] [Marks, John] [Marsh, Rauni] [Massey, Tom] [McArthur, Richard] 
Appendix D 

Draft NUREG-1936 D-64 April 2010 

1 [McClure, Matthew] [McCoy, Timothy] [McKenna, Chris] [McKenna, Kathy] [McKenna, Lauren] [McKenna, 

2 Rick] [M, Crystal] [Metz, Richard] [Minault, Kent] [Miranda, Tina] [Moore, Kerry] [Mostov, Liz] [Munson, 

3 Clarence William] [Nagle, Thomas] [Nanfra, Freya] [Nash, James] [Nerode, Gregory] [Novick, Wesley] 

4 [Nunez, Albert] [Nunez, Carlos] [Oakes, Bonnie] [Olmstead, Harry] [O'Meara, Patrick] [Pacheco-Theard, 

5 Lauren] [Paquet, Kevin] [Parsons, Barry] [Paul, Georgia] [Pedraza-Tucker, Liette] [Petkiewicz, Margaret] 

6 [Phipps, Donald] [Piner, Lisa] [Piser, Daniel] [Putney, Louis] [Rader, Nancy] [Radford Jr., Roger] [Raines, 

7 Mary] [Ramstrom, Eric G and Shirley S] [Randall, David] [Rankin, Susan] [Reidenbach, Gregory] 

8 [Rosenblum, Stephen] [Ross, Anne] [Sather, Alice] [Sauer, Elizabeth] [Schmidt, Jason] [Schopp, Ricky] 

9 [Schwarz, Walter] [See, Bud] [Shafer, Scott] [Shashani, Linda] [Sherrow, Sarah] [Shively, Daniel] [Siecke, 

10 Martin] [Simila, Owen] [Skercevic, Maria] [Smith, Enoch] [Smith, Martha] [Snowden, Patricia] [Sorin, 

11 Susanna] [Soroos, Marvin S] [Soto, Yvonne] [Stevens, Denise] [Stilwell, Lisa] [Strange, Linda] [Theil, 

12 Tony] [Thiele, Abhaya] [Tornatore, James] [Trenholme, Art] [Turner, Tamisha] [Valliere, Cliff] [VanEtten, 

13 Margot] [Vieg, Jeannette] [Voeller, Estelle] [Wadkins, Melanie] [Waldman, Sam] [Walker-Meere, Susan] 

14 [Walsh, Donald] [Walters, Betty] [Wanner, Gabrielle] [Ward, John] [Welch, Irene] [Wilkins, Paul] 

15 [Willoughby, CaraLea] [Wilson, Deb] [Yeatts, Jordan] [Zastawecky, Margaret] [Zelikson, Linda])

16 Comment: The EIS must address the possible effects of transportation of radioactive waste 

17 generated at Calvert Cliffs, in the unlikely event a waste repository ever will be built. This should 

18 include road, rail and barge transportation on the Chesapeake Bay into the Port of Baltimore.

19 (0019-10 [Mariotte, Michael])

20 Comment: If barges are not used, then trucks or trains would be. The Baltimore train tunnel fire 

21 of 2001 could have killed thousands if high-level radioactive waste had been on board, and that 

22 route has been targeted by the Dept. of Energy in the past. DOE truck shipment routes criss23 cross the State of Maryland. (0019-12 [Mariotte, Michael])

24 Comment: I hope your process includes careful inspection of the dry cask irradiated fuel 

25 storage units at Calvert Cliffs as well as the problems involved in transporting this waste to 

26 another site. Have the casks degraded over time? How could such dangerous material be 

27 transported safely, avoiding densely populated areas -- which is where our rail lines and 

28 highways go -- without risk to the ecosystem of the Chesapeake Bay or the human population of 

29 the area? (0020-6 [Donn, Marjory])

30 Comment: The transportation risks, again, are -- there are vulnerabilities to accidents and 

31 attacks. (0025-100 [Kamps, Kevin])

32 Comment: And even if there are no accidents or attacks on these transportation containers, 

33 they are like mobile X-ray machines rolling down the railroad tracks, down the highways, in the 

34 Port of Baltimore, and there are certain people like pregnant women who should not be exposed 

35 to any radioactivity if it can be avoided. (0025-102 [Kamps, Kevin])

36 Response: The EIS will evaluate the radiological impacts of transporting fuel and waste to and 

37 from the proposed Calvert Cliffs Nuclear Power Plant (CCNPP) site. The impacts will be 
Appendix D 

April 2010 D-65 Draft NUREG-1936 

1 calculated for truck shipments of fuel and waste to and from the plant because the impact of 

2 truck shipping bounds the impacts of transporting these materials. The EIS will also include an 

3 analysis of the impacts of severe transportation accidents that could potentially occur along a 

4 spent fuel transportation route. 

5 Comment: A system of disposal is already in place for the existing two reactors at Calvert 

6 Cliffs. NAACPCCB [National Association for the Advancement of Colored People Calvert 

7 County Branch] is concerned about the existing disposal program especially in terms of 

8 transport of the waste out of the county, and the impact an accident could have on the 

9 community. In addition, a 3 rd reactor will create more waste, and more possibilities for 

10 accidents. NAACPCCB insists on the facility having a detailed plan outlining the disposal of all 

11 waste, and contingency plans in the event of accident. (0017-2 [Brown, Jr., Edsel])

12 Comment: [A]nother accident scenario that folks around here need to worry about is the 

13 sinking of a barge on the Chesapeake Bay, because another proposal for removing these 

14 wastes from Calvert Cliffs is to barge them up to the Port of Baltimore. There's enough fissile 

15 material in the waste containers that, in the presence of water, if water were to infiltrate into a 

16 sunken container, a chain reaction could be initiated, and that would make emergency response 

17 a suicide mission at that point, because it would be giving off deadly doses of radioactivity.

18 (0025-101 [Kamps, Kevin])

19 Response: A detailed analysis of the health and safety impacts of transporting fuel and waste 

20 by truck to and from the proposed Calvert Cliffs Nuclear Power Plant site will be conducted and 

21 included in Chapter 6 of the EIS. Emergency preparedness planning and preparations to 

22 respond to transportation accidents is described in detail in the "Final Environmental Impact 

23 Statement for a Geologic Repository for the Disposal of Spent Nuclear Fuel and High-Level 

24 Radioactive Waste at Yucca Mountain, Nye County, Nevada" (DOE/EIS-0250F).

25 Comment: [T]he EIS should evaluate the strength of transportation casks from tests conducted 

26 at the Sandia National Laboratory and consider the likelihood of a breach in any expected rail 

27 accident, including protracted fire and lengthy submersion. We suspect that the common 

28 opinion is that high-level waste would be shipped in containers resembling oil drums, and this is 

29 untrue. (0025-63 [Meadow, Norm])

30 Comment: The EIS should evaluate the strength of transportation casks from tests conducted 

31 at the Sandia National Laboratory (http://www.sandia.gov/tp/SAFE_RAM/SEVERITY.HTM), and 

32 consider the likelihood of a breach in any expected rail accident, including protracted fire, and 

33 lengthy submersion. (0028-37 [Meadow, Norman])

34 Comment: The MCC [Maryland Conservation Council] believes that the strength of 

35 transportation casks is sufficient to prevent releases of radioactive material in any conceivable 

36 transportation accident. (0028-38 [Meadow, Norman])
Appendix D 

Draft NUREG-1936 D-66 April 2010 

1 Response: The EIS will include an analysis of the radiological impacts of potential 

2 transportation accidents involving spent nuclear fuel [in Chapter 6]. Spent fuel is transported in 

3 massive, heavily-shielded shipping casks, referred to in 10 CFR Part 71 as Type B containers, 

4 and are designed to withstand severe transportation accident environments. The likelihood and 

5 consequences of shipping cask failures will be included in the transportation accident impact 

6 analysis in the EIS. 

7 16. Comments Concerning Cumulative Impacts

8 Comment: [W]hat are the implications of being 15 miles from a naval base? Does it work for 

9 us? Does it paint a particular bullseye? How does it weigh in, if at all? (0024-109 [Buchanan, Bill])

10 Response: The EIS will take into consideration other Federal projects in the vicinity, and any 

11 cumulative impacts of these projects will be assessed [in Chapter 7 of the EIS]. The concern 

12 about terrorism is an issue the NRC addresses separately and is out of the scope of this EIS. 

13 17. Comments Concerning the Need for Power

14 Comment: There is no end in sight to our rapidly expanding population - everywhere, not just 

15 in Calvert County - which means there is no end in sight for increasing energy demands. 

16 Alternative energy sources would be welcome but, so far, they are technologically inadequate to 

17 meet demand. (0004-3 [Arndt, Gunter])

18 Comment: The EIS needs to ask the following question: Given the above, would not the per 

19 capita demand (kW hr per year, say) or the per household residential demand decrease at a 

20 rate equal to or exceeding the ca. 1% population growth rate? If the answer is yes, no additional 

21 power plants are needed, nuclear or otherwise. (0005-20 [Vogt, Peter])

22 Comment: [T]he EIS needs to evaluate the likelihood that in the Mid-Atlantic grid area, per 

23 capita kWhrs/yr will level or has already leveled off. (0005-21 [Vogt, Peter])

24 Comment: Initiatives taken by Maryland state government in 2007 aim to cut per capita electric 

25 consumption by 15% by the year 2015. Even if this goal is missed, what can easily be achieved 

26 can and probably will offset the 1% population growth rate. How close Maryland will come to 

27 reaching this goal cannot be evaluated/predicted just a year after the new measures were 

28 enacted. It is reasonable to expect that progress can be evaluated after 3 years, i.e. by 2010.

29 (0005-22 [Vogt, Peter])

30 Comment: Both Maryland and the nation are at a critical juncture. While conservation and 

31 energy efficiency will be important responses to increased electricity demand, and we support 

32 those efforts as does Constellation Energy and UniStar, conservation and energy efficiency will 

33 not offset the need for new base-load generation in Maryland or across the country. We need 
Appendix D 

April 2010 D-67 Draft NUREG-1936 

1 new energy generation and we need to reduce our dependence on foreign energy supply. (0014-

2 3 [Clark, Gerald] [Kelley, Linda] [Parran, Wilson] [Shaw, Susan] [Stinnett, Barbara])

3 Comment: I have long recognized the importance of nuclear energy in the electric power 

4 industry as a primary source for supplying our country's energy needs. The additional unit will 

5 positively contribute to the economic health of not only Calvert County, but the entire state of 

6 Maryland and the United States, through the availability of safe and affordable power. 

7 Expansion of the Calvert Cliffs, allows diversification of energy sources through the use of non 

8 polluting nuclear fuel. The additional unit will meet the increasing energy demands of the state 

9 of Maryland and the entire Mid-Atlantic Region. (0015-2 [O'Donnell, Anthony])

10 Comment: The world is not going to fill its need for clean and environmentally friendly energy 

11 without pursuing all the many options available. Nuclear energy is emissions free when 

12 managed safely, less damaging to the environment and the technology is here today. We need 

13 to go forward with this project. It will be beneficial to my County and the Country by supplying 

14 needed energy and reducing our dependence on fossil fuel and all its damaging emissions.

15 (0016-3 [Zahniser, Albert])

16 Comment: [T]he construction of a third nuclear reactor at Calvert Cliffs would dramatically 

17 increase Maryland's energy self-sufficiency, nearly doubling the plant's present capacity and 

18 generating enough electricity to serve approximately 2.5 million homes, more than the total 

19 number of households projected for the State of Maryland in 2015. (0023-3 [Hodge, Gary])

20 Comment: As technology advances, our economy and our population increases, so, too, will 

21 our need for energy grow. (0024-21 [Kanaley, Mike])

22 Comment: Maryland is at a critical juncture in the availability of baseload generation, 

23 specifically the state's desire to generate enough reliable supply to reduce the import of energy 

24 to the state. (0024-8 [Parran, Wilson])

25 Comment: Maryland is at a critical juncture in the availability of base load generation, 

26 specifically the state's desire to generate enough reliable supply to reduce the import of energy 

27 to the state. (0025-10 [Parran, Wilson])

28 Comment: The U.S. Department of Energy estimates that our electricity demand will increase 

29 25 percent by the year 2030. (0025-118 [Walther, Robert])

30 Comment: As our technology advances, our economy expands, and our population increases, 

31 so, too, will our need for electricity grow. (0025-119 [Walther, Robert])

32 Comment: According to the U.S. Department of Energy, the United States' demand for 

33 electricity will rise approximately 25 percent by 2030. That means our nation will need hundreds 
Appendix D 

Draft NUREG-1936 D-68 April 2010 

1 of new power plants to provide electricity for our homes and for our continued economic growth.

2 (0025-128 [Green, Bonnie])

3 Comment: I believe the power from this plant is absolutely necessary. I have read in the 

4 Baltimore and Washington newspapers that we may be looking forward to brownouts as early 

5 as 2011, because generation is not keeping up with the demand. (0025-139 [Sinclair, Jim])

6 Comment: I think that by constantly focusing on how we need to increase supply, and not 

7 focusing on how we should be decreasing demand, is really putting the horse -- or the cart 

8 before the horse. (0025-162 [Hunter, Theresa])

9 Comment: I believe that without the addition of the new generating facilities I personally 

10 believe that this will leave Maryland at a significant disadvantage. So, basically, we will be 

11 forced to import and pay more for electricity that's generated outside of the state. So I know that 

12 the environmental reports consider a variety of facts, and I just ask and encourage that you 

13 consider the electricity demand as part of your independent review. (0025-166 [Pretto-Simmons, 

14 Nancy])

15 Comment: We do need electricity on the grid. (0025-22 [Russell, Jack])

16 Comment: [B]usinesses, not only here in Calvert County and St. Mary's County, as it was just 

17 mentioned, but also to your neighbor to the north and more regionally, depend upon reliable 

18 energy sources to be able to conduct their businesses, and our consumers depend upon 

19 reliable energy sources. (0025-32 [Burton, Bob])

20 Comment: [A]s a state, we have a critical energy supply problem. We need new energy 

21 generation, and we need to reduce our dependence on foreign energy supply. (0025-7 [Parran, 

22 Wilson])

23 Comment: While energy efficiency and conservation are very desirable, the EIS must consider 

24 the rate of growth of the population in Maryland. These measures will perhaps only slow the rate 

25 of growth of demand. (0025-74 [Meadow, Karen])

26 Comment: The PJM itself is estimating the need for a one and a half percent increase per year 

27 of summer production capacity over the next 15 years to meet demand. That means an 

28 increase of 25 percent of current capacity -- an amount that will be difficult to attain through 

29 energy efficiency and conservation alone, or even in concert with renewables. (0025-75 [Meadow, 

30 Karen])

31 Comment: [W]hen you look at the stats and the figures from the State of Maryland, where 

32 privately we are being told, "Get ready, because by 2011 we'll have the rolling brownouts," in St. 

33 Mary's County we can't afford that. We are a growing community. Our energy needs are not 
Appendix D 

April 2010 D-69 Draft NUREG-1936 

1 going to decrease, and with conservation we might be able to keep them stable at the current 

2 levels. (0025-83 [Scarafia, Bill])

3 Comment: We feel that it’s critical to -- for growth in our region to have this additional supply 

4 on hand. We know it's down the road, but as our regions continue to grow we need to make 

5 sure that we have enough power to support key development in government agencies and other 

6 organizations that come to the State of Maryland and our region. (0025-86 [Green, Joseph])

7 Comment: [T]he EIS must consider the projected rate of growth of demand for electricity which 

8 will be driven significantly by population growth as projected by the U.S. Census Bureau. (0028-

9 22 [Meadow, Norman])

10 Comment: Efficiency and conservation can only slow the rate of growth of energy need, they 

11 will not be able to reduce absolute demand. (0028-23 [Meadow, Norman])

12 Comment: The PJM estimates a 1.5% increase per year of summer peak load capacity over 

13 the next 15 years to meet demand, resulting in a total increase of 25% of current capacity. 

14 Compared to the year 2000, the US Census Bureau estimates that Maryland's population will be 

15 33% larger by 2030 and 260% larger by 2100. (0028-24 [Meadow, Norman])

16 Comment: It is important to acknowledge that demand for electricity in our grid region is 

17 significantly higher in the summer as compared to the winter months (the next highest demand 

18 season of the year). (0028-8 [Meadow, Norman])

19 Response: These comments acknowledge or question the need for power based on an 

20 expanding population. The State of Maryland has examined the need for new electricity 

21 generation capacity in Maryland (Maryland Public Service Commission (MPSC). 2007. Electric 

22 Supply Adequacy Report of 2007. Online at: 

23 http://www.psc.state.md.us/psc/Reports/home.htm.) These studies will be reviewed in 

24 conjunction with preparing the need for power section [Chapter 8] in the EIS. 

25 18. Comments Concerning Alternatives - No Action

26 Comment: The EIS should fully and transparently consider alternatives to Calvert Cliffs-3, 

27 including ... the “no action” alternative. (0019-5 [Mariotte, Michael])

28 Comment: Alternatives to this plant -- the EIS must consider alternatives to the plant, including 

29 the “no action” alternative. The EIS should very carefully look at whether and how Maryland’s 

30 electric supply and its needs can be met through renewables, through energy efficiency, and the 

31 cost factors of those. I believe that a very strong case can be made -- and we’ll be making that 

32 later this year to the Public Service Commission -- that Calvert Cliffs is the most expensive 
Appendix D 

Draft NUREG-1936 D-70 April 2010 

1 choice to meet Maryland’s electric needs and they can be met much cheaper and much more 

2 cleanly through renewables and efficiency. (0025-47 [Mariotte, Michael])

3 Response: Alternatives to the proposed action, including siting alternatives, energy 

4 alternatives, and the no-action alternative, will be considered in Chapter 9 of the EIS. 

5 19. Comments Concerning Alternatives – Energy

6 Comment: Recent years have seen dramatic Improvements in appliance efficiency (e.g., 

7 refrigerators), insulation, light bulbs, etc., paralleled by rapidly decreasing cost of solar 

8 photovoltaics, (panel prices are declining at around 8% per year, largely due to reduced 

9 manufacturing costs caused by higher production volumes). Passive and PV solar, as well as 

10 ground source “geothermal”, are very practical in the grid area served by the Calvert Cliffs 

11 Nuclear Power Plant. (0005-19 [Vogt, Peter])

12 Comment: Most will agree that we have to arrest greenhouse gas emissions from fossil carbon 

13 fuels, because of likely widespread adverse impacts caused by resultant climate change. The 

14 mere fact that nuclear power greatly reduces C02 emissions does not by itself justify the US 

15 renaissance of nuclear power plants advocated by the nuclear industry/lobby and financially 

16 “greased’ by EPACT. If nuclear were the only viable alternative to current C02-emitting coal17 fired plants, most would agree we need more nuclear power plants. However, nuclear is 

18 absolutely not the only alternative, and is arguably the most risky and environmentally 

19 hazardous alternative. (0005-23 [Vogt, Peter])

20 Comment: The EIS needs also to evaluate carbon sequestration (to offset C02 emissions from 

21 coal) and better scrubbing of other pollutants from coal, which the US has in abundance. Coal22 fired plants are not inviting terrorist targets, there is no long-term waste issue, and many US 

23 jobs depend on coal mining, transport, and utilization. (0005-25 [Vogt, Peter])

24 Comment: [I]t is safe to assume that nuclear fusion reactors will still not be operational even in 

25 the middle of this century (if ever). However, PV solar, ground-source geothermal, and solar 

26 passive air or water heating are not rocket science-- only the start-up investment and public 

27 inertia has slowed their acceptance. (0005-26 [Vogt, Peter])

28 Comment: Recent trends in solar photovoltaic electric generation technology and pricing are 

29 dramatic. The EIS needs to extrapolate these trends not just to the time a potential third reactor 

30 would go on line (2015?) but for the probable lifetime of such a reactor (2075?). (0005-27 [Vogt, 

31 Peter])

32 Comment: Solar power will never cover ALL our electricity needs, but will become a significant 

33 fraction of the total power mix. Solar, energy by itself is completely free and clean, and will be 

34 available for some billions of years! (0005-29 [Vogt, Peter])
Appendix D 

April 2010 D-71 Draft NUREG-1936 

1 Comment: [W]e are lucky enough to be a coastal state. Nuclear reactors are extremely 

2 expensive - why can’t we just build a great big wind farm out on the ocean like the one planned 

3 for Rehoboth, DE? (0007-5 [Shannahan, Brittany])

4 Comment: The EIS should fully and transparently consider alternatives to Calvert Cliffs-3, 

5 including but not limited to: 

6 • use of renewable energy to meet electricity demand and/or equivalent output of Calvert 

7 Cliff-3 

8 • use of energy efficiency to reduce electricity demand to equivalent output of Calvert Cliffs-3, 

9 including various and aggressive energy efficiency program scenarios 

10 • use of a combination of renewable energy and energy efficiency to meet electricity demand 

11 and obtain an equivalent output of Calvert Cliffs-3. (0019-4 [Mariotte, Michael])

12 Comment: I hope the EIS will include in-depth consideration of alternatives to Calvert Cliffs –3. 

13 The area’s power needs can be met by safer and more environmentally friendly means: through 

14 using renewable energy sources and by developing energy efficiency programs. (0020-8 [Donn, 

15 Marjory]) 

16 Comment: Renewable energy sources will be valuable in diversifying the nation’s energy 

17 supply, but their intermittent nature precludes their role as a reliable generation source. (0024-10

18 [Parran, Wilson])

19 Comment: Conservation and more efficient electrical appliances help and a deeper 

20 commitment to renewable sources, such as wind, solar and geothermal, is needed, but 

21 conservation and renewable energy don’t provide the baseload power we require to ensure the 

22 lights go on every time we flick a switch. (0024-22 [Kanaley, Mike])

23 Comment: [I]t's our belief that through a combination of energy efficiency, clean renewables, 

24 like solar, wind, and geothermal, combined heat and power, and distributed generation, the 

25 state can meet its energy needs without investing a lot of money in a new nuclear power plant.

26 (0024-36 [Neumann, Johanna])

27 Comment: [I]f nuclear energy was the only way we could avoid climate change, global 

28 warming, then we'd have to weigh those risks, but there are alternatives, including wind power 

29 and solar energy and efficiency. (0024-60 [Dubois, Gwen])

30 Comment: I would argue that there’s reliable, fast, cheap, clean, safe, and more secure 

31 sources of electricity. Those would include efficiency and renewables. (0024-80 [Kamps, Kevin])

32 Comment: Efficiency is seven times more cost effective dollar for dollar than nuclear power in 

33 reducing greenhouse gas emissions. So, given our limited resources and our limited time in 

34 addressing this crisis, we really have to go for the low-hanging fruit. (0024-81 [Kamps, Kevin])
Appendix D 

Draft NUREG-1936 D-72 April 2010 

1 Comment: Nuclear is one of the most expensive and one of the most time-consuming ways to 

2 generate electricity, and I would like to commend Constellation Energy for its Super Bowl ad at 

3 the end of January where they showed wind power and the potential of wind power, but 

4 strangely enough, they didn't mention nuclear at all. So, I would call on Constellation to live up 

5 to its Super Bowl ad and pursue wind power. (0024-82 [Kamps, Kevin])

6 Comment: Conservation and energy efficiency will be important responses to increased 

7 electricity demand and we support those efforts as does Constellation Energy and Unistar, but 

8 conservation and energy efficiency will not offset the need for new baseload generation in 

9 Maryland. (0024-9 [Parran, Wilson])

10 Comment: [H]ow much of a reduction in peak energy demand do you think there would be if 

11 we went to smart metering? (0025-109 [Johnston, Bill])

12 Comment: Conservation and energy efficiency will be important responses to increased 

13 electricity demand, and we support those efforts as does Constellation Energy and Unistar. But 

14 conservation and energy efficiency will not offset the need for new base load generation in 

15 Maryland. (0025-11 [Parran, Wilson])

16 Comment: A single [solar energy] panel setup, 200 miles long, 200 miles wide, that square, 

17 would meet the energy demands for the United States in the year 2050. Coal burning uses 

18 more land than solar, once you take mining into account, that you are cutting off the mountain 

19 tops here and there, filling the ravines. (0025-110 [Johnston, Bill])

20 Comment: Renewable energy sources will be valuable in diversifying the nation’s energy 

21 supply, but their intermittent nature precludes their role as a reliable generation source. (0025-12

22 [Parran, Wilson])

23 Comment: [G]reater conservation and renewable energy don’t provide the round-the-clock 

24 base load power we require to ensure the lights go on any time we flip the switch. (0025-120

25 [Walther, Robert])

26 Comment: I’m a great believer in renewables, such as wind power, and they should absolutely 

27 be part of the energy mix, but we can't rely on renewables alone. (0025-140 [Sinclair, Jim])

28 Comment: I think we should avoid fossil fuel alternatives whenever possible. The effect of 

29 greenhouse gases on the environment is becoming very well documented. I truly believe the 

30 planet is in peril as a result of the use of fossil fuels. (0025-141 [Sinclair, Jim])

31 Comment: [T]here is one group and one issue that I don’t think anybody has touched on, and 

32 that’s the new generation of power, and new technologies to generate power in the country is a 

33 national security issue. (0025-145 [McGarvey, Sean])
Appendix D 

April 2010 D-73 Draft NUREG-1936 

1 Comment: It seems to me that one of the more important things that ... as a means by which 

2 we might help ourselves to become less dependent on any source of power generation, whether 

3 that be from nuclear or other sources, is through energy conservation and efficiency. (0025-160

4 [Hunter, Theresa])

5 Comment: I think that it’s through energy conservation and efficiency that we should be 

6 targeting our way forward to get to a point where we're able to support our region with the type 

7 of energy needs that we are going to need now and into the future, and not rely upon things 

8 such as an expansion of nuclear power. (0025-161 [Hunter, Theresa])

9 Comment: When considering energy from wind, capacity factors should be documented by 

10 actual industry power production reports. For example, for wind installations in Pennsylvania, 

11 which are right next to where they want to put them in Maryland, and from the capacity value 

12 assigned by the PJM grid managers to the current wind installations, particularly for summer 

13 capacity when the demand is highest and the output is lowest. (0025-65 [Meadow, Karen])

14 Comment: Environmental impact should include the actual land required for erecting those 

15 4,800 turbines, plus the land required for the road system and the transmission lines. This land 

16 area would exceed 20,000 acres of cleared forest in the Appalachians, approximately 700 miles 

17 of ridge line, because they need to go on the ridge line to get the wind. (0025-67 [Meadow, Karen])

18 Comment: [T]he EIS should examine the number of studies and their quality to measure bird 

19 and bat kills in the Appalachians, and should evaluate whether research done on wind 

20 installations in California, in a very different habitat, is applicable to the ecology of birds and bats 

21 in the Appalachians. (0025-68 [Meadow, Karen])

22 Comment: Given that the wind installations proposed for western Maryland would be situated 

23 on major bird and bat migratory routes, the environmental impact of the turbines must be 

24 carefully considered. The habitat damage of the wind turbines far exceeds the actual cleared 

25 pads, since certain species of birds will not roost within 300 feet of a clearing. (0025-69 [Meadow, 

26 Karen])

27 Comment: In regard to offshore wind, the EIS should evaluate the amount of research that has 

28 been done on the effects of noise and vibrations from the turbines on the ecology of the waters 

29 in which the turbines are placed. We are aware of only one brief study of something that could 

30 potentially cause extensive permanent damage to the ecology of these offshore waters, and 

31 that's wholly unacceptable. (0025-70 [Meadow, Karen])

32 Comment: For bioenergy sources, such as with grass or short rotation forest crops, the 

33 amount of land required to replace the reactor's output should be investigated based on the 

34 known yield of these products. Land required for bioenergy crops would be approximately 6,000 
Appendix D 

Draft NUREG-1936 D-74 April 2010 

1 square miles under cultivation. This is 60 percent of the State of Maryland. (0025-71 [Meadow, 

2 Karen])

3 Comment: Photovoltaic power should be evaluated on the basis of capacity factors. 

4 Accordingly, in Maryland, it would require covering 100 square miles with very expensive solar 

5 panels, which is half the area of Calvert County. (0025-72 [Meadow, Karen])

6 Comment: [W]e are living in a changing global warming environment, which may change the 

7 weather pattern, meaning alternatives to nuclear power that are based on weather, such as 

8 wind and sun, may well be ineffective in the years to come. (0025-73 [Meadow, Karen])

9 Comment: I think if you insist on having nuclear power, and I insist there’s very viable 

10 alternatives for anyone who is interested in looking into it, they should be located on the ocean 

11 where you get cooler water and higher operating efficiencies. (0025-113 [Johnston, Bill])

12 Comment: There are cleaner forms of energy - solar for one, wind for another. Both are 

13 sustainable & with little or no public risk. (0026-2 [Marsh, Rauni])

14 Comment: One mistake and we’re all dead or worse. Nuclear power is not the answer! 

15 Sustainable natural energy from Nature is the only answer. (0026-5 [Marsh, Rauni])

16 Comment: [N]uclear power must be compared to other methods for the generation of electricity 

17 on the basis of cost, reliability, and lack of carbon dioxide emissions, balanced against the 

18 potential for harm. (0028-1 [Meadow, Norman])

19 Comment: Nuclear reactors work at approximately 90+% capacity year round. Calculated from 

20 the Capacity Values mentioned above, 5,500 2 MW wind turbines would be required to produce 

21 the same amount of electricity as the proposed reactor during the summer months when our 

22 region's demand is highest (and increasing most rapidly). (0028-10 [Meadow, Norman])

23 Comment: Since nearly all commercial wind energy development is currently planned for the 

24 ridgetops along the Appalachian Mountain chain, and since the vast majority of these potential 

25 development sites are presently covered in dense forest, the impact resulting from construction 

26 of 5,500 huge wind turbines and their associated roads and transmission lines likely would 

27 result in the clearing of about 20,000 acres of forest along approximately 800 miles of ridge line. 

28 Wind energy facilities which have been built in the last 5 years in the PJM grid region have 

29 averaged about 3 to 5 acres of forest cleared per wind turbine, and they install on average 

30 about 7 or 8 wind turbines per mile of ridgeline. It should be noted that, in fact, there is not 

31 nearly enough suitably windy ridgetop in western Maryland to accommodate this intensity of 

32 wind energy development. (0028-11 [Meadow, Norman])
Appendix D 

April 2010 D-75 Draft NUREG-1936 

1 Comment: Clearing 20,000 acres of forest releases a significant amount of carbon dioxide and 

2 eliminates a major carbon sequestration source, which has to be deducted from the 

3 environmental advantage of the wind installation. (0028-12 [Meadow, Norman])

4 Comment: When investigating ecological damage caused by industrial wind installation, the 

5 NRC should examine the quality of the research done to measure bird and bat kills in the 

6 Appalachians and should evaluate whether research done on wind installations in CA is 

7 applicable to the ecology of birds and bats in the Appalachians. (0028-13 [Meadow, Norman])

8 Comment: Given that the 20,000 acres of forest and ridgetop habitat in the mountains of 

9 Western MD and adjacent states likely would be needed to generate an equivalent amount of 

10 electricity from wind installations as compared to the single new reactor proposed to be added 

11 to Calvert Cliffs, and given that as many or more than 5,500 huge wind turbines therefore would 

12 be situated on major bird and bat migratory routes, the environmental impact of the wind energy 

13 alternative to this nuclear reactor must be carefully considered. (0028-14 [Meadow, Norman])

14 Comment: The habitat damage of the wind turbines far exceeds the actual 20,000 acres 

15 cleared, since many forest interior dwelling species will not successfully persist or reproduce 

16 within at least 300 feet of a cleared edge, meaning that for the 700 mile length of the road and 

17 turbine clearings, an additional 300+ feet of forest interior habitat will be lost along each side of 

18 the road and turbine clearings' entire length. (0028-15 [Meadow, Norman])

19 Comment: In regard to offshore wind, the EIS should evaluate the amount of research that's 

20 been done on the effects of noise from the turbines on the ecology of the waters in which the 

21 turbines are placed. ... The effects of the noise injected into the marine environment might not 

22 manifest themselves for several decades. (0028-16 [Meadow, Norman])

23 Comment: About 1650 offshore turbines (3.5 MW using a summer Capacity Factor of 25%) 

24 would be required to equal the summer-time generating capacity of the proposed nuclear 

25 reactor. (0028-17 [Meadow, Norman])

26 Comment: Bioenergy sources such as switch grass or short rotation forest crops are being 

27 proposed to fire steam boilers. The amount of land required to equal the proposed reactor???s 

28 output should be investigated based on the known energy output and productivity for any crop 

29 being considered for firing stream boilers. Current average yields should be used, not 

30 unconfirmed projections of yield. (0028-18 [Meadow, Norman])

31 Comment: Approximately 6,000 square miles of land would be required for the cultivation 

32 of either switch grass or short rotation forest crops. This is 60% of the State’s land area and is 

33 equal to the area of all current forest and agricultural land. (0028-19 [Meadow, Norman])
Appendix D 

Draft NUREG-1936 D-76 April 2010 

1 Comment: The EIS should investigate the energy required to dry these crops as we have been 

2 unable to determine if this has been considered by proponents of the method. (0028-20 [Meadow, 

3 Norman])

4 Comment: Photovoltaic power’s potential to provide electricity must be evaluated by using the 

5 Capacity Factor appropriate for Maryland, and not by nameplate capacity of the installations. 

6 The MCC estimates that it would require covering 100 square miles with solar panels (this is 1/2 

7 the area of Calvert County) at a cost of $86 billion to equal the output of the single reactor.

8 (0028-21 [Meadow, Norman])

9 Comment: The damage to wildlife from small releases should be contrasted with the damage 

10 to habitat that would result from the construction of thousands of wind turbines, either on-or off11 shore, or the conversion of thousands of square miles of farm and forest to bioenergy 

12 production which you will hear about shortly. (0028-34 [Meadow, Norman])

13 Comment: [W]e believe that these renewables cannot provide a sufficient amount of electric 

14 power to significantly reduce dependence on coal. (0028-4 [Meadow, Norman])

15 Comment: When considering energy from wind, the potential for electricity generation from 

16 commercial installations should be estimated from the annual and summer-time Capacity 

17 Factors documented by actual power production reports of existing facilities. (0028-6 [Meadow, 

18 Norman])

19 Comment: [T]he Capacity Value (i.e., the capacity factor achieved during the 4-hour summer 

20 afternoon expected peak demand period -- following the methodology used by PJM’s grid 

21 managers) ought to be used in evaluating the capability of wind energy or other renewable 

22 energy projects to substitute for this proposed nuclear reactor. (0028-7 [Meadow, Norman])

23 Comment: Nameplate capacity provided by the manufacturers of wind turbines is misleading 

24 for estimating the wind generation potential which possibly could come from facilities located in 

25 western Maryland or elsewhere in the Mid-Atlantic Highlands region. (0028-9 [Meadow, Norman])

26 Response: The comments identify alternative energy sources, request that NRC consider 

27 [energy] alternatives [in] its analysis, or comment that certain alternatives cannot meet the 

28 power need. Alternative energy sources, including energy conservation and renewable energy 

29 sources, will be considered in [Chapter 9 of] the EIS. 

30 Comment: In carrying out the Environmental Impact Statement (EIS) scoping process related 

31 to Constellation Energy/Unistar’s proposed Calvert Cliffs – 3 reactor, please consider 

32 alternatives to building the reactor. (0020-1 [Donn, Marjory])
Appendix D 

April 2010 D-77 Draft NUREG-1936 

1 Response: [Chapter 9 of the EIS will discuss the no-action alternative, alternative sites, 

2 alternative energy sources, and alternative plant systems. 

3 Comment: We believe that there are cleaner, safer, and more affordable alternatives [to 

4 nuclear power], so that Maryland can meet its energy challenges while moving forward with a 

5 clean energy economy and, you know, ultimately a much more environmentally sound and 

6 much more conscious of public health energy future. (0024-34 [Neumann, Johanna])

7 Response: The EIS will be prepared in accordance with 10 CFR 51.75(c). Alternative energy 

8 sources, including energy conservation and renewable energy sources, will be discussed in 

9 Chapter 9 of the EIS. 

10 20. Comments Concerning Benefit – Cost Balance

11 Comment: UniStar/Constellation Energy’s Environmental Report lacks credibility and appears 

12 more intended at deflecting and deterring public involvement in the EIS than contributing to 

13 careful and transparent analysis. Specifically, the applicant’s assertion (and the NRC’s apparent 

14 acceptance of that assertion) that all financial information, including basic estimates of 

15 construction cost, are to remain proprietary makes any discussion of cost/benefit analysis 

16 impossible, and thus irrelevant, and leaves the EIS unable to fulfill one of its most basic 

17 obligations. (0019-1 [Mariotte, Michael])

18 Comment: Even if the NRC staff has access to this allegedly proprietary information, and 

19 prepares a cost/benefit analysis based upon its access, the public still would not have the ability 

20 to assess this information, add a public perspective the NRC staff may be lacking, and comment 

21 upon this information—legal requirements of the EIS. (0019-2 [Mariotte, Michael])

22 Response: The applicant is entitled by 10 CFR 2.390 to have trade secrets and commercial 

23 and financial information held by the NRC as privileged or confidential, subject to certain 

24 procedural controls. The Commission also determines whether the right of the public to be fully 

25 apprised as to whether the bases for and effects of the proposed action outweighs the 

26 demonstrated concern for protection of a competitive position, and whether the information 

27 should be withheld from public disclosure. The NRC has determined that the requested 

28 financial information shall be held as confidential. The comparison of alternatives in the EIS is 

29 an environmental comparison; financial issues are addressed if an alternative site is determined 

30 to be environmentally preferable to the proposed site. 

31 Comment: Will nuclear power become a dinosaur by mid-century? If so, will it be too costly to 

32 dismantle such a plant (none of the size even of Calvert Cliffs Units I and 2 have ever been 

33 dismantled-this would cost billions of dollars). (0005-28 [Vogt, Peter])
Appendix D 

Draft NUREG-1936 D-78 April 2010 

1 Comment: All of the sunken costs related to these construction activities, they should be 

2 included in the total capital cost of the project, especially when comparing the costs per kilowatt 

3 hour between nuclear and the alternative options. (0025-91 [Fisher, Allison])

4 Comment: Erecting 5500 wind turbines in western Maryland will cost $22 billion, using a cost 

5 of $2 million per installed MW. (0028-27 [Meadow, Norman])

6 Comment: [G]iven the wide range of cost estimates already reported by other U.S. utility 

7 projects (for example, Florida Power & Light testimony before the Florida Public Service 

8 Commission estimates construction costs for a single new nuclear unit running from $6 to $12 

9 billion--a huge range), the EIS should not limit itself to a single cost figure, but rather must 

10 conduct its cost/benefit analysis on a range of foreseeable construction costs. (0019-3 [Mariotte, 

11 Michael])

12 Comment: I think there are many reasons why this new reactor should not be built. One of 

13 these reasons is the cost. Constellation Energy says they expect it to cost around 4-5 billion 

14 dollars, but other estimates have ranged all the way up to a possible 12 billion. Then there's the 

15 cost of decommissioning it after the relatively short lifetime of a nuclear reactor. (0020-3 [Donn, 

16 Marjory])

17 Comment: We will provide a cost-benefit analysis for the new nuclear power plant. It will use 

18 the current costs of nuclear power that you're seeing in the press today. (0024-116

19 [Vanderheyden, George])

20 Comment: [W]e strongly feel that there should be a cost-benefit analysis as part of the 

21 environmental impact statement. You know, when Constellation was first embarking on this 

22 process, they were thinking the reactor might cost, you know, $2.5 to $3 billion. You know, new 

23 analyses coming out of Florida suggest that the cost may be as much as $12 billion. Those are 

24 significantly different figures and before we embark on that kind of plan, we need to make sure 

25 we know what we're getting into and so a cost-benefit analysis, looking at the tiered construction 

26 costs, should be part of this environmental impact statement. (0024-37 [Neumann, Johanna])

27 Comment: Right now, Constellation is talking, I don't know, somewhere on the order of $4 

28 billion a reactor, but -- and that may give you one set of conclusions about the costs and 

29 benefits of this facility. But if the reactor costs $8 billion, that might give you a different set of 

30 conclusions. And in that regard, that reactor in Finland, the only one that is being built with this 

31 design, is, after three years of construction, two years behind schedule and 50 percent over 

32 budget. That kind of thing has to be considered. (0025-48 [Mariotte, Michael])

33 Comment: This month, two different utilities in Florida submitted documents to the Florida 

34 Public Service Commission estimating single reactor costs ranging from $6- to $12 billion per 

35 reactor. That's a big difference, and that is going to change the cost benefit analysis 
Appendix D 

April 2010 D-79 Draft NUREG-1936 

1 substantially, and this EIS should look at all of those different possibilities and not just accept 

2 this single cost for this facility. (0025-49 [Mariotte, Michael])

3 Comment: Cost-benefit analysis should include the actual cost per installed watt of generating 

4 capacity of the turbines, as well as the cost of transmission lines, not the net cost after tax 

5 benefits, which are always talked about. This cost would be somewhere in the range of $16 

6 billion as opposed to the $6- to $8 billion attributed to the new reactor. (0025-66 [Meadow, Karen])

7 Comment: Just last December, over $20 billion was approved in nuclear loan guarantees for 

8 new reactors and for uranium enrichment in the United States. This is to an industry that profits 

9 at each reactor about a million dollars per day and has already enjoyed hundreds of billions of 

10 dollars in subsidies over the decades. (0024-89 [Kamps, Kevin] 

11 Comment: [T]he Price-Anderson Act has been renewed. That means that if there’s a major 

12 accident at Calvert Cliffs, that it will be the U.S. taxpayers who bear the brunt of that accident in 

13 large part. (0024-90 [Kamps, Kevin])

14 Comment: Cost benefit analysis should include the actual cost for the per installed watt of 

15 generating capacity as well as the cost of extensive length of transmission lines that will be 

16 required for highly decentralized sources of electric power such as wind and photovoltaics, not 

17 the net cost to the purchaser after government tax liability relief. Projections of reductions in cost 

18 should not be treated as assured. (0028-26 [Meadow, Norman])

19 Comment: The property damages from that 1982 report were around $90 billion at each 

20 reactor if there’s a major accident. So, if you adjust for inflation, double that amount of money, 

21 and again these were 1980 era population figures. So, you have to increase the casualty rates 

22 because the population has grown since then. (0024-78 [Kamps, Kevin])

23 Response: NRC regulations require a reactor license applicant to be financially qualified to 

24 engage in licensed activities. The staff will evaluate the applicant’s financial qualification in its 

25 Safety Evaluation Report, not the EIS. However, the EIS will address the benefit-cost of the 

26 proposed action. The benefit-cost balance for the project will rely on the best available estimate 

27 of project timing and duration, with uncertainties noted where appropriate. Chapter 11 [now 

28 Chapter 10] of the EIS will discuss the estimated overall costs and environmental impacts of the 

29 proposed project. 

Appendix E 

Draft Environmental Impact Statement 

Comments and Responses 

April 2010 E-1 Draft NUREG-1936

Appendix E 

Draft Environmental Impact Statement 

Comments and Responses 

1 This appendix is intentionally left blank. The final Environmental Impact Statement (EIS) will 

2 contain the comments on and responses to the draft EIS in this appendix. 

Appendix F 

Key Consultation Correspondence 

April 2010 F-1 Draft NUREG-1936 

Appendix F 

Key Consultation Correspondence 

1 Table F-1 identifies the consultation correspondence sent and received during the 

2 environmental review of the Calvert Cliffs Unit 3 combined license application. Full copies of the 

3 National Marine Fisheries Service (NMFS) Biological Assessment and Essential Fish Habitat 

4 Assessment are also included in this appendix. 

5 Table F-1. List of Consultation Correspondence 

Source Recipient

Date 

Accession No.

U.S. Nuclear Regulatory Commission 

(Mr. Richard Raione) 

National Marine Fisheries Service 

(Ms. Patricia Kurkul) 

February 29, 2008 

ML080370414 

U.S. Nuclear Regulatory Commission 

(Mr. Richard Raione) 

Fish and Wildlife Service 

(Mr. Dan Murphy) 

February 29, 2008 

ML080390482 

U.S. Nuclear Regulatory Commission 

(Mr. Richard Raione) 

Maryland Historic Trust 

(Mr. J. Rodney Little) 

February 29, 2008 

ML080430656 

U.S. Nuclear Regulatory Commission 

(Mr. Richard Raione) 

Advisory Council on Historic Preservation 

(Mr. Don Klima) 

February 29, 2008 

ML080430649 

U.S. Nuclear Regulatory Commission 

(Mr. Richard Raione) 

Pennsylvania Fish and Boat Commission 

(Mr. Douglas J. Austin) 

March 03, 2008 

ML080520182 

U.S. Nuclear Regulatory Commission 

(Mr. Richard Raione) 

Cedarville Band of Piscataway Indians, 

Inc (Chief Natalie Proctor) 

March 03, 2009 

ML080570335 

U.S. Nuclear Regulatory Commission 

(Mr. Richard Raione) 

Commission on African History and 

Culture (Ms. Tonya Hardy) 

March 05, 2008 

ML080570370 

U.S. Nuclear Regulatory Commission 

(Mr. Richard Raione) 

Piscataway Indian Nation 

(Chief William “Red Wing” Tayac) 

March 05, 2008 

ML080570294 

U.S. Nuclear Regulatory Commission 

(Mr. Richard Raione) 

Piscataway Conoy Confederacy and 

Subtribes, Inc. 

(Tribal Chairman Mervin Savory) 

March 05, 2008 

ML080510408 

U.S. Nuclear Regulatory Commission 

(Mr. Richard Raione) 

Virginia Department of Game and Inland 

Fisheries (Mr. Robert W. Duncan) 

March 05, 2008 

ML080520092 

6 
Appendix F 

Draft NUREG-1936 F-2 April 2010 

Table F-1. (contd) 

Source Recipient

Date 

Accession No.

U.S. Nuclear Regulatory Commission 

(Mr. Richard Raione)

Maryland Department of Natural 

Resources (Mr. John R. Griffin) 

March 05, 2008 

ML080450160 

U.S. Nuclear Regulatory Commission 

(Mr. Richard Raione)

Virginia Marine Resources Commission 

(Mr. Steven G. Bowman) 

March 05, 2008 

ML080520160 

U.S. Nuclear Regulatory Commission 

(Mr. Richard Raione)

Pennsylvania Game Commission 

(Mr. Carl Roe) 

March 05, 2008 

ML080520172 

U.S. Army Corps of Engineers 

(Ms. Margaret E. Gaffney-Smith)

U.S. Nuclear Regulatory Commission 

(Mr. Michael Lesar) 

April 11, 2008 

ML081130278 

Maryland Department of Natural 

Resources (Ms. Susan T. Gray) 

U.S. Nuclear Regulatory Commission 

(Chief, Rules and Directives Branch) 

April 16, 2008 

ML081130284 

Fish and Wildlife Service 

(Ms. Mary J. Ratnaswamy) 

U.S. Nuclear Regulatory Commission 

(Ms. Harriet Nash) 

May 07, 2008 

ML081340645 

U.S. Nuclear Regulatory Commission 

(Mr. Nilesh Chokshi) 

U.S. Army Corps of Engineers (Ms. 

Margaret E. Gaffney-Smith) 

June 11, 2008 

ML081570139 

Maryland Historic Trust 

(Ms. Dixie Henry) 

U.S. Army Corps of Engineers 

(Ms. Kathy Anderson) 

September 25, 

2008 

ML093630083 

Fish and Wildlife Service 

(Mr. Leopoldo Miranda) 

U.S. Army Corps of Engineers 

(Colonel Peter W. Mueller) 

September 30, 

2008 

ML093630080 

National Marine Fisheries Service 

(Mr. John Nichols) 

U.S. Army Corps of Engineers 

(Ms. Kathy Anderson) 

October 3, 2008 

ML082910715 

Maryland Department of the 

Environment 

(Mr. Elder Ghigiarelli, Jr.) 

U.S. Army Corps of Engineers 

(Ms. Kathy Anderson) 

October 31, 2008 

ML093630082 

Maryland Historic Trust 

(Mr. Rodney Little) 

U.S. Army Corps of Engineers 

(Mr. William Seib) 

February 13, 2009 

ML090570416 

U.S. Nuclear Regulatory Commission 

(Mr. Robert Schaaf) 

New York State Department of 

Environmental Conservation 

(Mr. Steve Sanford) 

March 17, 2009 

ML083400571 
 Appendix F 

April 2010 F-3 Draft NUREG-1936 

Table F-1. (contd) 

Source Recipient

Date 

Accession No.

New York State Department of 

Environmental Conservation 

(Mr. Chuck Nieder) 

U.S. Nuclear Regulatory Commission 

(Ms. Laura Quinn) 

April 02, 2009 

ML091170694 

(email) 

U.S. Army Corps of Engineers 

(Ms. Beth E. Bachur) 

Advisory Council on Historic Preservation 

(Mr. Reid J. Nelson) 

July 15, 2009 

ML093060235 

Advisory Council on Historic 

Preservation 

(Mr. Raymond V. Wallace) 

U.S. Army Corps of Engineers 

(Ms. Beth E. Bachur) 

July 24, 2009 

ML093060220 

U.S. Army Corps of Engineers 

(Ms. Beth E. Bachur) 

U.S. Nuclear Regulatory Commission 

(Mr. Michael Lesar) 

July 30, 2009 

ML093240035 

U.S. Nuclear Regulatory Commission 

(Mr. Robert Schaaf) 

Susquehanna River Basin Commission 

(Mr. Paul Swartz) 

October 26, 2009 

ML092660186 

U.S. Nuclear Regulatory Commission 

(Mr. Robert Schaaf) 

Maryland Department of the Environment 

(Ms. Shari Wilson) 

October 26, 2009 

ML092660193 

U.S. Nuclear Regulatory Commission 

(Mr. Robert Schaaf) 

Maryland Department of Natural 

Resources (Mr. John R. Griffin) 

October 26, 2009 

ML092660202 

U.S. Nuclear Regulatory Commission 

(Mr. Robert Schaaf) 

Pennsylvania Game Commission 

(Mr. Carl Roe) 

October 26, 2009 

ML092660259 

U.S. Nuclear Regulatory Commission 

(Mr. Robert Schaaf) 

Virginia Marine Resource Commission 

(Mr. Steven G. Bowman) 

October 26, 2009 

ML092660325 

U.S. Nuclear Regulatory Commission 

(Mr. Robert Schaaf) 

Virginia Department of Game and Inland 

Fisheries (Mr. Robert W. Duncan) 

October 26, 2009 

ML092660318 

U.S. Nuclear Regulatory Commission 

(Mr. Robert Schaaf) 

Pennsylvania Fish and Boat Commission 

(Mr. Douglas J. Austin) 

October 26, 2009 

ML092660314 

U.S. Nuclear Regulatory Commission 

(Mr. Robert Schaaf) 

National Marine Fisheries Service 

(Ms. Patricia Kurkul) 

October 26, 2009 

ML092660237 

U.S. Nuclear Regulatory Commission 

(Mr. Robert Schaaf) 

Fish and Wildlife Service 

(Mr. Leopoldo Miranda) 

October 26, 2009 

ML092660268 

Maryland Department of Natural 

Resources (Ms. Susan T. Gray) 

U.S. Nuclear Regulatory Commission 

(Ms. Laura Quinn) 

November 13, 2009 

ML093280756 
Appendix F 

Draft NUREG-1936 F-4 April 2010 

Table F-1. (contd) 

Source Recipient

Date 

Accession No.

Pennsylvania Fish and Boat 

Commission (Mr. David Spotts) 

U.S. Nuclear Regulatory Commission 

(Ms. Laura Quinn) 

November 16, 2009 

ML093290145 

Virginia Department of Game and 

Inland Fisheries (Mr. Ernie 

Aschenbach) 

U.S. Nuclear Regulatory Commission 

(Ms. Laura Quinn) 

December 04, 2009 

ML093520692 

National Oceanic and Atmospheric 

Administration (Mr. John Nichols) 

U.S. Nuclear Regulatory Commission 

(Ms. Laura Quinn) 

December 10, 2009 

ML093520687 

Fish and Wildlife Service 

(Mr. Leopoldo J. Miranda) 

U.S. Nuclear Regulatory Commission 

(Mr. Robert Schaaf) 

February 25, 2010 

ML100640429 

U.S. Army Corps of Engineers 

(Ms. Kathy Anderson) 

Advisory Council on Historic Preservation 

(Mr. Reid Nelson) 

March 16, 2010 

ML100810272 

1 
1 

. United States Department of the Interior 

May 7,2008 

Harriet Nash 

Office of New Reactors . 

fISH AND WILDLIFE SER VICE 

Chesapeake Bay Field Office 

177 Admira.l Cochrane Drive 

Annapolis. ~D 214()1 

U.S. :-Judear Regulatory Commission. 

Mail Stop T-6D32 

Washington. DC 20555 

RE:EvaluationJor the Calvert Cliffs Nuclear Power Plant, Unit 3 Combined License 

Partial Application,· Calvert County, MD. 

Dear Ms: Nash: 

This responds to your letter, received May 2, 2008, requesting information on the presence of 

. species which are federally listed or proposed for listing as endangered Of threatened within 

the above referenced project area. We have reviewed the information you enclosed and are 

providing cozrunents in accordance with Section 7 of the Endangered Species Act (87 Stat. 

884, as amended; 16U.S.C.lS31 etseq.). 

The federally threatened Puritan tiger beetle (Cicindela puritana) is known to occUr within 

the vicinity ·of the above referenced project site. The Puritan tiger beetle occurs along 

. shorelines of the Chesapeake Bay and its tidal tributaries in locations with sandy beaches, 

often narrow, below high bluffs. The larvae of the beetle live in deep burrows on nonvegetated portions of the bluff face; the adults use both the bluff and the beach below it. 

Populations have declined due to habitat alterations resulting from shoreline development 

and shoreline stabilization (bulkheads. revetments, groins, breakwaters). The beetle larvae, 

in particular, are sensitive to natural and human-induced changes to beaches and bluffs, as 

well as human traffic and water-borne pollution. Any potential impacts on Puritan tiger 

beetle habitat shoul d be analyzed as part of your environmental assessment. If such impacts . 

may occur, further Section 7 consultation with the U.S. Fish and Wildlife Service may be 

r.equired. 

The federally threatened northeastern beach tiger beetle (Cicindela dorsalis dorsalis) is 

known to occur within the vicinity of the above referenced project site. Thi s beetle is most 

vulnerable to disturbance in the larval stage,which lasts two years. Larvae live in vertical 

burrows generally in the beach intertidal zone, where they are particularly sensitive to 

destruction by high levels of pedestrian traffic. off-road. vehicles, and other factors such as 

. beach changes due to coastal development and beach stabilization structures. Any potential 

April 2010 F-5 

Appendix F 

Draft NUREG-1936 
1 

Appendix F 

impacts on northeastern beach tiger beetle habitat should be analyzed as part of your 

environmental assessment. If such impacts may occur, further Section 7 consultation with 

the U.S. Fish and Wildlife Service may be required .. 

We understand that Unistar Nuclear contracted with Dr. Barry Knisley to conduct tiger beetle 

studies and evaluate potential impacts ofllie project, resulting in two reports completed in 

2006 and 2007. These studies may provide the necessary infOlmation to evaluate the . 

proposed project: We look forward to receiving copies of these rep'orts and any other analysis 

of impacts on tiger beetles that has been done. . 

Except for ocCasional transient individuals, no other federally proposed or listed endangered 

or threatened species are known to exist within the project impact area. Should project plans 

change, or if additional information Qn the distribution of listed or proposed species becomes 

tlvailable, this detemination may be reconsidered. This response relates only to fede!aIly 

protected threatened or endangered species lmder our jurisdiction. For infonnation on the 

preseri~e of other rare species. you should contact Lori Byrne of the Maryland Wildlife and 

Heritage Division at (410) 260-8573. 

Effective August 8,2007, ).lDder the authorifyofthe Endangered Species Act of 1973, as . 

amended,the U .s.Fish and Wildlife Service (Service) removed (delisted) the bald .eagle in 

the lower 48 States () f the United States 'from the Federal Li st of Endangered and Threatened 

Wildlife. However,the baid'eagleis still protected by the Bald and Golden Eagle Protection 

Act, Lacey Act, and the Migratory Bird Treaty Act. As a result, if your project may cause 

"disturbance" to the bald eagle, please consult the '-'National Bald Eagle Management 

Guidetines" dated May 2001. If any planned or ongoing activities cannot be conducted in 

. compliance with the National Bald Eagle Management Guidelines (Eagle Management 

Guidelines), please contact the Chesapeake Bay Ecological Services Field Office at 410 -57 3-

4573 for technical assistance. The Eagle Management Guidelines can be found at: 

hftp;!lwww.fws.gov/migr.atorvbirds/issues/Ba1dEaglelNationalBaldEagleManagemeotG 

uideJines, pdf. 

In the future, if your project can not avoid disturbance to the bald eagle by complying with 

the Eagle Management Guideline;>, you will be able to apply for a permit that authorizes the 

take of bald and golden' eagles under the Bald and Golden Eagle Protection Act, generally 

wberethe take to be authorized is associated with otherwise lawful activities. This proposed 

pemTit process will. not be available until the Service issues a final rule for the issuance of 

these take permits under the Bald and Golden Eagle Protection Act. . 

An additional concern of the Servic~ is wetlands protection. Federal and state partners of the 

Chesapeake Bay Program have adopted an interim goal of no overall net loss of the Basin's 

remaining wetlands, and the long term goal ofincreasing the quality and quantity of the 

Basin's wetlands resource base,· Because cifthis policy and the functions and values 

wetlands perfOmi, the Service recommends avoiding wetland impacts~ All wetlands within 

the proj ect area should be identified, and ifeonstruction in wetlands is prpposed, the U.S. 

Army Corps of Engineers. Baltimore District, should be contacted for permit requirements. 

They can be reached at (410) 962-3670. . 

Draft NUREG-1936 F-6 April 2010 
1 

2 

We appreciate the opportunity to provide information relative to fish and wildlife issues, and 

thank you for your interest in these resources. If you have any questions Or need further 

assistance, please contact Andy Moser at (410) 573<4537. 

Sincerely. 

~1~~a~ 

Mary J. Ratnnswamy. Ph.D. 

Program Supervisor, 'Threatened and Endangered Species 

cc: Lori Byrne, Maryland Wildlife and Heritage Division, Annapolis, MD 

Appendix F 

April 2010 F-7 Draft NUREG-1936 
1 

2 

Appendix F 

MEMORANDUM TO: 

FROM: 

SUBJECT: 

Kathy Anderson 

Habitat Conservation Division 

Chesapeake Bay Program Office 

410 Severn Ave., Suite 107 A 

Annapolis, Maryland 21403 

October 3, 2008 

Baltimore District, Corps of Engineers 

Regulatory, Maryland Permit - South 

John Nichols 

CAL VERT CLIFFS NUCLEAR PROJECT 

This pertains to,Public Notice CENABOP-RMS 2007-08123, and your Essential Fish Habitat (EFH) 

Assessment,dated September 3,2008, for the proposal by Unistar Nuclear Operating Services to perform 

site preparation activities and construct supporting facilities at the site of a proposed 1,710 MW nuclear 

power generation station (Unit 3). 

The Nucle'ar Regulatory Commission (NRC), the lead Federal Agency for this proposal, is preparing an 

Environmental Impact Statement (EIS) for work associated with the expansion of the power plant facilities. 

The EIS will contain information important to our ability to make a comprehensive review of the project's 

impacts on National Marine Fisheries Service resources. Therefore, we wish to defer our final comments 

on this proposal until following our review of the EIS. 

Based on our participation, to date, in the scoping process for this proposal, we have identified several 

issues of concern, which will be addressed further in our final comments. These issues are as follows. 

I. The proposed new Unit 3 intake, relative to its impact from impingement and entrainment of 

adult, juvenile, and planktonic stages finfish and crustaceans, and other forms of local 

meroplankton. . 

2. The proposed new discharge pipe; relative to impacts on benthic habitat during installation, 

and the thermal quality of its effluent. 

3. Restoration of a barge unloading facility, including maintenance and new dredging of an 

entrance chaimel, relative to impacts on benthic habitat and natural oyster bar. 

4. Nontidal wetland and stream impacts (permanent and temporary) resulting from .construction 

of the new Unit 3 facility and associated infrastructure. 

I will be looking forward to further cciordmation with your agency and NRC, prior to, and following our 

forthcoming review of the EIS. If you have any questions, please contact me at (410) 267-5675; or, 

John.Nichols@NOAA.GOV. 

Draft NUREG-1936 F-8 April 2010 
1 

fr 

MARYLAND DEPARTMENT OF THE ENVIRONMENT 

1800 Washington Boulevard. Baltimore MD 21230 

410-537-3000.1-800-633-6101 

Martin O'Malley 

Governor 

Appendix F 

Shari T. Wilson 

Secretary 

Anthony G. Brown 

Lieutenant Governor 

Robert M. Summers, ph.D. 

Ms. Kathy B. Anderson 

Regulatory Branch 

Baltimore District, COrps of Engineers 

P.O. Box 1715 

Baltimore, MD 21203-1715 

October 31, 2008 

RE: Water Quality Certification - Unlstar/Calvert Oiffs 3 Nuclear Project 

USACE Tracking No. NAB-2007-QS123-M05 

Dear Ms. Anderson: 

I am writing with regard to the Section 401 water Quality Certification (Wo.c) for the 

referenced project. As you are aware, the Maryland Department of the Environment continues 

to review the proposed wetlands and waterways impacts resulting from the project. 

The state is currently awaiting the release of the Draft Environmental Impact Statement 

COEIS) which is currently scheduled for February, 2009. Upon i1s release, the Wetlands and 

Waterways Program will review the DEIS to ensure that the alternatives analysis meets the 

state's requirements and that proposed impacts to regulated resources have been minimized 

to the extent practicable. . 

Deputy Secretary 

Assuming the project ultimately satisfies all of Maryland's regulatory requirements, the WQC 

wig be issued as part of the state's wetlands and waterways authorizatlons. Accordingly, the 

State reserves its opportunity to issue the WQ: and requests that the COrps of Engineers not 

waive the .... 'os; foi the PiOjed:. 

If you have any questions, please contact me at (410) 537-3763. 

cc: Gary Setzer 

AdarnSnyder 

ij Recycled Paper www.mde.state.md.us TrY U,etS 1·800·735·2258 

Via Maryland ~elay Service 

April 2010 F-9 Draft NUREG-1936 
1 

Appendix F 

M(lrtiIlOi~ftJll<1'. 

GVN'l'F!ti1" -

Maryland Department of Planning 

Maryland Historical Trust . Rhhm-d EberiJllrt HalJ 

SI'CI1't.Jry 

11mb{}lJ"f G. BI'Ollm 

· Lt. Gfll'f:rnllt 

Mlulhewj. Pow .. ,. 

f)t'Pl~t)' Sr.m.'Mry 

February 13,2009 

Mr. William Seib 

Chief, Maryland Section Southern 

Regulatory Branch, Baltimore District 

U.S. Army Corps of Engineers 

P.O. Box 1715 

Baltimore, l\ID 21203·1715 

.. Re: MHT Review of Phase II National Register Evaluations and Assessment of Effects tor Cultural 

. Resources, Calvert Cliffs Nuclear Power Plant Expansion, Calvert County, Maryland. . 

Dear Mr. Seib: 

The Marybnd Historical Trust (Trust) has received additional information related to the above-referenced 

undertaking. The Trust first received notice of the proposed expansion of the Calvert Cliffs Nuclear Power 

Plant from UniStar Nuclear in October of 2006. Since that time, investigations have been undertaken to 

identify historic resources that may be within ~e project's area of potentia) effect and to assess the effects of the 

proposed constnwtion on those resources .. While other federal. agencies will be involved in the regulating and 

pel111itting of the eventual operation of the plant, ihs ourunderitanding that the Corps is the primary federal 

. agency that will be reviewing and permitting the site preparation activities and the actuai construction of the 

facility. We are therefore writing to the Corps pursuant to Section 106 of the National. Histone Preservation Act 

to continue consultation regarding effects on archeological resources (both terrestrial and undel'Water) and the 

historic built environment. 

:Archeology: The Trust has been provided. with copies of the draft reports on the Phase I and Phase II 

archeological investigations that have been conducted for the above-referenced project. The primary draft 

report, Phase I Cultural Resources Investigations and Phase II National Register SUe Evaluations, Calvert 

Cliffs Nuclear Power Plant, Calvert County. Maryland (Munford ct al. 2008) was prepared by GAl Consultants, 

Inc. and presents the necessary documentation on the. goals, methods, results, a.'1d reconunendations ofboth 

Phase I and PhaSe II investigations that have been conducted within the project area. The document is notably 

well-organized and well-written and is consistent with the reporting requirements of the Standards and 

Guide lines for Ar·cheologicallnvestigations in MarylalJd (Shaffer and Cole 1994). Please note, however, that 

the following items must be addressed.in the preparation of the final document: 

• 

• 

The title for FigUre L·J (Project Area) should include. th~ appropriate quadrangle name (Cove Point). 

The rep.ort should spe~ifY that all materials remains and field records generated by the investigations 

will be deposited with the Maryland Archeologicai Laboratory for long-term preservation. 

. 100 Camm"n;,y Plqce. C/-ol<!nsv;!le,.f,lllrylimd 21032~2023 

ftlet;'ol1e. 4i0.5I4.7600 • Fax: 410.9814071 • Toll Fm.· 1.800.756.0119. TJ.Y Usmc Mary/,md Refny 

Inut)irr. wUJUJ.m.dlJ.!/lmdhistorka1trllst.net 

Draft NUREG-1936 F-10 April 2010 
1 

Appendix F 

• While the report acknowledges that site 18CV 474 has the potential to address research questions relating 

to Maryland's slave economy, tnrnsformations following emancipation, and,:domestic agricultural sites 

in the nineteenth century, it may be helpful to include a list of more specific and more detailed research 

questions that could be explored through further investigation of this site, 

As noted in our letter dated June 7, 2007, Phase I survey work res;Utedin the identification offourteen 

,archeological sites, and the Trust repomfJlended that Phase II evaluative studies be conducted at four of these 

sites (l8CV474, 18CV480, 18CV481, and 18CV482) to evaluate the resources in terms of their eligibility for 

the National Register of Historic Places. The Phase II investigations were earned out between March and May 

of2008 and consisted of the excavation of961 additional shovel test,pits and 46 test units. Sites 18CV481 and 

18CV 482 have both been identified as late nineteenth century domestic sites. Both sites have been heavily 

disturbed by mechanical earth-mOVIng activities, and GAI,has recommended that the two sites are not eligible 

forlisting in the National Register of Historic Places .. Based on the information presented in the draft report, we 

concur that sites 18CV481 and 18CV 482 do 110t meet the criteria for eligibility in the National Register given 

their loss of integrity and inability to yield any additional information. Further investigations of these two sites 

are not warranted. - .. 

Site 18CV480 represents the location of the former Parran's Park farmstead (CT-58) - a mid-nineteenth to 

twentieth century landowner's domestic complex that was demolished by BG&E in 1972. A total of24, 938 

artifacts have been recovered from the site, including a variety of historic ceramics (predominantly undecorated 

whiteware, butalso transfer print, hand-painted, edge decorated, and sponge decorated whiteware), glassware, 

cut nails, brick fragments, window glass, porcelain doll fragments, glas~ marbles, buttons, coins, combs,. 

medicine bottles, and tobacco pipe fragments. The remnants of seventeen cultural features were also identified, 

including a deep pit feature, five stone wall or pier sections, and several postholes/molds. Despite the high 

density of artifacts and the presence of partial features, the Phase II investigations have clearly revealed that the 

site has been heavily impacted by modem activities. The area where the house once stood was evidently 

. bulldozed· and graded when the structure W4~ razed; and other areas have been excavated and used as borrow 

. sites during thecQnstruction ofthe existing.power plant. Due to the significantly reduced integrity of the site, 

GAl has recommended that site18CV480 is not.eligible for listing in the National Register. Based on the 

infonnatiori presented in the draft report, we concur that site 18CV 480 does not meet the criteria for eligibility 

in the National Register given its loss of integrity and. inability to yield any additional information. Further 

investigation oftrus site is not warranted.' . 

Site 18CV474, on the other hand, has been identified as a mid-nineteenth to early-twentieth century domestic 

site possessing remarkably good integrity. A total of 3,644 artifacts have been recovered from the site, 

including a variety of tt~mporally diagnostic ceramics (pearl ware, yellowware, and whiteware), bottle glass, cut 

nails, brick fragments, wi,?dow glass, lamp chimney glass, buttons, tobacco pipe fragments, and a glass bead, 

Four intact features have also been'identified, including a stone foundation and chimney base, a build~r's 

trench" an area of stone paving, and;a.possiblepier support for anorth addition. The temporally diagnostic 

artifacts and cartographiC soUrces iiidicate that this site was occupied from ca. fSSO to 1910, and the limited 

quantity arid variety of deconited ceramicssilggests· that the residents were of a lower socioeconomic status than 

the landO\l.1J.ers who were residing at site 18CV480. The property encompassing these sites was, in fact, owned 

and occupied by the' Somervell family during the eighteenth and nineteenth centuries, and census data indicates 

that this locally prominent family relied heavily on enslaved labor throughout the fust half of the nineteenth 

century. The Slave Schedule of the 1860 census, for example, identifies Alexander Somervell as the owner of 

52 slaves, and Charles Somervell (Alexand~r's son) as the owner of sixteen slaves. Hou,<;ing for the~e slaves 

April 2010 F-11 Draft NUREG-1936 
1 

Appendix F 

may have been dispersed throughout the Somervell plantation, and the archeological investigations conducted at 

site 18CV474 indicate that the site. may represent one such residence for some of the slaves andlor tenants, 

sharecroppers, or freed African Americans. 

As note.d above, site 18CV474 has retained much ofits integrity and has the potentia! to yield significant 

information regarding domestic agricultur~l sites in nmeteenth century southern Maryland. Specifically, 

additional archeological investigations may be able to address research question~ relating to Maryland's slave 

economy and the,wide variety oftransformationsthat took place. following emancipation. GAl has therefore 

recommended that site 18CV474 is, eligible for listing in the National Register under Criterion D and that, if 

possible, the site should be preserved in place. Based on the information presented in the report, we concur that 

site 18CV474 is indeed eligible forindusionil,l the National Register. ,. . - . 

The expansion of the Calvert Cliffs Nuclear Power Plant, as currently proposed, would result in the destruction 

, of site 18CV 474 and would constitute an adverse effect on this significant archeological resource. To continue 

the Section 106 consultation process; the Corps of Engineers and UniStar Nuclear Development will need to 

continue to coordinate with the Trust on ways to avoid or mitigate the adverse effect on the site. If site . 

avoidance is not possible, UniStar will need to provide the Trust with documentation detailing the constraints 

and providing justification as to why site 18CV 4 74 cannot be avoided during construction. ,If site avoidance is 

not possible, Phase III data recovery investigations will be warranted to mitigate the undertaking's adverse 

effects on the archeological property. All parties will need to negotiate and ,execute a Memorandum of 

Agreement (MOA) that stipulates the agreed-upon mitigation measures, including the Phase III investigations, 

methods of public outreach and interpretation, and the curation of all artifacts and materials generated by the 

investigations conducted at site 18CV474. The Trust must be provided with a draft Data Recovery Plan for site 

i8CV4,74 so that we may provide appropriate comments and recommendations. Following our review and 

approval oftbe Data Recovery Plan, we will be happy to draft an MOA for the purpos~s of review and 

comment. 

Please note that a suppJeI)1ental Phase I CuIWra1~esources Investigation report was submitted'to ou~ office by 

,UniStar,on February 9, 2009. This document provided a summary of the methods, results, I\Uld 

recommendations of Phase I archeological investigations that were carried out at three new localities (Preston's 

Cliffs Wetland ,MitigationArea, Camp Conoy Wetiand Mitigation Area, and the Old Bay Farm Access Road). 

III short, the supplemental Phase i survey identified in extension of a previously -recorded site - l8CV7. This 

site' represents an early nineteenth to twentieth century domestic component associated with the National 

Register eligible 'Preston's Cliffs Farmstead (CT-59), We understand that the portion of site 18CY7 that was 

most recently recorded by GAl is located within the Preston's Cliffs Wetland Mitigation Area and may be , 

impacted by tree planting activities. GAl has recommended either site avoidance or further (Phase II)· 

archeological investigations to evaluate the site'sNationill Register eligibility prior to these activities. It is our 

, opinipn, hmvevei, thata Phase)l stUdy bfthe portion of site 18CV7 that is to be impacted would not be . 

meaningful or appropriate at this titne, as the purpose ofa Phase II investigation is to evaluate an archeological 

resource in its entirety and~o provide a definitive statement regarding the overalLsite's integrity, significance, 

and National Register eligibility. We are therefore recommending that the area containing a poriion of site. 

18CV7 be reforested through the hand-planting of seedlings, as this piactice is unlikely to have an ad:verse 

effect on the potentially significant nineteenth-century archeological resource. Please provide our office with a 

'copy oIthe wetland mitigation plan and map (including proposed pianting techniques) for the Preston's Cliffs 

Wetland Mitigation Area for our review, when this information becomes available. IfUniStar is unable to 

Draft NUREG-1936 F-12 April 2010 
1 

Appendix F 

utilize the hand-planting of seedlings technique in the area of site 18CV7, then further consultation regarding 

. potential impacts to ·this site will be necessary. 

Underwater Archeology: On January 20,2009, the Maryland Historical Trust (Trust) received a copy of the 

draft report on the Phase I underwater archaeological survey that was conducted for the above-referenced 

project. The document was prepared by Panarnerican Consultants, Inc,and prepared for MACTEC Federal 

Programs, Inc. We have reviewed the draft report in accordance with Section .106 of the national Historic 

Preservation Act of 1966, as amended, .and are writing to provide our comments regarding effects Otl. historic 

and archeologi~al properties. . 

The draft report,Submerged Cultural Resources Survey of a Proposed Outfall Pipe, Calvert Cliffs Nuclear 

Power Plant Unit 3 Construction, Calvert County, Maryland (Faught 2008), is not consistent with the reporting 

requirements of the Trust's Standards and GUidelines for Archeological Investigations in Maryland (Shaffer . 

and Cole 1994) and will require'revisions before the report can be accepted. 

The Phase I survey was carried out during March of 2008 and consisted of an electronic remote-sensing survey 

within the proposed project area utilizing side-scan sonar, magnetometer, and sub~bOttom profiler. Although 

the Maryland Inventory of Historic Properties records no known historic resources within the project area, the 

dredging activity has the potential for destroying <:urrently unknown archeological, scientific, prehistoric, or 

historical data. While the draft Phase I report states that "none oXthe magnetic anomalies or side-scan targets 

are considered potentially significant for the purpose of this investigation", the Trust feels that the author of the 

report failed to adequately illustrate the lack of significance with clear figures and data. The lack of a clearly 

defined.project APE within the report also hampered the Trust's ability to determine which of the targets might 

be impacted by the proposed construction of the outfall pipe. Much of the surveyed area appears well squth of 

. the propos!';d outfall pipe .. The Trust is also confused by the use of lOO-ft lane spacing, when the Trust often 

requires 50-ft lanespadng in submerged cultural resource surveys to. ensure complete coverage and adequate 

resolution of tb,e magnetic anomaJies that might represent historic wrecks or other archeological resources. 

Specific comments and ·reconunendations will follow. 

Based on the documentation presented in this report, we concur thatthe proposed outfall pipe construction is 

unlikely.to impact any significant cultural resources. For this reason, we believe that the portion of the Calvert 

Cliffs Nuclear Power Plant that includes the Proposed Outfall Pipe possesses no archeological research potential 

and that further archeological investigations are not warranted forSection 106 purposes. lfthe proposed outfall . 

. pipe is realigned, per the report recomm·endations, further consultation will be required and a resUrvey of the 

area might be requested. The Section 106 requirements for this particular undertaking have, in fact been . 

. ·fi.i1filled. We lookforWard to receiving two copies of the final report, revised to address the Trust's comri:lents, 

for our library.·' . . '. 

Specific Comments; . 

• An maps should contain a North Arrow and a Scale 

• P. 1 Introdu.ction. The survey area should be stated in acres and hectares. 

• P. 3 Environmental SC.tting; No evidence is provided for the statement, "The geologic beds of the cliffs 

(eroded portions of old sediment beds) apparently continue underwater according to the sidescan 

record." 

• P. 4 figure 4 requires a citation 

April 2010 F-13 Draft NUREG-1936 
1 

Appendix F 

• p, 7- 8 Methods: magnetometer - section needs to include the coverage ofthe magnetometer and the 

height towed above the seafioor, 

• P,12 Methods: GIS Mapping Locational Controls and Analysis - the bathymetric map referenced in this 

section was not included in the report 

o Figure 12- it would be helpful if a background image of the marine chartlUSGS quad was 

included behind the track lines and magnetic data, . 

• p, 13-19 Results Section 

o There is not enough information in this section of the report to independently verify the author's 

results 

• M06, in particular, needs to be described in more detail, and the rationale for dismissing . 

. this object, which has a relatively large amplitude and long duration·and is de.scribed as a complex dipole. .. . 

• Higher resolution images of side-scan targets I - 4 need to be included for completeness, 

and so that the Trust can assess these objects, 

• Fig. 17-18 - it would be helpful if a background image of the marine chartfUSGS qU11d 

was included behind the mosaics. 

• The results section references a paleochannel feature identified with th~ subbottom 

profiler, but there is no direct evidence of the presence of the paleochanlnel other than the· 

green shading included on Figure 18 .. The section on the presence and ~nterpretation of 

the paleochannel needs to be included so that individuals reading the report can clearly 

andindependently verify its presence. . . I 

I 

I 

I 

, '. • • . ." I 

Historic Built Environment: Investigations. to identify historic buildings, structures, andlanl:1scapes that 

might be affected by the pr9posed power plant expansion identified'four places that are eligib~e for listing in the 

National Register of Historic Places. Parrah's Park (CT-58) and Preston's Cliffs (CT-59) C(Jndlin tobacco barns 

that are significant for their association with agricultural history. The Drum Point RailroadBtd (CT-1295) is 

significant for its association with local history and engineering. Camp Conoy (CT-1312) is significant for its 

association with important trends in recreational and social hi story. . I. . • .' I 

The Trust has reviewed the recommendations in the report Letter Report, Criteria of Effects E~aluation, Calvert 

Cliffs Nuclear Power Plant. !he report fmds that the proposed power plant ex:pansio? wi.H nOf adversely affect·' 

Partan.'s Park or Preston's Chffs. The report also flllds that the proposed work will reqUire' th¥·alteration and .. : 

demolition of portions of the Dnun Point Railfoad Be~ and Camp Conoy. The Trust agrees tHat these changes 

would constitute an adverse effect to historic properties. . . " .: I . 

. . . ·1 

In the event of an adverse effect finding, 36 CFR800.6 requires the. responsible agency to co~tinue, consultation 

with the Trust, other interested parties, and the general public to identify and consider alternative plans that can 

avoid; minimize; and, if necessary, mitigate adverse effects. Interested parties should includeiihe county 

government and local history groups. Examples of efforts to minimize adver.e effects includ~ using vegetative 

buffers to minimize visual effects and moving, rather than demolishing, historic buildings. E~amples of ~fforts 

to mitigate adverse effects include documentation and the study, survey, or repair of historic r6sources that are 

similar to those that must be_ demolished. I 

Draft NUREG-1936 F-14 April 2010 
1 

2 

Appendix F 

We recommend that the Corps's applicant proceed with the Section 106 process by consulting with as broad a 

range of interested parties aspracticaJ and compiling their recommendations about the best ways to avoid, ' 

minimize, and mitigate the adverse effects of the undertaking. As noted above, once the results ofthis 

consultation and detailed information about the nature of the adverse effects are provided to the Trust, the Trust 

wiUprovide a draft MOAto the Corps and UniStar for review and consideration. 

Thank you for providing us with this opportunity to comment., If you have questions or require assistance, 

please contact'Dixie Henry (regarding terrestrial archeology) at 410-514-7638 \ dhenry(a),mdp.state.md.us, 

Jonathan Sager (regarding historic buildings and landscapes) at 41 O~514~ 7636 \ i sager@mdp.state.md:us; or 

Brian,Jordan (regarding underwater archeology) at 410-514-7668\ bjordan(ciJ,mdp.state.md.us. 

Sincerely. 

~~ 

~~~uw. Director \ State Historic Preservation Officer 

Maryland Historical Trust 

JRL\DLHIJES 

200803669 

CC: ,Kathy Anderson (COE) 

Susan Gray (PPRP) 

R. McLean (DNR) 

Yvonne F.' Abemethy (Constdlation Energy) 

'Dimitri Lutchenkov (UniStar) 

Ben Resnick (GAl) , 

Barbar A. Munford (GAl) 

Kirsti Uunila (Calvert County) 

April 2010 F-15 Draft NUREG-1936 
1 

Appendix F 

preserving America's Heritage 

July 24, 2009 

Ms. BethE. Bachur 

Acting Chief, Maryland Section Southern 

Baltimore District, U.S. Army Corps of Engineers 

P.O. Box 1715 

Baltimore, MD 21203-1715 

Ref, Proposed Calvert Clip Nuclear Power Plant Project 

Calvert CoUU{JI, Maryland 

DearMs. Bachur: 

On July 17, 2009, the Advisory COlmcil on Historic PreselVation (ACHP) received your notification and 

supporting documentation regarding the adverse effects of the referenced project on properties listed on 

and eligible for listing in the National Register of Hi storie Places. Based upon the information you 

provided, we have concluded that Appendix A, Criteriafor CouncilIl1I'olvement in Reviewing Individual 

Sectioni 06 Cases, of our regulations, "Protection of Historic Properties" (36 CFR Part 800), does not 

apply to tlris undertaking. Accordingly, we do not believe thai our participation in the consultation to 

resolve adverse effects is needed. However, if we receive a request for participation from the State 

Historic Preservation Officer (SHPO), Tribal Historic Preservation Officer, affected Indian tribe, a 

consulting party, or other party, we may reconsider this decision Additionally, should circumstances 

change, and you determine that our participation is needed to conclude the consultation process, please 

notify us. 

Pursuant to 36 CFR §800.6(bX1)(iv), you will need to file the final Memorandum of Agreement (MOA), 

developed in consultation with the Maryland SHPO and any other consulting parties, and related 

documentation with the ACHP at the conclusion of the consultation process. The filing of the MOA and 

supporting documentation with the ACHP is required in order to complete the requirements of Section 

106 of the National Historic Preservation Act. 

Tlumk you for providing us with the opportt:mity to review this undertaking. If you have any questions, 

please contact Tom McCulloch at 202-606-8554, or via email at tmcculloch@achp.gov. 

Sincerely, 

Raymond V. Wallace 

Historic Preservation Technician 

Federal Property Management Section 

Office of Federal Agency Programs 

ADVISORY COUNCIL ON HISTORIC PRESERVATION 

1100 Pennsylvania Avenue NW, suite 803 Washington, DC 20004 

Phone: 202-606-8503 ~ Fax: 202-606-8647 ~ achp@achp.gov ~ www.achp.gov 

Draft NUREG-1936 F-16 April 2010 
1 

April 2010 

REPlY,Q 

ATTENT10N OF 

Operations Division 

Mr. Mi(;hael Lesar 

DEPARTMENT OF THE ARMY 

BALTIMORE DISTRICT. O.S. ARMY CORPS OF ENGINEERS 

P.O. BOX 1715 

BALTIMoRe. MO 21203-H1S 

JUl3D11JOI 

Chief, Rules and Directives Branch 

Division of Administrative Services 

Mai1stop T6-D59 

U.S. Nuclear Regulatory Commission 

Washington, DC 20555-0001 

Dear Mr. Lesar: 

Appendix F 

This is in reference to the Phase I Mitigation Plan forthe Department of the Army 

(DA) pennit application NAB-2007-08123-MOS (Calvert Cliffs 3 Nuclear Project, 

LLC/Unistar Nuclear Operating Services, LLC) to construct the proposed Calvert Cliffs 

Nuclear Power P1ant Unit 3 in the Chesapeake Bay and unnamed tributaries to the 

Chesapeake Bay, forested non-tidal wetlands, Johns Creek and Goldstein Branch and 

their unnamed tributaries at Unistar's Calvert Cliffs site near Lusby, Calvert County, 

Maryland. 

We have reviewed the Phase I Mitigation Plan dated February 18,2009, and find that 

the proposal to enhance one manmade, abandoned sediment basin within the Lake Davies 

Disposal Area; to enhance portions of lohns Creek; to create forested and herbaceous 

wetland habitat within the largest manmade, abandoned, sediment basin on the 

Lake Davies disposal area; to create forested wetland habitat within the Camp Conoy 

area; to construct stream restoration; and to construct stream enhancement is conceptually 

acceptable as a suitable methodology to provide compensatory mitigation for the 

proposed project impacts to Waters of the U.S., including jurisdictional wetlands. 

The proposed wetland mitigation includes creation of approximately 0.9 acres area of 

open water pond habitat; 1.3 acres of freshwater marsh; 7.2 acres of bottomland 

hardwood forest; eradication of invasive vegetation and enhancement of approximately 

2.4 acres of bottomland hardwood forest; enhancement of wetlands abutting Johns Creek 

by eradication of invasive vegetation and enhancement of approximately 15.7 acres of 

bottomland hardwood forest; and creation of approximately 4.6 acres of forested wetland 

habitat. The proposed stream mitigation includes restoration of stream functions along 

approximately 6,283 linear feet of stream portions by employing treatments such as 

instream habitat structures (cover logs, lateralllongitudinal diversity and root wads); bank 

stabilization (vegetative and bioengineering solutions); and riparian wetland 

enhancements (hydraulic and vegetative). The proposed stream mitigation also includes 

enhancement of a total of approximately 4,146 linear feet of specific stream portions by 

improving aquatic habitat, constructing bank: stabilization and planting native riparian 

vegetation. These proposed compensatory mitigation projects must be monitored for a 5-

F-17 Draft NUREG-1936 
1 

Appendix F 

year period and must be protected in perpetuity through establis1nnent of a legally 

binding long~term protection mechanism. The final mitigation plan must comply with 

the U.S. Anny Corps of Engineers Regulatory Guidance Letter No. 08-03 (Minimum 

Monitoring Requirements for Compensatory Mitigation Proj eels Invo1ving the 

Restoration, Establishment andlor Enhancement of Aquatic Resources, dated October 10, 

2008). The Final Mitigation and Monitoring Plan should be an update of the Phase 1 

Mitigation Plan based on actual field survey conditions and qualitative/quantitative data. 

In addition, tbe Final Mitigation and Monitoring Plan should include final construction 

design plans and the following: 

1. Content of the final compensatory mitigation plan must be based on the final 

proposed project impacts and results of the ground truth surveys and analysis. 

2. Detailed explanation for any deviations from the Phase I pian. 

3. Detailed short~tenn and long-term plans to control Phragmitis australis (common 

reed) within and in the vicinity ofthe proposed wetland and stream creation, 

enhancement and restoration areas before, during and after the proposed 

mitigation work. 

4. A sununary of the various assessment methods or analytical models used and 

definition oftbe basis for the ratings or criteria. 

S. A description of upland conditions On site that could have a detrimental impact on 

the mitigation areas and a description of work in uplands on site that could 

ameliorate future potential impacts to mitigation areas. 

6. A declaration and a plan sheet illustration showing that work in the lOO-foot wide 

stream mitigation area centered at the confluence of the stream with the 

Cbesapeake Bay will be restricted from June 1 through August 31, inclusive of 

any year, t6 avoid impacts to tiger beetle habitat. 

7. A declaration that only wetland vegetation species that are native and nonpersistent will be planted in the wetland mitigation areas 

8. A declaration ensuring the wetland and stream creation, enhancement and 

restoration areas continue to function as wetlands as defined in the Corps Wetland 

Delineation Manual (87 Manual) (i.e., the areas must exhibit wetland hydrology, 

hydric soils and a predominance ofbydrophytic vegetation) and the streams 

continue to function as designed after work is completed. 

9. A declaration that the wetland creation and enhancement areas will be field 

checked to ensure that elevations will achieve the hydrology necessary to support 

the plants species proposed for planting in those areas. If the wetland creation 

and enhancement areas do not thrive, the reasons for failure will be determined; 

corrective measures will be taken and the area replanted. 

10. A signed document that ensures appropriate financing will be set aside to cover 

the estimated potential costs of remediation for the compensatory mitigation 

projects if stipulation number 8 above is not accomplished as required by the 

Corps. 

2 

Draft NUREG~1936 F-18 April 2010 
1 

April 2010 

In addition. Calvert Cliffs 3 Nuclear Project, LLcmnistar Nuclear Operating Services, 

LLC must provide a draft restrictive covenant document for permanent conservation 

easements on the wetland and stream creation, enhancement and restoration areas to the 

Corps at least 45 days prior to completion of the Final Mitigation and Monitoring Plan. 

Onl;e the dOl;umenl is approved by the Corps, a copy of the signed document and 

confinnatory evidence that the said documents have been filed in the land records of the 

appropriate County must be included in the Final Mitigation and Monitoring Plan. 

Appendix F 

A copy of this letter will be fumished to Ms. Laura Quinn. NRC, Ms. Cheryl Kerr, 

MDE, Mr. Michael Milbradt, Calvert Cliffs 3 Nuclear Project, LLC, and Mr. Dimitri 

Lutchenkov, Unistar Nuclear Operating Services, LLC. If you nave any questions 

concerning this lener, please call Mrs. Kathy Anderson, of this office, at (410) 962- 5690. 

Sincerely, 

Beth E. Bachur 

Acting Chief, Maryland Section Southern 

3 

F-19 Draft NUREG-1936 
1 

Appendix F 

DEPARTMENT OF 

NATlRALREsoURCES 

Martin O'Malley, Govemo' 

Anthony G.Srown, Lt. Govemo' 

John R. GYlffln, Secretary 

Eric Scllwaab, Deout'j Secretary 

November 13,2009 

Ms Laura Quinn, Environmental Program Manager 

Office of New Reactors 

US Nuclear Regulatory Commission 

11555 Rockville Pike 

Rockville, MD 20852 

SUBJECT: INFORMATION REQUEST AND CONSULTATION REGARDING THE 

COMBINED LICENSE APPLICATION FOR CAL VERT CLIFFS NUCLEAR 

POWER PLANT UNIT 3 

Dear Ms. Quinn: 

This letter responds to Mr. Robert Schaaf's letter of October 26, 2009 to Secretary Shari 

Wilson, of the Maryland Department of the Environment, regarding the combined license application 

for Calvert Cliffs Nuclear Power Plant Unit 3. 

As you know, the State of Maryland is participating as an Interested State in the subject case. 

The State lead is the Power Plant Research Program, who has been actively engaged in the process, 

including participating in the recent site visits to Eastalco and Bainbridge. 

In 2007, UniStar applied to the Maryland Public Service Commission (PSC) for a Certificate 

of Convenience and Necessity (see http://webaW.psc.state.md.us; select Case 9127). Pursuant to the 

case, the State of Maryland undertook an environmental review process similar to the one the NRC is 

currently undergoing. The Maryland Department ofN atural Resources, the Maryland Department of 

the Environment, as well as 5 other executive branch State agencies, conducted a coordinated, 

consolidated review of the Calvert Cliffs Unit 3 proj ect. The review resulted in recommending almost 

one hundredhcensing conditions to the PSC. The PSC approved the project on June 26, 2009, and 

these conditions, in their final form, are presented in items 114 and 139 of the PSC 9127 case jacket. 

In particular, please note Conditions 43-53, which cover terrestrial and ecological aspects, including 

threatened and endangered species. 

With regard to alternative site evaluation, Maryland no longer requires alternative siting 

studies as a part of our power plant evaluations. However, PPRP has conducted site specific 

evaluations at the Bainbridge site as well as the Eastalco site. The Environmental Review Documents 

related to these two sites were provided to Ms. Maryann Parkhurst of your evaluation team shortly 

after the Bainbridge and Eastalco site visits. Although these evaluations were done based on other 

Tawes State Office Building· 580 Taylor Avenue' Annapolis, Maryland 21401 

410.260.8DNR or toll free in Maryland 877.620.8DNR • www.dnr.maryland.gov • TIV users call via Maryland Relay 

Draft NUREG-1936 F-20 April 2010 
1 

2 

Appendix F 

power plant designs, we believe they provide an excellent overview of general site conditions, 

including terrestrial and aquatic ecology. We have not conducted any studies of the Thiokol site. 

We appreciate the opportunity to provide you with feedback on these and other important 

matters. If you have any questions, please give me call (410-260-8661) or send me an email 

(sgray@dnr.state.md.us). 

cc: Shari \Vilson, Secretary MDE 

Bill Paul, Chief, ARMA 

Pete Dunbar, Director, PPRP 

Brent Hare, AAG 

Brent Bolea, AAG 

April 2010 

Sincerely, 

Susan T. Gray 

Manager, Nuclear Programs 

Power Plant Research Program 

F-21 Draft NUREG-1936 
1 

Appendix F 

MEMORANDUM TO: 

FROM: 

SUBJECT: 

Laura Quinn 

Habitat Conservation Division 

Chesapeake Bay Program Office 

410 Severn Ave., Suite 107A 

Annapolis, Maryland 21403 

December 10, 2009 

Environment Projects Branch 3 

Nuclear Regulatory Commission 

John Nichols 

Calvert Cliffs Nuclear Power Plant, Unit 3 

Alternative Sites Analysis 

This pertains to your request, dated October 26,2009, for information on National 

Marine Fisheries Service (NMFS) trust resources, and NMFS regulatory review issues 

that should be considered in evaluating three alternative sites the Environmental Impact 

Statement (in preparation) for the proposed Calvert Cliffs Nuclear Power Plant, Unit3, in 

Calvert County, Maryland. The three alternative sites (all in Maryland) include: 1) the 

Bainbridge Site, in Port Deposit, Cecil County; 2) the Thiokol Site, near Mechanicsville, 

St. Mary's County, and; 3) the Eastaclo Site, in Frederick County. I have provided the 

following ·infonnation. 

Bainbridge Site 

Of the three alternative sites, Bainbridge is ofhighest value to living marine resources 

under NMFS purview. The Susquehanna River is a documented migratory corridor 

and/or spawning/nursery ground for several species of imadromous and catadroinous fish, 

including striped bass, white perch, yenow perch. alewife, blueback herring, hickory 

shad, American shad, and American eel. Generally firmlhard bottom along the Port 

Deposit shoreline provides ideal habitat for anadromous species with demersal eggs 

(deposited on, and adhering to bottom substrate); i.e., alewife, blueback herring, hickory 

shad, and American shad. 

The Port Deposit shoreline is also a historically important area for submerged aquatic 

vegetation (SA V). Dense, multi-species beds occur annually at Marina Park in Port 

Deposit, extending channelward up to 100 feet from the mean high water shoreline, SAY 

significantly enhances nursery ground values for the above anadromous species. Virginia 

Institute of Marine Science annual aerial SA V surveys for the Chesapeake Bay (Havre de 

Grace Quad) should be referenced to determine historical occurrence and distribution of 

SA V along the Port Deposit shoreline. 

Draft NUREG-1936 F-22 April 2010 
1 

Appendix F 

Power plant cooling water intakes, such as that which would be required for a nuclear 

facility at Bainbridge, can jeopardize reproductive potential of spawning anadromous fish 

through impingement and entrainment of eggs and larvae. It is preferable that such 

intakes not be sited within anadromous fish spawning grounds. Where spawning ground 

locations are unavoidable, NMFS recommends strict intake design criteria to minimize 

egg and larvae mortality, including the following measures. 

1. Wedge wire screening on intake openings, preferably with 1 mm mesh size, 

but not greater than 2mrn meshsize. Back-flush mechanisms are generally 

required to maintain the latter small-mesh screening free from clogging. 

2. lntake velocities which do not exceed 0.5 feet per second. 

3. Recessed intakes, constructed off the main waterway, which are less 

accessible to anadromous fish life stages. 

Dredging of an intake channel for a Bainbridge Power Plant intake, required to maintain 

adequate flow velocities and volumes, would also pennanently convert hard bottom and 

SA V bed to fine-grain unvegetated substrate, of lower value to anadromous fish 

reproductive activities. 

The Susquehanna River at Port Deposit is essentially freshwater riverine, near the head of 

tidal influence, and upstream of Essential Fish Habitat, as designated under the 

Magnuson-Stevens Fishery Conservation & Management Act (MSA). Consequently, 

selection of the Bainbridge site would not directly affect federally managed species under 

MSA, such as bluefish and summer flounder. However, anadromous fish that spawn in 

the Port Deposit area are important prey for bluefish and summer flounder in the 

Chesapeake Bay, and impacts to the reproductive potential of these prey species would 

indirectly affect managed predatory species, While addressing the impacts ofthc 

Bainbridge site under MSA consultation is not required, it is recommended, because of 

the importance of the lower Susquehanna to anadromous prey species. Addressing of the 

Bainbridge site under MSA consultation could be included as an addition to the Essential 

Fish Habitat assessment currently being prepared by your agency for the Calvert Cliffs 

site. 

The lower Susquehanna River below Conowingo Dam has been detennined to be 

important forage habitat for the endangered shortnose sturgeon, and may also support 

spawning activity for this species. Your agency should contact Julie Crocker of our 

Protected Resources Division in Gloucester, MA; (978) 281~9328; ext. 6530, or 

Julie.Crocker@NOAA.GOV, to determine your Section 7 consultation responsibilities 

for the Bainbridge site under the Endangered Species Act. 

April 2010 F-23 Draft NUREG-1936 
1 

Appendix F 

Tbiokol Site 

Withdrawal of cooling water from the Patuxent River would our agency's primary 

concern with selection of the Thiokol Site. Such an intake would be located downstream 

of the anadromous fish spawning grounds in the river. However, juveniles and adults of 

anadromolls species seasonally migrate through the lower Patuxent River, including 

striped bass, white perch, yellow perch, alewife, and blueback herring. The latter life 

stages are mobile, pelagic in occurrence, and would, to a lesser degree than eggs and 

larvae, be susceptible to impingement.and entrainment fTom a cooling water intake. 

Other commercially important estuarine species that forage and nursery in the lower 

Patuxent River, which would be susceptible to impingement and entrainment from a 

cooling water intake, include blue crab, spot, croaker, weakfish, menhaden, American 

eel, winter flounder; and, veliger larvae of American oysters, produced by adult oysters 

on Natural Oyster Bars (NOB). A cooling water intake should ·located as far as possible 

away from NOBs, to minimize oyster larvae mortality. 

Annual salinities in the Jack Bay area of the lower Patuxent River range from 9 to 13 ppt, 

and the lower Patuxent River has been designated as EFH for several federally managed 

species under MSA. Based on species ecology and salinity tolerances, federally managed 

species that occur 1n the lower Patuxent River include adult and juvenile bluefish, and 

adult and juvenile summer flounder, A bottom oriented intake would increase 

susceptibility of summer flounder to impingement/entrainment, and should be factored 

into impact cons.iderations for this s.ite. Addressing potential impacts to EFH and 

managed species from a cooling water intake in the lower Patuxent River could be as an 

expansion of the EFH assessment currently in preparation for the Calvert Cliffs site. 

The Thiokol site lies along the drainage divide between the Patuxent and Potomac Rivers. 

Nontidal streams associated with the site are headwater systems, such as Tom Swamp 

Run and Rich Neck Creek, tributaries to McIntosh Run. Both streams likely provide 

nursery/forage ground for female American eel. White perch and yeHow perch spawning 

grounds occur downstream of tho Thiokol Site, and would be indirectly affected by 

adverse changes to the hydrology of upstream tributaries resulting from development of 

the site. 

Eastaclo Site 

The Potomac River drainage in Frederick County lies upstream of Great Falls, a natural 

barrier to migratory fish, with the exception of American ee!. Due to limited manpower, 

NMFS Habitat considers the Potomac River above Great Falls as a No Resources area, 

and does not participate in regulatory review of projects located in the upper Potomac 

drainage. We, therefore, have no resource or rCh'Ulatory input for the Eastaclo Site. 

If you have any questions, or additional information needs, please contact me at 

(410) 962-5675; or, John.Nichols@NOAA.GOV. 

Draft NUREG-1936 F-24 April 2010 
1 

January 28,2010 

United States 

United States Department of the Interior 

FISH AND WILDLIFE SERVICE 

Chesapeake Bay Field Office 

177 Admiral Cochrane Drive 

Annapolis. MD 21401 

410/573-4575 

Nuciear regulatory commission 

Wa$wngton; .D.C. 2055~-OOOl 

Appendix F 

.. . RE: In/017tiatidnand Consuitation ~equesi regarding the combined license tipplfcation!or 

. . . Calvert clfttS Nuclear Power Plant Unit 3 . . 

Dear: Robert G. Schaaf 

This responds to your letter, received November 16, 2009, requesting information on the 

presence of species which are federally listed or proposed for listing as endangered or threatened 

within the above referenced project area. We have reviewed the information you enclosed and 

are providing cOmIDe'nts in accordance with section Tofthe Endangered Species Act (87 Stat. 

884, as amended; 16 U.S.C. 1531 et seq.). 

The federally threatened bog turtle (Clemmys muhlenbergii) may be present within the project 

area or within the vicinity of the project. Bog turtles primarily inhabit palustrine wetlands 

comprised of a muddy bottom or shallow water, and tussocks of vegetation. A survey for bog 

turtle habitat and bog turtles may be appropriate. These surveys should be conducted at any 

location where the Maryland Wildlife and Heritage Division recommends. Upon completion; 

survey reports shouJd be forwarded to both the Service and the Maryland Wildlife and Heritage 

Division for review. If you have not already sent a copy of your request for threatened and 

endangered species information to the Maryland Department of Natural Resources Wildlife and . 

Heritage Division (580 Taylor Avenue, E-l, Annapolis MD 21401), please do so. Ms. Lori 

Byrne of the Wildlife and Heritage Division will provide additional information regarding the 

need for surveys and a list of experts who are qualified to perform such surveys. 

Except for occasional transient individuals, no other federally proposed or listed endangered or 

threatened species are known to exist within the project impact area. Should project plans 

c\1ange,or if additional information on the distribution oflisted or proposed species becomes . 

available, this determination may be reconsidered. 

This response relates only to federally protected threatened or endangered species under our 

. jurisdiction. For information on the presence of other rare species, you should contact Lori 

Byrne ofthe Maryland Wildlife and Heritage Division at (410) 260-8573. 

April 2010 F-25 Draft NUREG-1936 
1 

Appendix F 

Effective August 8, 2007, under the authority of the Endangered Species Act of 1973, as 

amended, the U.S. Fish and Wildlife Service (Service) removed (de list) the bald eagle in the 

lower 48 States of the United States from the Federal List of Endangered and Threatened 

Wildlife. However, the bald eagle will still be protectedhy the Bald and Golden Eagle 

Protection Act, Lacey Act and the Migratory Bird Treaty Act. As a result, starting on August 8, 

2007, if your project may cause "disturbance" to the bald eagle, please consult the "National 

Bald Eagle Management Guidelines" dated May 2007. 

If any planned' or ongoing activities cannot be conducted in compliance with the National Bald 

Eagle Management Guidelines (Eagle Management Guidelines), please contact the Chesapeake 

Bay Ecological Services Field Office at 410-573-4573 for technical assistance. The Eagle 

Management Guidelines can be found at 

http://www.fws.gov/migratorybirds/issues/BaldEaglelNationaIBaldEagleManagementGuid 

elines.pdf. 

In the future, if your project can not avoid disturbance to the bald eagle by complying with the 

Eagle Management Guidelines, you will be able toapply fora permit that authorizes the take of 

hald and golden eagles und.er the Bald and Golden Eagle Protection Act,. generally where the' 

:take to be authorized is associated with otherwise lawful activities. This proposed permit' 

process will not be available until the Service issues a final rule for the issuance of these take 

permits under the Bald and Golden Eagle Protection Act. 

An additional concern of the Service is wetlands protection. Federal and state partners of the 

Che$apeake Bay Program have adopted an interim goal of no overall net loss of the Basin's 

remaining wetlands, and the long term goal of increasing the quality and quantity of the Basin's 

'wetlands resource base. Because of this policy and the functions and values wetlands perform, 

the Service recommends avoiding wetland impacts, All wetlands within the project area should 

be identified, and if construction in wetlands is proposed, the U.S. Army Corps of Engineers, 

Baltimore District, should be contacted for permit requirements. They can be reached at (410) 

962-3670. 

We appreciate the opportunity to provide information relative to fish and wildlife issues, and 

thank you for your interest in these resources. If you have any questions or need further 

assistance, please contact Andy Moser at (410) 573-4537. 

Sincerely, 

Leopoldo Miranda 

Field Supervisor 

cc: Lori Byrne, Maryland Wildlife and Heritage Division, Annapolis, MD 

Draft NUREG-1936 F-26 April 2010 
1 

United States Department of the Interior 

FISH AND WILDLIFE SERVICE 

Chesapeake Bay Field Office 

February 25,2010 

Mr. Robert G. Schaaf 

United States 

Nuclear regulatory commission 

Washington, D.C. 20555-0001 

177 Admiral Cochrane Drive 

Annapolis, MD 21401 

410/573-4575 

Appendix F 

. RE: New alternative sites. in Marylandfor Calvert clifft Nuclear Power Plant Unit 3: 

Bainbridge Naval Training Facility site, Cecil County; Thiokol site, St. Mary's County; 

Eastalco site, Frederick County. 

Dear Robert G. Schaaf: 

This responds to your letter, received Novemper 16,2009, requesting information on the 

presence of species which are federally listed or proposed for listing as endangered or threatened 

within the above referenced project areas and your February 12,2010, request for more specific 

information concerning these alternative sites. We have reviewed the information you enclosed 

and are providing comments in accordance with section 7 of the Endangered Species Act (87 

Stat. 884, as amended; 16 U.S.C. 1531 et seq.). 

, The federally threatened bog turtle (Clemmys muhlenbergii) may be present within the project 

area or within the vicinity of the Bainbridge Naval Training Facility site. Bog turtles primarily 

inhabit palustrine wetlands comprised of a muddy bottom or shallow water, and tussocks of 

vegetation. A survey for bog turtle habitat and bog turtles may be appropriate. These surveys 

should be conducted at any location where the Maryland Wildlife and Heritage Division 

recommends. Upon completion, survey reports should be forwarded to both the Service and the 

Maryland Wildlife'alTa Heritage Division forrevi.ew~ If you have notal ready-sent a copy of your 

request for threatened and endangered species information to the Marylaiid Department of . 

N~tural Resources Wildlife and Heritage Division (580 Taylor Avenue; E-1, Annapolis MD -" 

21401), please do so. Ms. LoriByme of the Wildlife and Heritage Division will provide 

additional information regarding the need for-surveys and a list of experts who are qualified to 

perform such surveys. -

The Federally endangered dwarf wedge mussel (Alasmidonta heterodon) may be present within 

the area affected by the development of the Thiokol site. This freshwater mussel occurs in 

McIntosh Run and may be affected by changes in flow or water quality in tributary streams 

which originate near the Thiokol site. 

April 2010 F-27 Draft NUREG-1936 
1 

Appendix F 

' .. Except for occasional transient individuals, no federally proposed or listed endangered or 

threatened species are known to exist within the vicinity of the Eastalco site .. Should project 

plans change, or if additional information on the distribution of listed or proposed species 

becomes available, this determination may be reconsidered. 

This response relates only to federally protected threatened or endangered species under our 

jurisdiction. For information on the presence of other rare speCies, you should contact Lori 

Byrne of the Maryland Wildlife and Heritage Division at (410) 260-8573. 

Effective August 8, 2007, under the authority of the Endangered Species Act 0(1973, as 

amended, the U.S. Fish and Wildlife Service (Service) removed (delist) the bald eagle in the 

lower 48 States of the United States from the Federal List of Endangered and Threatened 

Wildlife. However, the bald eagle will still be protected by the Bald and Golden Eagle 

Protection Act, Lacey Act and the Migratory Bird Treaty Act. As a result, starting on August 8, 

2007, if your project may cause "disturbance" to the bald eagle, please consult the "National 

Bald Eagle Management Guidelines" dated May 2007. . 

If any planned or ongoing activities cannot be conducted in compliance with the National Bald 

Eagle Managkinent Guidelines (Eagle Management Guidelines), please contact the Chesapeake 

Bay Ecological Services Field Office at 410-573-4573 for technical assistance. The Eagle 

Management Guidelines can be found at: 

http://www.fws.gov/migratorybirds/issueslBaldEaglelNationalBaldEagleManagementGuid 

eliDes. pdf. 

" In the future, if your project can not avoid disturbance to the bald eagle by complying with the 

Eagle Management Guidelines, you will be able to apply for a permit that authorizes the take of 

bald and golden eagles under the Bald and Golden Eagle Protection Act, generally where the 

take to be authorized is associated with otherwise lawful activities. This proposed permit 

process will not be available until the Service issues a [mal rule for the issuance ofthese take 

permits under the Bald and Golden Eagle Protection Act. . 

An additional concern of the Service is wetlands protection. Federal and state partners of the 

Chesapeake Bay Program have adopted an.interim goal of no overall net loss of the Basin's 

remaining wetlands, and the long term goal of increasing the quality and quantity of the Basin's 

wetlands resource base. Because of this policy and the functions and values weHands perform, 

the Service recommends avoiding wetland impacts. All wetlands within the project area should 

be identified, and if construction in wetlands is proposed, the U.S. Army Corps of Engineers, 

Baltimore District, should tie contacted for permit requirements. They can be reached at (410) 

962-3670. 

We appreciate the opportunity to provide information relative to fish and wlldlife issues, and 

thank you for your interest in these resources. If you have any questions or need further 

assistance, please contact Andy Moser at (419) 573-4537. 

Sincerely, 

' . ffi~ 

poldo Miranda 

Flo!d S,"".vi"" 

Draft NUREG-1936 F-28 April 2010 
1 

2 

cc; Lori Byrne, Maryland Wildlife and Heritage Division, Annapolis, MD 

April 2010 F-29 

Appendix F 

Draft NUREG-1936 
1 

Appendix F 

REPlVTO 

ATTENTION OF 

Operations Division 

DEPARTMENT OF THE ARMY 

BALTIMORE DISTRICT. U.S. ARMY CORPS OF ENGINEERS 

P.O. BOX 1715 

BALTIMORE, MD 21203·1715 

MAR 1 6 2010 

Mr. Reid J. Nelson, Director 

Office of Federal Agency Programs 

Advisory Council on Historic PreselVation 

Old Post Office Building, Suite 803 

1100 Pennsylvania Avenue, N.W. 

Washington, DC 20004 

Dear Mr. Nelson: 

I am writing to conclude the review by the U.S. Anny Corps of Engineers, Baltimore 

District (Corps) in consultation with the Maryland State HIstoric Presetvation Officer 

(MD SHPO), regarding the Department of the Army (DX) application CENAB-OP-RMS 

(Calvert Cliffs 3 Nuclear Project, LLClUnistar Nuclear Operating SetVlCes, LLC)2007-

08123, pursuant to Section 106 ofthe National Historic PreselVation A:t of 1966, as 

amended. 

In a letter dated July 15, 2009, (Enclosure 1) and in consultation with the MD SHPO, 

we notified you that the proposed undertliking would have an adverse effect on historic 

properties in accordance with 36 CFR 800.6(a) (1). We also provided documentation 

referenced in 36 CFR 800.11 (e); Finding of no adverse effect or adverse effect. 

There have been no substantive revisions or additions to previous do:urnentation 

provided to your office regarding this project. However, the Corps, the MD SHPO and 

the pennit applicant have entercd into a Memorandum of Agreement (MOA) to resolve 

the adverse effects associated with this undertaking. As described in the subject MOA, 

the applicant, in consultation with the Corps and MD SHPO, has agreed to implement 

cultural resource studies for ancillary environmental stewardship opportunities, 

reforestation activities, or other modifications to the previously reviewf,d Project for 

which cultural resource studies have not been completed, even though f:uch treatment 

may exceed the Corps' scope of authority as published in Appendix C, and has 

participated in the consultation, has responsibilities for implementing s1ipuiations under 

the Memorandum of Agreement ("MOA"), and is a concurring party to this MOA. The 

Corps, and the MD SHPO agree that the requirement for appropriate public notice and 

involvement stated in 36 CFR 800.14 (b) (2) (ii) is satisfied by a combiaation of past 

public notice and public and agency hearings and reviews, which includes consideration 

of the Project's effects on historic properties. All of the parties to the MOA are satisfied 

that the stipulations in the MOA successfully take into account the effCl;t of the project on 

historic properties. As further described in the MOA, the public was pmvided the 

opportunity to comment on the DA application CENAB-OP-RMS (Cab'ert Cliffs 3 

Draft NUREG-1936 F-30 April 2010 
1 

Appendix F 

Nuclear Project, LLClUnistar Nuclear Operating Services, LLC) 2007-08123 by public 

notice dated September 3, 2008. No comments were received from the public on this 

project. Finally, by letter dated July 24,2009, the Advisory Council on Historic 

Preservation declined to participate in the Section 106 consultation regarding this project, 

by advising the Corps that further participation and consultation, to resolve adverse· 

effects, was not needed, (Enclosure 2). 

The MEMORANDUM OF AGREEMENT A:'\.fONG THE U.S. ARMY CORPS OF 

ENGINEERS AND THE MARYLAND STATE HISTORIC PRESERVATION OFFICER 

AND CALVERT CLIFFS 3 NUCLEAR PROJECT, LLC (AS CONCURRING PARTY) 

PURSUANT TO 36 CFR 800 AND 33 CFR PART 325 APPENDIX C REGARDING THE 

CALVERT CLIFFS NUCLEAR POWER PLANT CALVERT COUNTY, MARYLAND 

was developed to mitigate adverse effects to historic properties. In accordance with 

36 CFR 800.6(b)(l)(iv), we are filing a copy of this MOA (Enclosure 3) with your office 

to conclude the Corps' requirements under Section 106 of the National Historic 

Preservation Act for this project. Further, any Department of the Anny Section 10/404 

permit that may be issued will include special conditions for implementation of this 

executed MOA. 

Copies of the signed MOA are being provided to all of the signatories as well as 

Ms. Laura Quinn, Nuclear Regulatory Commission, and Ms. Cheryl Kerr, Maryland 

Department of the Environment. Please file the mat.mal enclosed and contact 

Mr. Woody Francis, of this office, at 410-962-5689 if you have any questions. 

Sincerely, 

Kathy 

I.~~~ B. Anderson 

Chief, Maryland Section Southern 

Enclosures 

April 2010 F-31 Draft NUREG-1936 

1 Biological Assessment 

2 

3 National Marine Fisheries Service

4 

5 

6 Calvert Cliffs Nuclear Power Plant Unit 3 

7 Calvert County, Maryland 

8 

9 

10 

11 U.S. Nuclear Regulatory Commission Combined License Application 

12 Docket No. 52-016 

13 

14 

15 U. S. Army Corps of Engineers Permit Application 

16 Permit Application No. NAB-2007-08123-M05 (Calvert Cliffs 3 Nuclear 

17 Project, LLC/UniStar Nuclear Operating Services, LLC) 

18 

19 

20 

21 

22 April 2010

23 

24 

25 

26 U.S. Nuclear Regulatory Commission 

27 Rockville, Maryland 

28 

29 

30 U.S. Army Corps of Engineers 

31 Baltimore District

Appendix F

April 2010 F-33 Draft NUREG-1936

1 1.0 Introduction 

2 The U.S. Nuclear Regulatory Commission (NRC) is reviewing an application from Calvert Cliffs 

3 3 Nuclear Project, LLC and UniStar Nuclear Operating Services, LLC (UniStar or applicant) for a 

4 combined license (COL) to construct and operate a new nuclear reactor with a design-rated 

5 gross electrical output of 1710 megawatts-electric (MW(e)) on the Calvert Cliffs site. The U.S. 

6 Army Corps of Engineers (USACE or Corps) is reviewing an application from UniStar for a 

7 Department of the Army (DA) Permit pursuant to Section 10 of the Rivers and Harbors 

8 Appropriation Act of 1899 (Rivers and Harbors Act) and Section 404 of the Clean Water Act (33 

9 U.S.C. 1344) to perform site preparation and construction activities for the proposed new unit at 

10 the Calvert Cliffs site. Currently, there are two operating nuclear reactors on the Calvert Cliffs 

11 site, Units 1 and 2. The proposed new reactor – Unit 3 – would be located adjacent to existing 

12 Units 1 and 2. The site is located about 60 mi south of Baltimore; 40 mi southeast of 

13 Washington, D.C.; 10.5 mi southeast of Prince Frederick, Maryland; and 7.5 mi north of 

14 Solomons, Maryland (Figure 1). 

15 Pursuant to National Environmental Policy Act of 1969, as amended (NEPA), the NRC and the 

16 Corps are cooperating agencies with the NRC being the lead agency, and they are preparing an 

17 environmental impact statement (EIS) as part of the agencies’ review of the COL and DA permit 

18 applications. The Corps is cooperating with the NRC to ensure the information presented in the 

19 EIS is adequate to fulfill the requirements of Corps regulations; the Clean Water Act Section 

20 404(b)(1) Guidelines, which contain the substantive environmental criteria used by the Corps in 

21 evaluating discharges of dredged or fill material into waters of the United States; and the Corps 

22 public interest review process. As required by Title 10 of the Code of Federal Regulations 

23 (CFR) Part 51.26, the NRC has published in the Federal Register a Notice of Intent (73 FR 

24 8719) to prepare an EIS and to conduct scoping. The final EIS will be issued after considering 

25 public comments on the draft EIS. The impact analysis in the EIS includes an assessment of 

26 the potential environmental impacts of the construction and operation of a new nuclear power 

27 unit at the Calvert Cliffs site and along the associated transmission line corridors, including 

28 potential impacts to the threatened and endangered species. If issued, the COL would 

29 authorize UniStar to construct and operate the new unit. The Corps will finalize its Record of 

30 Decision after issuance of the final EIS. 

31 The Corps and the NRC are conducting a joint consultation with the National Marine Fisheries 

32 Service (NMFS) pursuant to Section 7(c) of the Endangered Species Act of 1973, as amended 

33 (ESA) and have prepared this biological assessment (BA), which examines the potential 

34 impacts of construction and operation of the proposed Unit 3 at the Calvert Cliffs site on 

35 threatened or endangered species. This BA examines the potential impacts of the proposed 

36 actions on Federally listed species within the NMFS’s jurisdiction. The BA focuses on five 

37 species, the shortnose sturgeon (Acipenser brevirostrum), the loggerhead turtle (Caretta 

38 caretta), the Kemp’s ridley turtle (Lepidochelys kempii), the green turtle (Chelonia mydas), and 

39 the leatherback turtle (Dermochelys coriacea), that occur near the Calvert Cliffs site (Table 1). 

40 There are no areas designated as critical habitat near the Calvert Cliffs site. 

Appendix F

April 2010 F-35 Draft NUREG-1936
1 

2 Figure 1. Location of the Calvert Cliffs Site, 50-mi Region (UniStar 2009a) 

Appendix F

Draft NUREG-1936 F-36 April 2010
1 Table 1. Federally Listed Estuarine and Marine Species Occurring in Calvert County 

Scientific Name Common Name Federal Status 

Acipenser brevirostrum shortnose sturgeon Endangered 

Caretta caretta loggerhead turtle Threatened 

Lepidochelys kempii Kemp’s ridley turtle Endangered 

Chelonia mydas green turtle Threatened 

Dermochelys coriacea leatherback turtle Endangered 

Source: NMFS 2008 

2 2.0 Calvert Cliffs Site Description 

3 The Calvert Cliffs site is located on the Chesapeake Bay about 60 mi south of Baltimore; 40 mi 

4 southeast of Washington, D.C.; 10.5 mi southeast of Prince Frederick, Maryland; and 7.5 mi 

5 north of Solomons, Maryland (Figure 1). The site comprises about 2070 ac adjacent to 

6 Chesapeake Bay in an unincorporated area of Calvert County, Maryland. The NRC has 

7 licensed two existing nuclear generating units at the Calvert Cliffs site, Calvert Cliffs Nuclear 

8 Power Plant (CCNPP) Units 1 and 2, that have a combined net electric generating capacity of 

9 approximately 1700-1780 MW(e). Units 1 and 2 use once-through cooling systems and obtain 

10 water from the Chesapeake Bay. The combined flow of CCNPP Units 1 and 2 intakes is about 

11 5332 cfs. There are two shoreline water intake structures for the existing units that share a 

12 common forebay, and each unit has its own fish-return system. The two existing units also 

13 share a discharge pipe that enters the Chesapeake Bay north of the intake structure. South of 

14 the intake structure is a barge slip for offloading heavy replacement components. The barge 

15 slip has been used several times since 2001 to receive replacement steam generators, 

16 transformers, and vessel reactor heads, and it is likely that there would be occasional use of the 

17 facility in the future for continued operation of CCNPP Units 1 and 2, which could require future 

18 maintenance dredging (UniStar 2009b). Both existing units would remain and continue to 

19 operate and would not be affected by the proposed action. 

20 The Chesapeake Bay is one of the largest estuary systems in the world and currently supplies 

21 cooling water for CCNPP Units 1 and 2. The Bay is very productive and is an important part of 

22 the cultural and economic fabric of the area. Much of the Chesapeake Bay, including the reach 

23 that encompasses Calvert County, is considered impaired, primarily because of low dissolved 

24 oxygen (DO) and increased nutrients and sedimentation from human activities. The 

25 Chesapeake Bay Program (CBP) oversees monitoring at selected locations throughout the Bay 

26 and has developed average seasonal conditions from 1985 to 2008. One station, known as 

27 CB4.4, is in the middle of the Bay, east of the Calvert Cliffs site. The average monthly surface 

28 water temperature at this location has ranged from about 38°F (February) to about 81°F (July; 

29 August) (MDNR 2009a). The average monthly surface water salinity at station CB4.4 is typically 

30 lowest in late spring, ranging from about 10 to 11 ppt (April through June), and highest in late 

31 fall, ranging from about 15 to 16 ppt (September through November) (MDNR 2009b). Average 

32 monthly DO concentrations at station CB4.4 have ranged from about 0.3–0.4 mg/L (July; 

33 August) to 9.0–10.0 mg/L (January through March) (MDNR 2009c). Average June through 

34 September DO concentrations have been hypoxic (less than 2.0 mg/L) (Wicks et al. 2007). The 

Appendix F

April 2010 F-37 Draft NUREG-1936
1 minimum DO concentrations during those months occasionally may be anoxic (less than 

2 0.2 mg/L). 

3 Sediments near the CCNPP barge dock area primarily were composed of sand (94 to 

4 96 percent) and gravel (2 to 5 percent) with a small percentage of clay (EA Engineering 2007) 

5 and were typical for the general region (Llansó et al. 2007). Total organic carbon (TOC) in the 

6 sediments ranged from about 2.4 to 3.1 percent. Most organic compounds analyzed in the 

7 CCNPP sediments were reported as not detected (EA Engineering 2007). The concentrations 

8 of metal compounds that were detected in the sediments were such that effects are expected to 

9 be rare (Buchman 2008). The benthic infaunal community found near the barge dock was 

10 generally sparse and comprised relatively few taxa (EA Engineering 2007) and were generally 

11 similar to the regional community (Llansó et al. 2007). 

12 3.0 Proposed Federal Actions 

13 The proposed Federal actions are the issuance of a COL for the construction and operation of a 

14 new nuclear reactor at the Calvert Cliffs site pursuant to 10 CFR 52.97 and the decision 

15 regarding a DA permit pursuant to Section 404 of the Clean Water Act and Section 10 of the 

16 Rivers and Harbors Act. 

17 The NRC, in a final rule dated October 9, 2007 (72 FR 57416), limited the definition of 

18 “construction” to those activities that fall within its regulatory authority in 10 CFR 51.4. Many of 

19 the activities required to construct a nuclear power plant are not part of the NRC action to 

20 license the plant. Activities associated with building the plant that are not within the purview of 

21 the NRC action are grouped under the term “preconstruction.” Preconstruction activities include 

22 clearing and grading, excavating, erection of support buildings and transmission lines, and other 

23 associated activities. These preconstruction activities may take place before the application for 

24 a COL is submitted, during the staff’s review of a COL application, or after a COL is granted. 

25 Although preconstruction activities are outside the NRC’s regulatory authority, many of them are 

26 within the regulatory authority of local, State, or other Federal agencies. The distinction 

27 between construction and preconstruction is not carried forward in this BA, and they are being 

28 discussed together as construction activities for the purposes of this joint consultation. 

29 The Corps action is the decision whether to issue a permit pursuant to Section 404 of the Clean 

30 Water Act and Section 10 of the Rivers and Harbors Act for proposed structures in and under 

31 navigable waters and the discharge of dredged, excavated, and/or fill material into waters of the 

32 United States, including jurisdictional wetlands.

33 Prerequisites to construction activities include, but are not limited to, documentation of existing 

34 site conditions within the Calvert Cliffs site and acquisition of the necessary permits (e.g., COL, 

35 local building permits, a National Pollutant Discharge Elimination System (NPDES) permit, a 

36 Clean Water Act Section 404 permit, a General Stormwater Permit, and other State and local 

37 permits). After these prerequisites are completed, planned construction activities could proceed 

38 and would include all or some of all the activities identified in 10 CFR 50.10(a)(1). Following 

39 construction, no separate operating license would be required. 

Appendix F

Draft NUREG-1936 F-38 April 2010
1 Briefly, the construction and operation activities that could affect Federally protected species 

2 based on habitat affinities and life-history characteristics and the nature and spatial and 

3 temporal considerations of the activity are: 

4 Construction 

5 Dredging and modification of the existing barge slip, including a sheet-pile wall and a stone 

6 apron, on the Chesapeake Bay shoreline 

7 Installation of the cooling water intake system including new sheet pile, armor removal, 

8 armor installation, and dredging, including the fish-return system 

9 Installation of the cooling water discharge system 

10 Increased vessel traffic associated with the construction activities. 

11 Operation

12 Impingement, entrainment, and entrapment associated with the cooling water intake system 

13 Discharge plume from the cooling water system (thermal, chemical, and physical effects) 

14 Maintenance dredging of the barge slip. 

15 The construction footprint for the proposed Unit 3 and all associated facilities would cover about 

16 460 ac, including about 175 ac of previously disturbed ground. UniStar has proposed to build 

17 and operate an AREVA NP, Inc. U.S. EPR design pressurized water reactor steam electric 

18 system, which is rated at 4590 MW(t) with a net electrical output of 1562 MW(e). Unit 3 would 

19 require cooling water intake and fish-return facilities that are separate from CCNPP Units 1 and 

20 2 and would also have a separate plant access road and protected area. The proposed 

21 circulating water supply system (CWS) would be closed-cycle using a mechanical-draft cooling 

22 tower with plume abatement (UniStar 2009a). The project would affect about 5.7 ac of tidal 

23 open waters. 

24 The existing transmission system for CCNPP Units 1 and 2, which consists of two circuits, 

25 would also be used to service Unit 3. No new transmission corridors would be constructed 

26 outside the construction footprint. Operation of the transmission system is not expected to 

27 affect Federally protected species in the Chesapeake Bay. 

28 3.1 Cooling Water Intake System 

29 A 180-ft-long sheet-pile wall, embedded 15 ft into the Bay bottom, would be built to extend from 

30 the existing baffle wall for CCNPP Units 1 and 2 to the shoreline south of the present intake 

forebay to create a 9000-ft2 31 (0.21-ac) wedge-shaped pool that would become the intake 

32 embayment for the new unit (Figure 2) (UniStar 2008b). The wall would be built of steel sheet 

33 piling supported by 30-in.-diameter soldier piles placed on 10-ft centers. The new baffle wall 

34 would not have an opening that would allow the new wedge-shaped pool to communicate 

35 directly with the Bay. Therefore, Unit 3 would share the embayment now used by Units 1 and 2. 

36 A 50-ft section of shoreline armoring would be removed prior to the wall installation. The 

37 construction of the sheet-pile wall would take about 2 months. Once the wall is in place, 

Appendix F

April 2010 F-39 Draft NUREG-1936
1 

2 Figure 2. Site Plan at Unit 3 Intake Structure (UniStar 2009d) 

Appendix F

Draft NUREG-1936 F-40 April 2010
1 about 60 ft of shoreline armor within the wedge-shaped pool would be removed, and a 

2 temporary sheet-pile wall would be installed upland along the intake water pipe route. The 

3 upland sheet-pile wall would extend about 30 ft into the wedge-shaped pool to create a small 

4 area that would be dewatered to facilitate dredging of a 30-ft by 30-ft area to a depth of 25 ft 

(900 ft2 5 ; 0.02 ac). This excavation would house two 60-in.-diameter intake pipes that would 

6 extend about 20 ft channelward. The pipes would have trash racks but no screens at their 

7 openings. The intake piping would be perpendicular to the tidal flow of the Bay to minimize the 

8 component of the tidal flow parallel to the intake-area flow, reducing the potential of organisms 

9 entering the common forebay shared by the CWS and safety-related ultimate heat sink (UHS) 

10 intake structures for Unit 3. The flow velocity from the Bay into the existing intake area and the 

11 expected flow into the Unit 3 intake pipes are both less than 0.5 fps. About 80 ft of the shoreline 

12 within the pool would be armored, with the armoring extending about 10 ft from shore. The new 

13 sheet-pile wall would be armored by placing riprap on the Bay bottom extending about 75 ft from 

14 the shoreline and about 25 to 95 ft toward the channel (UniStar 2009d). The armoring would be 

15 added to the Bay bottom as a series of four overlying layers ranging from washed gravel on the 

16 bottom to large quarry rock (average about 2 tons each rock) on the top (UniStar 2009d). The 

overall thickness of the armoring would vary according to the water depth. About 4650 ft2 17 

18 (0.11 ac) of the Bay bottom would be armored (Figure 2). The temporary sheet-pile wall within 

19 the wedge-shaped pool would be removed. The construction of the intake system would take 

20 about 4 months. 

21 The two intake pipes would be placed in trenches dug on land and would extend about 500 ft 

22 south to the location of common forebay (UniStar 2009a). The common forebay would be 100 ft 

23 long by 80 ft wide and would be about 12 ft deep (UniStar 2009a). The Unit 3 CWS makeup 

24 water intake structure would be a concrete structure about 78 ft long and 55 ft wide with 

25 individual pump bays. Three 50-percent-capacity, vertical, wet-pit CWS makeup pumps would 

26 provide up to 44,000 gpm of makeup water. The Unit 3 UHS makeup water intake structure 

27 would be a concrete structure about 75 ft long and 60 ft wide with individual pump bays. Four 

28 100-percent-capacity, vertical, wet-pit UHS water makeup pumps would provide up to 3000 gpm 

29 of makeup water. Flow velocities at the CWS and UHS makeup structures would be less than 

30 0.3 fps and less than 0.1 fps, respectively. 

31 For the CWS makeup water intake structure, water would flow from the common forebay 

32 through trash racks and two traveling screens into a smaller forebay that feeds the three CWS 

33 makeup pumps. The trash bar spacing would be 3.5 in. from center to center. Debris collected 

34 by the trash racks would be collected in a debris basin for cleanout and disposal as solid waste. 

35 The traveling screens for each system would be dual-flow screens with a double-entry/center36 exit flow pattern. The screen panels would be metallic or plastic mesh with a mesh size of 

37 3/8 in. or smaller (UniStar 2009b). The screens would be mechanically rotated above the water 

38 for cleaning with a pressurized water spray. Screen wash water would be supplied by two 

39 screen wash pumps. Through-screen flow velocities would be less than 0.5 fps. For the UHS 

40 makeup intake structure, water flows from the common forebay to each makeup pump after 

41 passing through a trash rack and dual-flow screen. The screens for the UHS pumps would not 

42 be equipped with a fish-return system (UniStar 2009c). 

Appendix F

April 2010 F-41 Draft NUREG-1936
1 3.2 Fish-Return System 

2 A fish-return system similar to those for CCNPP Units 1 and 2 would be built (UniStar 2008b) for 

3 the Unit 3 CWS pumps. The final design details have not been determined. Organisms would 

4 enter the return system at the intake screens for the CWS intake structure located at the 

5 common forebay after the organisms traveled through the pipe originating at the shoreline 

6 intake about 500 ft north of the forebay. The UHS pumps would not be connected to the fish7 return system because the UHS makeup system only operates periodically or in the case of a 

8 design-basis accident (DBA) (UniStar 2009c). The return system would be located on the east 

9 (Bay) side of the Unit 3 intake forebay about midway between the CCNPP Units 1 and 2 intake 

10 forebay and the existing barge dock. The proposed fish-return outfall pipe would extend about 

11 40 ft into the Bay with end of the pipe emerging from the Bay floor but remaining below mean 

12 lower low tide level (UniStar 2009a). This design was chosen to minimize any drop at the exit 

13 point into the Chesapeake Bay (UniStar 2009a). Any bends in the pipes would be greater than 

14 90 degrees to facilitate fish passage. The walls and joints of the pipes would be smooth to 

15 reduce potential fish abrasion (UniStar 2009b). About 40 linear ft of shoreline armoring would 

16 be removed to allow installation of the return pipe. A 6-ft-deep trench extending 40 ft from shore 

17 would be dredged to house the return pipe. The trench would be about 5 ft wide at the bottom 

and about 65 ft wide at the level of the Bay floor (UniStar 2008b). An area of about 2600 ft2 18 

19 would be directly disturbed by the dredging. After the return pipe is placed in the trench, the 

20 trench would be backfilled with the dredged sand and stone material. A 10-ft by 10-ft section of 

21 the Bay bottom would be covered to a depth of 2 ft by a riprap apron. The shoreline armoring 

22 would be replaced. The existing fish-return systems for CCNPP Units 1 and 2 would not be 

23 modified. 

24 3.3 Cooling Water Discharge Structure 

25 The 30-in.-diameter cooling water discharge pipe would be placed in a 550-ft-long trench 

26 dredged in a trapezoidal form at a 5:1 side slope to prevent sloughing of the trench sides 

27 (UniStar 2008b) (Figure 3). The trench bottom would range from 3 to 6 ft wide, and the 

28 maximum width of the trench at the level of the Bay bottom would be about 70 ft. UniStar 

29 proposes to use a three-port diffuser, which would rise 3 ft above the bed of the Chesapeake 

30 Bay, located 550 ft from the shoreline. Each diffuser port would direct water out of the pipe at 

an angle of 22.5° above horizontal (Figure 3). A minimum area of about 38,500 ft2 31 (0.88 ac) of 

Bay bottom would be directly disturbed by the pipeline installation. About 7000 yd3 32 of material 

would be dredged for the pipe installation. About 5,800 yd3 33 of this material would be reused to 

backfill the trench with the remainder (about 1200 yd3 34 ) being deposited at an existing upland 

35 (non-wetland), environmentally controlled disposal area at the Lake Davies laydown area on the 

36 site. Riprap with a median diameter of 12 in., and filter fabric would be placed on top of the 

37 backfilled material to provide a minimum 4 ft cover over the pipe. The riprap would be placed 

38 within discharge pipe trench to the top of the trench at the original grade of the Bay bottom, but 

39 would not extend above the existing Bay bottom. A 2-ft-deep riprap area would be placed to 

40 extend approximately 10 ft on each side of the 40-ft-long multiport diffuser. The area of Bay 

bottom covered by this riprap is about 800 ft2 41 . 

Appendix F

Draft NUREG-1936 F-42 April 2010
1 

2 Figure 3. Details of the Proposed Unit 3 Cooling Water Discharge Outfall (UniStar 2008b) 

Appendix F

April 2010 F-43 Draft NUREG-1936
1 3.4 Barge Dock Improvements 

2 The existing barge slip for CCNPP Units 1 and 2 would be restored and extended to re-establish 

3 use during the construction of proposed Unit 3. An area about 1500 ft long by 130 ft wide 

(average width), covering about 195,000 ft2 4 (4.5 ac) of Bay bottom would be dredged to a 

5 bottom depth of 16 ft mean low water (UniStar 2008b). This would require the mechanical 

dredging of about 50,000 yd3 6 of bottom substrates. UniStar considers the removal of sediment 

from about 1065 ft of the total length, about 45,000 yd3 7 , as maintenance dredging, with the 

removal of material from the remaining 435 ft, about 5000 yd3 8 , as new dredging beyond the 

9 original dredging limits. This extension is necessary to extend the proposed channel to tie into 

10 the same depth as the existing natural depth contour of 16 ft mean low water. Prior to 

11 dredging, two existing crane piles and one mooring bollard may be removed from the channel 

12 area (UniStar 2008b) (Figure 4). Additional maintenance dredging would remove silt that has 

13 accumulated in the shoreward portion of the barge dock area during the past 30 years, altering 

14 the normal flow pattern from an existing culvert outfall. The area would be restored by installing 

15 a 12-ft by 90-ft concrete apron and a 90-ft-wide sheet-pile wall at the beach end of the area and 

16 building a 40-ft long by 40-ft wide by 2-ft deep riprap apron that would extend about 40 ft into 

the Bay, covering about 1600 ft2 17 (0.04 ac). The sheet-pile wall would be constructed of steel

18 sheet-piling supported by 30-in.-diameter soldier piles. The restoration would allow the 

19 discharge from the culvert outfall to flow directly in the Bay. The restoration is expected to take 

20 about two weeks. 

21 Once the barge dock area has been refurbished, it would be used by barges that may be as 

22 large as 200 ft long and 50 ft wide. The numbers of barges that would be used has not been 

23 specified. Typically, the barges used are about 35 ft wide. Barge drafts range from 2 ft to 11 ft, 

24 depending on the load. UniStar expects that the barge dock would be in use for about five 

25 years during the construction, but stated that although there are no specific plans for 

26 maintenance dredging, eventual replacement of major components could require dredging in 

27 the future. UniStar has requested permission from the Corps to conduct maintenance dredging 

28 for 10 years (USACE 2008). The dredged material removed from the barge slip would be used 

29 during the plant construction as sand bedding for underground pipe installation or deposited at 

30 an existing upland (non-wetland), environmentally controlled disposal area onsite that was used 

31 for previous dredge disposal. The dredged material would be characterized prior to use or 

32 disposal. 

33 4.0 Protected Estuarine and Marine Species Descriptions 

34 This section describes the life history and habitat use for Federally listed estuarine and marine 

35 species that may occur on or near the Calvert Cliffs site (Table 1). 

36 4.1 Shortnose Sturgeon (Acipenser brevirostrum) 

37 The shortnose sturgeon is a long-lived fish species belonging to the Order Acipenseriformes, 

38 which includes sturgeons and paddlefishes. The species, which is Federally endangered, 

39 occurs along the western Atlantic coast from the Saint John River, New Brunswick, to the St. 

Appendix F

Draft NUREG-1936 F-44 April 2010
1 

2 Figure 4. Proposed Restoration of Barge Slip (with existing contours) for the Construction of 

3 Proposed Unit 3 (UniStar 2008b) 

Appendix F

April 2010 F-45 Draft NUREG-1936
1 Johns River, Florida (Kynard 1997; Murdy et al. 1997), with Chesapeake Bay the center of its 

2 distribution (Kynard et al. 2009). The range of the shortnose sturgeon coincides considerably 

3 with that of the Atlantic sturgeon (Acipenser oxyrinchus), although the latter ranges to the Gulf 

4 of Mexico (Murdy et al. 1997). The NMFS recognized 19 shortnose sturgeon population 

5 segments along its range, roughly divided into northern and southern regions (NMFS 1998). 

6 The northern region includes populations from about the Chesapeake Bay and Delaware River 

7 northward, and the southern region includes populations from about the Cape Fear River, North 

8 Carolina southward. The status of shortnose sturgeon in Chesapeake Bay is discussed in 

9 Section 4.1.2 of this BA. 

10 The principal reasons for the severe declines in the abundance that led to the eventual listing of 

11 shortnose sturgeon as endangered were pollution and overfishing (NMFS 1998). Another 

12 important factor was the damming of many rivers used for spawning that restricted fish to lower13 quality habitats. The U.S. Fish and Wildlife Service (FWS) listed the shortnose sturgeon as 

14 endangered in 1967 (NMFS 1998). NMFS assumed responsibility for the species in 1974. A 

15 recovery plan was prepared in 1998 (NMFS 1998). The 19 population segments considered by 

16 NMFS were not based on morphological or genetic differences among the various segments but 

17 were linked to major rivers or estuaries along the coast and differences in life-history properties 

18 among populations (Walsh et al. 2001; Wirgin et al. 2005). They do not represent distinct 

19 population segments (DPS) as defined under the ESA. Wirgin et al. (2005) studied the 

20 mitochondrial DNA of fish from 11 of the 19 segments to examine the population structure along 

21 the entire species’ range. Wirgin et al. (2005) found that their data supported the possible 

22 existence of many genetically distinct populations of shortnose sturgeon in tributaries along the 

23 western Atlantic coast. However, these populations did not strictly segregate according to 

24 geographic region. A more recent study based on data from more sturgeons, including 

25 additional fish from the Potomac River, generally supported the population segments identified 

26 by NMFS (Wirgin et al. 2009). However, four populations, including the one found in the 

27 Chesapeake Bay, were not genetically distinct from the two closest neighboring populations. 

28 NMFS initiated a status review for the shortnose sturgeon in November 2007 to update the 

29 biological information on the status of the species and to consider if shortnose sturgeon should 

30 be identified and assessed as DPS rather than as a single unit (72 FR 67712). 

31 4.1.1 Shortnose Sturgeon Biology 

32 Shortnose sturgeon, which grow to a maximum length of 4.6 ft, is one of the smallest sturgeon 

33 species. Shortnose sturgeon are freshwater amphidromous fish, living primarily in freshwater or 

34 in low-salinity estuaries and occasionally swimming into higher salinity coastal waters to feed 

35 (Bemis and Kynard 1997; Murdy et al. 1997; NMFS 1998). Shortnose sturgeons spend most of 

36 their lives in their birth river systems, only rarely moving into marine waters (NMFS 1998). 

37 There is considerable latitudinal variation in the life-history characteristics of the species 

38 (Kynard 1997), which makes it difficult to identify specific features of sturgeons living in 

39 Chesapeake Bay. The information presented below is based primarily on northern populations. 

40 Shortnose sturgeons mature relatively late, with females maturing at about 12 to 18 years of 

41 age and males maturing at about 10 to 11 years of age at the most northern spawning location 

42 (Dadswell et al. 1984). Individuals mature much more quickly in southern locations. Individual 

43 shortnose sturgeon may not spawn every year and may go as long as 11 years between 

Appendix F

Draft NUREG-1936 F-46 April 2010
1 spawning in northern areas (Dadswell et al. 1984). Adults spawn from February to April, 

2 generally over the rocky bottoms in deeper channels of swiftly flowing rivers (Dadswell et al. 

3 1984; Murdy et al. 1997). Spawning may be strongly related to temperature (Dadswell et al. 

4 1984), although river flow conditions must be appropriate before ovulation and spawning occur 

5 (Kynard 1997). Females deposit eggs that attach to the bottom substrate and remain there for a 

6 few days (Kynard 1997). The eggs hatch into secretive, poorly swimming yolk-sac larvae that 

7 develop into feeding larvae within several days. The feeding larvae are able to move 

8 downstream but stop migrating before reaching the estuary. Growth of young-of-the-year fish is 

9 fairly rapid with young often reaching lengths of about 6 in. or more during the first season 

10 (Dadswell et al. 1984). Young-of-the-year sturgeons stay in freshwater (Kynard 1997). Young 

11 sturgeons, aged 1 to 3 years, often join adults in freshwater concentration areas that may be 

12 favorable places to feed. Adults and juveniles continue to associate in groups in estuaries and 

13 forage at the freshwater-saltwater interface (Kynard 1997). In the Chesapeake Bay, this 

14 interface, or salt front, typically occurs about 12 mi from the Susquehanna River mouth but can 

15 move several miles up or down the estuary because of changes in water flow from the river or 

16 strong up- or down-estuary wind events (North and Houde 2001; North et al. 2004). These 

17 groups at the salt front persist primarily during spring and summer, after which adults may swim 

18 to deeper waters in lower parts of estuaries to overwinter (Kynard 1997). Juvenile shortnose 

19 sturgeon feed primarily on benthic insect larvae and crustaceans, whereas the primary foods for 

20 adults are mollusks (Murdy et al. 1997; NMFS 1998). Northern adults typically stop feeding in 

21 November (Kynard 1997). 

22 One of the primary threats to shortnose sturgeon is the blocking of natal rivers by dams or other 

23 obstructions. Shortnose sturgeon cannot be fished directly but are often caught as bycatch with 

24 other targeted fisheries, especially the American shad (Alosa sapidissima) gillnet fishery 

25 (Kynard 1997). 

26 4.1.2 Shortnose Sturgeon in Chesapeake Bay 

27 The occurrence and status of the shortnose sturgeon in Chesapeake Bay are enigmatic. 

28 Historically, the shortnose sturgeon was found in the Potomac and Susquehanna Rivers and 

29 probably in other major Chesapeake Bay tributaries, although historical records apparently were 

30 based on few verified records (Dadswell et al. 1984). However, populations have been 

31 decimated by loss of critical spawning habitat primarily from damming of rivers and pollution 

32 (Murdy et al. 1997). There were few published records of shortnose sturgeon occurrence in the 

33 Bay before 1996. Baltimore Gas and Electric Company (BGE) researchers captured a 

34 shortnose sturgeon during trawl studies near the Calvert Cliffs site in 1979 (UniStar 2008b). No 

35 shortnose sturgeon occurred in the impingement samples collected at CCNPP Units 1 and 2 

36 from 1975 to 1995 (Ringger 2000). 

37 A reward program conducted by the State of Maryland for Atlantic sturgeon that were captured 

38 during commercial fishing for other species yielded 40 shortnose sturgeon, most from the upper 

39 Bay (Welsh et al. 2002). Many of these sturgeon were tagged and released. Three sturgeon 

40 tagged in Chesapeake Bay were found in the Chesapeake and Delaware Canal or in the 

41 Delaware River. 

Appendix F

April 2010 F-47 Draft NUREG-1936
1 Small pieces of fins collected from many of the captured sturgeon were used for genetic 

2 analyses. Comparison of genetic data from sturgeons collected over several river systems 

3 showed that sturgeons from Chesapeake Bay and Delaware Bay were essentially 

4 indistinguishable (Wirgin et al. 2005; Wirgin et al. 2009). Shortnose sturgeons from the 

5 Potomac River were shown to be a genetic subset of sturgeons from the larger Chesapeake 

6 Bay and Delaware River systems. One possible explanation for this extreme similarity is 

7 shortnose sturgeon may no longer reproduce in Chesapeake Bay, and the individuals sampled 

8 there were seasonal migrants from the Delaware River (Wirgin et al. 2005; Wirgin et al. 2009). 

9 If shortnose sturgeon populations that existed in Chesapeake Bay before the 20th century were 

10 genetically distinct from those in the Delaware River, this distinction may have been affected by 

11 the major land barrier separating the two that was removed with the construction of the sea12 level Chesapeake and Delaware Canal in the late 1920s. 

13 Recent studies of the shortnose sturgeon in the Potomac River showed that a reproducing, 

14 resident population may eventually be re-established in the Bay. A study from 2004 to 2007 

15 documented the movements of two female shortnose sturgeons in the Potomac River (Kynard 

16 et al. 2007). A third female was tagged after the completion of the study (FWS 2009). All three 

17 female sturgeons were egg-bearing. One female, which had late-stage eggs when first caught 

18 in 2005, had not spawned when recaptured in the spring 2006 at about river kilometer (rkm) 185 

19 near Fletcher’s Landing (Kynard et al. 2009). This female was captured again in the summer 

20 2007 and had early-stage eggs. A second female bearing late-stage eggs was caught in early 

21 spring 2006 (Kynard et al. 2009). The female that was tracked from 2005 to 2007 spent the 

22 summer-winter period in a 14.9 mi (24 km) part of the Potomac downriver of Craney Island and 

23 undertook a possible spawning migration upriver in the spring 2006. The 2006 female used a 

24 larger summer-winter range (about 48.5 mi) that extended from the capture point at rkm 63 to 

25 near Craney Island (Kynard et al. 2009). The 2005 female was tracked again in April 2009, 

26 swimming along 93-mi stretch of the river from Coles Point, Virginia (rkm 35) to Fletcher’s 

27 Landing (FWS 2009). The trip began in early April and took 11 days, during which the female 

28 reached a top speed of 2.6 km/hr. This female may live in the Potomac all year (FWS 2009). 

29 Despite the capture of egg-bearing females in the Potomac, there is no evidence yet that 

30 reproduction has been successful in the river. No shortnose sturgeon early life stages have 

31 been caught in the Potomac River despite sampling efforts designed to capture them (Kynard et 

32 al. 2009; FWS 2009). No Chesapeake Bay tributaries are known to support reproducing 

33 populations (FWS 2009). The occurrence of egg-bearing female shortnose sturgeons in the 

34 Potomac River is significant because it confirms the presence of suitable habitat for the species 

35 and suggests that a breeding population eventually may be established in the river. Kynard et 

36 al. (2009) offered that the surgeons now inhabiting the river could represent a remnant 

37 population or could be colonizers from the Delaware River because of the genetic similarity 

38 between the two fish groups. 

39 4.2 Sea Turtles 

40 Four species of sea turtles may occur in Chesapeake Bay during part of a year (Musick 1988). 

41 The two most common species are the loggerhead turtle (Caretta caretta) and Kemp’s ridley 

42 turtle (Lepidochelys kempii) (Mansfield 2006). The green turtle (Chelonia mydas) and the 

Appendix F

Draft NUREG-1936 F-48 April 2010
1 leatherback turtle (Dermochelys coriacea) also occur in the Bay (VIMS 2000). Both occur 

2 primarily in the lower Bay. Most occurrences in the Bay are larger juveniles that use estuaries 

3 as feeding habitat (Mansfield 2006). Turtles visit Chesapeake Bay primarily in the spring and 

4 summer (VIMS 2000). Abundances of sea turtles are commonly estimated by counting the 

5 number of nesting females or directly counting the number of nests in which eggs have been 

6 deposited (Broderick et al. 2006). Abundances of males are often unknown. Recent estimates 

7 of turtle occurrence in lower Chesapeake Bay have been made by using aerial surveys 

8 (Mansfield 2006). Abundances of turtles within the Bay have decreased substantially since the 

9 1980s. Spring and summer turtle abundances have declined by about 63 percent and 

10 75 percent, respectively (Mansfield 2006). Mansfield (2006) suggested that these decreases in 

11 the Bay could be occurring because of reductions in the forage base, such as blue crabs. 

12 Mansfield (2006) also studied turtles captured in pound nets located in Virginia waters at the 

13 mouth of the Potomac River, which provides a general indication of the relative commonness of 

14 the four species in the central Chesapeake Bay, closer to the Calvert Cliffs area. Loggerhead 

15 turtles, representing about 88 percent of the 436 turtles collected during the 22-year period from 

16 1980 to 2002, were the most common. Kemp’s ridley turtles accounted for about 12 percent of 

17 the turtles caught. Only one green turtle was caught, and no leatherback turtles were caught. 

18 Most of the turtles were caught between May and October. An unidentified species of sea turtle 

19 was impinged on the trash racks at the existing CCNPP facility in June 2001 (NRC 2001). 

20 Sea turtles generally show natal homing behavior in which females return to the areas of their 

21 birth to lay eggs (Bowen and Karl 2007), although the precision of the homing varies according 

22 to species life style. Genetic studies indicated species that travel great distances to forage, 

23 such as leatherback turtles, are less precise in returning to natal beaches than those that do not 

24 travel long distances, such as loggerhead turtles (Bowen and Karl 2007). 

25 All four sea turtle species face similar threats, with the primary threat being the unintentional 

26 capture by many types of fishing gear, including pound nets in Chesapeake Bay (NOAA 2008a, 

27 2008b). Additional threats include harvesting of eggs, juveniles, and adults and disturbance of 

28 nesting sites. Predators, other than humans, may also significantly affect sea turtles. The 

29 primary predators on turtle adults include several large shark species, particularly tiger sharks 

30 (Galeocerdo cuvier) (Heithaus et al. 2008). 

31 4.2.1 Loggerhead Turtle (Caretta caretta) 

32 The loggerhead turtle is a Federally and State threatened species (MDNR 2007; NOAA 2008a) 

33 that is found in temperate and tropical seas around the around the world (NOAA 2008a). In the 

34 Atlantic Ocean, loggerheads range from Argentina to Newfoundland. Loggerheads in the 

35 Northwest Atlantic nest primarily on beaches from Alabama to southern Virginia (Conant et al. 

36 2009). Eggs are laid between April and early September with hatching occurring about 2 

37 months after laying (NOAA 2008a). Hatchlings emerge from the nest, crawl to the surf, and 

38 swim away from shore for several days. Those from Northwest Atlantic rookeries eventually are 

39 caught by the Gulf Stream (McClellan and Read 2007). Juveniles eventually get transported to 

40 oceanic zones where they remain for 7 to 12 years (NOAA 2008a). These oceanic juveniles 

41 migrate to nearshore waters with estuaries, such as Chesapeake Bay, providing important 

Appendix F

April 2010 F-49 Draft NUREG-1936
1 habitat (NMFS and FWS 2007a). However, this migration to nearshore waters is often reversed 

2 with individuals moving back and forth between coastal and oceanic waters for several years 

3 (McClellan and Read 2007). Juveniles show a certain degree of homing, returning from the 

4 oceanic regions to areas often relatively close to their birth rookeries (Bowen et al. 2004). 

5 Loggerheads in the southeastern U.S. may reach a length of 36 in. and weigh as much as 

6 250 lb (NOAA 2008a). 

7 The Chesapeake Bay is used primarily by juveniles, but it is also frequented by adults in the 

8 summer. Loggerheads enter the Bay in April and May and leave with the arrival of cool waters 

9 in early to mid fall. Mitochondrial DNA analyses showed that about 64 percent of the 

10 loggerheads in the Bay were from rookeries in Florida, and the remainder were from rookeries 

11 in Georgia and South Carolina (Norrgard and Graves 1996). The Georgia and South Carolina 

12 rookeries account for only about 10 percent of the active loggerhead nesting in the southeastern 

13 U.S., and their relatively high contribution to the Chesapeake Bay’s loggerhead population 

14 suggests that the Bay is an important foraging area for juveniles (Norrgard and Graves 1996). 

15 The pound net entrapment study recorded the carapace lengths of trapped loggerhead turtles 

16 as ranging from about 18 to 45 in. (Mansfield 2006), which provides some indication of the size 

17 of loggerheads found in the Bay. 

18 Loggerheads have large heads and strong jaws that enable them to feed on hard-shelled prey. 

19 In the lower Chesapeake Bay area and coastal Virginia, loggerhead diet has shifted from 

20 invertebrates to fish since the 1980s (Seney and Musick 2007). Horseshoe crabs were a 

21 prominent prey in the 1980s, with blue crabs becoming predominant in the late 1980s and early 

22 1990s. After the mid-1990s, Atlantic menhaden (Brevoortia tyrannus) and Atlantic croaker 

23 (Micropogonias undulatus) became important prey. The changes probably resulted from 

24 declines in the invertebrate populations that forced the turtles to feed on discards or trapped 

25 fish. 

26 Concern over declining loggerhead populations had been ongoing for at least 30 years when 

27 the loggerhead was listed as Federally threatened (NMFS and FWS 1991a). Turtle abundance 

28 data away from nests are scarce, and it is generally accepted that estimates of nesting females 

29 or counting nests are reasonable guides to overall population size (NMFS and FWS 2007a). 

30 The most recent trends show significant declines in nesting females in many parts of the world, 

31 particularly in the South Florida Nesting Subpopulation, which has declined 39.5 percent since 

32 1998 (NMFS and FWS 2007a). Recent conservation activities include revision of the 1991 

33 recovery plan to address recovery of the Northwest Atlantic loggerhead population (NMFS and 

34 FWS 2008) and the completion of a status review to determine whether the western North 

35 Atlantic loggerhead population, or those in other areas, represent DPS (Conant et al. 2009). 

36 The revised recovery plan describes five recovery units that are defined by geography or 

37 political boundaries. Loggerhead turtles that occupy Chesapeake Bay originate from either of 

38 two recovery units. The Northern Recovery Unit includes breeding beaches from Georgia to 

39 Virginia, and the Peninsular Florida Recovery Unit encompasses beaches from the Georgia 

40 border to Pinellas County on Florida’s west coast. The two Recovery Units have averaged a 

41 total of about 70,000 nests per year since 1989, which accounted for about 99 percent of the 

42 Northwest Atlantic population nests. The number of nests in each Unit has decreased about 1.3 

43 percent to 1.6 percent per year since the 1980s. 

Appendix F

Draft NUREG-1936 F-50 April 2010
1 Conant et al. (2009) determined that the global loggerhead turtle population can be 

2 differentiated into nine DPS. Each DPS is discrete from all other segments and is significant to 

3 the species. One DPS, the Northwest Atlantic DPS, includes all turtles that frequent 

4 Chesapeake Bay. Conant et al (2009) concluded that the Northwest Atlantic DPS was at risk 

5 for extinction primarily because of juvenile and adult mortality as bycatch from recreational and 

6 commercial fishing. Habitat destruction, such as that from pollution, channel dredging, or 

7 climate change, may also contribute to population declines. 

8 4.2.2 Kemp’s Ridley Turtle (Lepidochelys kempii) 

9 The Kemp’s ridley turtle is a Federally and State-endangered species (MDNR 2007; NOAA 

10 2008b) that occurs along the Atlantic coast from Florida to New England and throughout the 

11 Gulf of Mexico (NOAA 2008b). About 95 percent of Kemp’s ridley turtles nest in Tamaulipas 

12 State, Mexico, although some nesting has occurred in within the United States in the Carolinas 

13 and Florida. Nesting occurs from May to July, with females laying two to three clutches. Eggs 

14 hatch within about two months, and young turtles move to offshore waters. Juveniles drift in 

15 association with the seaweed Sargassum sp. for about 2 years and return to near coastal areas 

16 as subadults. Juveniles and adults typically remain fairly close to shore during migrations, 

17 usually in waters less than 60 ft deep (Renaud and Williams 2005). Kemp’s ridley turtles are the 

18 smallest marine turtles, reaching a length of about 28 in. and a weight of 100 lbs (NOAA 2008b). 

19 Although Kemp’s ridley turtles are opportunistic feeders that typically consume prey that are 

20 locally abundant (Witzell and Schmid 2005), most probably feed on swimming crabs, 

21 supplemented with jellyfish, mollusks, other types of crabs, and fish. Juvenile turtles in Florida 

22 fed on tunicates (Molgula occidentalis) that were abundant on hard bottoms (Witzell and Schmid 

23 2005). Blue crabs and spider crabs (Libinia spp.) are the most important prey in Chesapeake 

24 Bay (Seney 2003). Abundance estimates are based on the number of nesting females. Kemp’s 

25 ridley turtles experienced severe population declines from the 1940s to the 1980s, and a 

26 recovery plan for the species was developed in 1992 (NMFS and FWS 1992a). Populations 

27 started to increase in the 1990s (NMFS and FWS 2007b). Numbers of nesting females have 

28 continued to increase in the 2000s. In 2006, about 100 nests were found in the U.S. The 

29 primary historical threat to Kemp’s ridley turtles was egg collection, but it has not been a 

30 significant issue since nesting beaches were protected in 1966 (NOAA 2008b). 

31 Kemp’s ridley turtles enter the Chesapeake Bay in spring and remain until the water cools in the 

32 fall (Musick 1988). After leaving the Bay, the turtles move offshore to the south, most likely 

33 overwintering between North Carolina and central Florida (Morreale and Standora 2005). While 

34 in the Bay, these turtles typically frequent shallower waters than loggerheads. Sizes of Kemp’s 

35 ridley turtles in the Chesapeake Bay range from about 6 to 25 in., in curved carapace length 

36 (Keinath et al. 1994), the largest size is about that of an adult. Keinath et al. (1994) estimated 

37 that about 200 to 1100 Kemp’s ridley turtles inhabit the lower Bay during the summer. There is 

38 a historical record of Kemp’s ridley turtle near the Calvert Cliffs site (Hardy 1962). The record is 

39 based on the identification of a beak from a dead turtle. Many young Kemp’s ridley turtles 

40 inhabit the Chesapeake Bay during the summer, but most of these live in the lower Bay 

41 (UniStar 2008a). 

Appendix F

April 2010 F-51 Draft NUREG-1936
1 4.2.3 Leatherback Turtle (Dermochelys coriacea) 

2 The leatherback turtle is a Federally and State endangered species (MDNR 2007; NOAA 

3 2008c) that is found worldwide in many ocean habitats. In the western Atlantic, it ranges from 

4 the Gulf of Maine to the Caribbean and is found in the Gulf of Mexico (NOAA 2008c). The 

5 leatherback turtles in the Atlantic are tentatively considered to belong to seven stocks, largely 

6 based on primary nesting sites (TEWG 2007). The primary nesting areas are in South America 

7 and West Africa, with minor sites in the Caribbean Sea and Florida. Most of the nesting in 

8 Florida occurs along the Atlantic coast from Brevard County to Palm Beach County (TEWG 

9 2007). Females may nest several times during the season. Eggs hatch about 2 months after 

10 being laid. Young turtles, about 2 in., in carapace length, quickly move offshore to pelagic 

11 habitats. Little is known about the distribution of juveniles, although they seem to occur in 

12 warmer waters (NOAA 2008c). After dispersing offshore, turtles are not usually seen again until 

13 they reach a large juvenile size of at least 59 in. carapace length and move into adult foraging 

14 areas (TEWG 2007). Adults return to nesting areas to reproduce. Leatherback turtles are the 

15 largest living reptiles with adults reaching lengths of about 6 ft and weighing as much as 1984 

16 lb. Soft-bodied animals, such as jellyfish and salps, are the primary prey consumed by 

17 leatherback turtles (NOAA 2008c). Leatherbacks undertake long distance foraging treks across 

18 the Atlantic Ocean (Ferraroli et al. 2004; Hays et al. 2006). Leatherbacks often associate with 

19 large aggregations of jellyfish (Houghton et al. 2006). Population trends are not clear. The 

20 Atlantic has a larger population than the Pacific (NOAA 2008c). There is some indication that 

21 nesting in the Caribbean and Florida has been increasing. Nesting in Florida increased about 

22 tenfold from the late 1980s to the early 2000s, with about 800 to 900 nests found recently 

23 (NMFS and FWS 2007c; TEWG 2007). A recovery plan for the Atlantic and Caribbean 

24 populations of the leatherback turtle was developed in 1992 (NMFS and FWS 1992b). 

25 4.2.4 Green Turtle (Chelonia mydas) 

26 The green turtle population occurring in the Chesapeake Bay is Federally and State-threatened 

27 (MDNR 2007; NOAA 2008d). The Florida breeding population is Federally endangered. On the 

28 U.S. Atlantic coast, the green turtle ranges from southern Florida to Massachusetts. In the 

29 United States, the major nesting area is in Florida, where nesting typically occurs from June to 

30 September with most occurring in June and July (NOAA 2008d). Females nest about every 2 

31 weeks and typically lay five clutches during the season (NOAA 2008d). The eggs hatch after 

32 about 2 months, and the young move to offshore areas where they spend several years. Older 

33 juveniles migrate to inshore areas where they mature. Adults may reach lengths of 3 ft, weigh 

34 300 to 350 lb, and are the largest of the hard-shelled sea turtles (NOAA 2008d). Adult green 

35 turtles feed primarily on plants, such as seagrasses and algae, but may also consume soft36 bodied invertebrates, such as jellyfish, sponges, and sea pens (NMFS and FWS 2007d). As 

37 with loggerhead turtles, green turtle abundance is estimated by the number of nesting females 

38 or nests with deposited eggs. Estimates have shown that green turtle populations worldwide 

39 have been declining for at least 100 years (NOAA 2008d), although six of eight nesting 

40 populations in the Atlantic Ocean, including the Florida population, have shown increases in the 

41 last few years (Broderick et al. 2006; NMFS and FWS 2007d). The numbers of green turtles 

42 nesting on Ascension Island in the South Atlantic may be about 285 percent larger than they 

43 were about 30 years ago (Broderick et al. 2006). Some green turtle populations may be 

Appendix F

Draft NUREG-1936 F-52 April 2010
1 affected by a disease, fibropapillomatosis. In Costa Rica, jaguars (Panthera onca) prey on 

2 turtles, but at a fairly low rate (Heithaus et al. 2008). A recovery plan for the Atlantic green turtle 

3 population was prepared in 1991 (NMFS and FWS 1991b). 

4 5.0 Potential Environmental Effects of the 

5 Proposed Actions 

6 This section describes the potential impacts from construction and operation of the proposed 

7 Unit 3 to Federally protected species in Chesapeake Bay. 

8 5.1 General Construction Impacts 

9 Impacts to the Federally protected species in Chesapeake Bay from construction of proposed 

10 Unit 3 would be associated mainly with the construction of new water intake and discharge 

11 systems; construction of a new fish-return system; and the refurbishing of the existing barge 

12 dock area, including dredging in Chesapeake Bay. These activities would result in temporary 

13 and permanent loss or conversion of aquatic habitat in the Chesapeake Bay. 

14 The major construction events associated with building proposed Unit 3 that would affect 

15 aquatic resources in Chesapeake Bay share certain construction activities, such as dredging, 

16 pile driving, and armoring. All work would be conducted in accordance with Federal, State, and 

17 local permits. The Federally protected species in Chesapeake Bay likely would not be 

18 adversely affected by the installation of new onsite transmission facilities for the proposed Unit 3 

19 because the facilities would be built on the uplands part of the Calvert Cliffs site. 

The total proposed project would permanently affect about 248,000 ft2 20 (5.7 ac) of tidal open 

waters. About 138,500 ft2 21 (3.2 ac) of the tidal open water impacts would be from maintenance 

dredging, and about 109,000 ft2 22 (2.5 ac) of impacts would be from new dredging. About 

52,500 ft2 23 (1.2 ac) of the new dredging would be backfilled.

24 5.1.1 Dredging and Pipeline Trenching 

25 Dredging of the Bay bottom would be done by using shore-based or barge-mounted clamshell 

26 dredges to reestablish the channel on the south side of the existing CCNPP Units 1 and 2 barge 

27 dock and to create the trench for the cooling water discharge and the fish-return outfall 

28 pipelines. Dredging or pipeline trenching constitutes a major, localized impact to the benthos. 

29 Additional Bay bottom next to the pipeline trench would be disturbed by the placement of the 

30 dredged material for later use in the backfilling of the trench. Effects of dredging for the 

31 installation of the Unit 3 intake pipes would be minimized by construction of a sheet-pile 

32 cofferdam and dewatering system. 

33 In addition to the physical removal of Bay bottom, dredging and pipeline trenching and 

34 backfilling increase the suspended sediment load in the water column. However, the surficial 

35 sediments in the area that would be dredged are primarily sandy (Section 2.0 of this BA) and 

36 likely would settle out of the water column relatively quickly. Some dredged material and water 

Appendix F

April 2010 F-53 Draft NUREG-1936
1 can be lost from the clam dredge as it is raised and deposited into the barge. The amount of 

2 material re-entering the water column as it is transferred from the barge to trucks would be 

3 small. The potential re-suspension of contaminants would not be a concern for the proposed 

4 dredging or trenching because the contaminant loads in the sediments in the barge dock area 

5 recently were shown to be very low (EA Engineering 2007). 

6 5.1.2 Pile Driving 

7 Pile driving would be used in three project areas, all involving the installation of the sheet-pile 

8 walls. The installation process involves using a vibratory hammer to install the sheet piling and 

9 a conventional pile-driving hammer to install the 30-in. soldier piles that are placed on 10-ft 

10 centers to support the sheet piling. The principal impact from this process is the generation of 

11 noise at levels that may be harmful to fish and turtles. 

12 Pile driving noise may affect fish and turtles by causing temporary hearing loss, auditory tissue 

13 damage (generally sensory hair cells of the ear), and non-auditory tissue damage (UniStar 

14 2008b). Two criteria, both measured at a standard distance of 10 m (32.8 ft) from the pile15 driving activity, are used to estimate the sound and vibration levels from pile driving that would 

16 injure fish. The peak sound-pressure level (peak pressure or peak), measured as decibels (dB) 

17 relative to reference level of one micro Pascal (dB re 1 Papeak), is the maximum excursion of 

18 pressure associated with the sound (Popper et al. 2006). Peak pressure determines the 

19 likelihood that the swim bladder and ear would be exposed to extreme mechanical stress 

20 (Popper et al. 2006). The sound exposure level (SEL), measured as dB re 1 Pa2•s, is the 

21 constant sound level of 1-second duration that would contain the same acoustic energy as the 

22 original sound. 

23 The interim criteria (Popper et al. 2006) specified a peak level of 206 dB and a cumulative SEL 

24 level of 187 dB for fish weighing 2 gm and heavier, or a cumulative SEL of 183 dB for fish lighter 

25 than 2 gm. The noise levels for the pile driving conducted during the proposed Unit 3 

26 construction were estimated by applying compilations of measurements of noise and vibration 

27 impacts associated with various methods of pile driving, types of materials, and water depth. 

28 The estimated peak and cumulative SEL values for driving 24- to 36-in. steel piles with a 

29 conventional pile-driving hammer in about 5-m (16.4-ft) water depth are about 203 to 208 dB 

30 and 177 to 180 dB, respectively. These values suggest that driving 30-in. steel piles with 

31 conventional hammers at the Calvert Cliffs site may produce sound impacts that approach or 

32 exceed the peak pressure guidance criterion of 206 dB, but would not likely exceed the 

33 minimum SEL criterion of 183 dB for fish lighter than 2 gm. Sheet-pile driving produces peak 

34 pressures ranging from 175 dB to 180 dB and cumulative SEL values ranging from 160 dB to 

35 165 dB, which are below the respective interim criteria values (UniStar 2008b). 

36 Sounds from pile driving also could affect sea turtles, but the effects are difficult to estimate. 

37 There has been little work done to determine the hearing sensitivity of sea turtles at various 

38 sound frequencies (Viada et al. 2008), and most of the inference about the potential for sound39 related injury is based on studies of turtle anatomy. There is some evidence that sea turtles 

40 initially might avoid sounds ranging from about 170 dB to 179 dB, but eventually may become 

41 habituated to the noise (Bartol and Musick 2002). 

Appendix F

Draft NUREG-1936 F-54 April 2010
1 5.1.3 Armoring 

2 The benthic substrate near key underwater structures in the project area would be armored by 

importing rocks. The largest area, about 4652 ft2 3 (0.11 ac), that would receive rock armor is 

4 next to the new sheet-pile wall that would be installed to create the intake area for Unit 3. 

5 Armoring next to the baffle wall would be added to the Bay bottom as a series of four overlying 

6 layers, ranging from washed gravel on the bottom to large quarry rock (average about 2 tons 

7 each rock) on the top (UniStar 2009d). The overall thickness of the armoring would vary 

8 according to the water depth. Armor would also be placed at the end of the fish-return system, 

9 the cooling water discharge diffuser, and the nearshore area of the barge dock. The major 

10 effect would be the conversion of the benthic habitat from a soft-bottom infaunal community to a 

11 hard-bottom epifaunal community, which eventually should colonize the rocks (Abbe 1987). 

12 The loss of soft-bottom habitat may reduce the potential forage area for benthic-feeding fish 

13 species and blue crabs. However, the area is not one of high benthic productivity, and the area 

14 that would be lost is relatively small. 

15 5.1.4 Vessel Movements 

16 Vessel use during the dredging or the installation of the in-water structures for proposed Unit 3 

17 would affect the aquatic resources of the area, particularly the benthos. The main effects from 

18 using vessels would include turbulence from propellers (prop wash), anchor cable scraping 

19 across the Bay bottom, and accidental spill of materials overboard. Vessels would be used 

20 during the installation of the cooling water discharge pipeline, during the offloading of materials 

21 from barges, and probably during the installation of the sheet-pile wall at the new intake area. 

22 The primary occurrence of vessels would be during the operation of the barge dock, which is 

23 expected to last about five years. The proposed barge docking procedures would minimize the 

24 potential impacts from prop wash (UniStar 2008b). Moving vessels could strike sea turtles. 

25 Vessel operations during construction are expected to cause short-term, localized impacts to 

26 the aquatic resources at the Calvert Cliffs site. These impacts are not expected to affect the 

27 protected species in the area of the site or the region along this coast of the Chesapeake Bay. 

28 5.2 General Operational Impacts 

29 For protected species in Chesapeake Bay, the primary concerns related to water intake and 

30 consumption are the impacts related to the relative amount of water drawn from the cooling 

31 water source, in this case the Chesapeake Bay, and the potential for organisms to be (1) 

32 entrapped within the wedge-shaped pool or common forebay; (2) impinged on the trash racks at 

33 the intake pipe openings, CWS intake, and UHS intake; (3) impinged on the travelling screens 

34 at the CWS and UHS intakes; and (4) entrainment into the cooling systems via CWS and/or 

35 UHS intakes. The intake system design for Unit 3 includes a fish-return system located at the 

36 CWS intake’s travelling screens in the common forebay but not at the UHS intake or at the 

37 intake pipe openings in the wedge-shaped pool. 

38 UniStar stated that a closed-cycle, recirculating, wet cooling system with a cooling tower would 

39 be used for Unit 3 (UniStar 2009a). The intake system for Unit 3 would incorporate protection 

40 measures that may reduce entrainment and impingement. The estimated maximum intake 

Appendix F

April 2010 F-55 Draft NUREG-1936
1 volume of 47,383 gpm for Unit 3 would not exceed the EPA 1-percent water column criterion 

2 (UniStar 2009a). Unit 3 would have a fish-return system similar to that used at existing CCNPP 

3 Units 1 and 2. Moreover, the through-screen flow velocity would be less than 0.5 ft/sec 

4 (0.15 m/sec) under the worst case scenario of minimum Chesapeake Bay level with highest 

5 makeup demand flow (UniStar 2009a). 

6 5.2.1 Entrainment 

7 The entrainment of organisms within the cooling water system at CCNPP Units 1 and 2 was 

8 studied from 1974 through 1980 (UniStar 2008a) and from March 2006 to September 2007 

9 (UniStar 2008c). The latter study included day and night sampling. Additional ichthyoplankton 

10 samples were collected just outside the existing baffle wall separating the intake area from the 

11 open waters of the Bay from April to December 2006, which allowed comparison of entrained 

12 organisms with natural populations in the Bay. 

13 No shortnose sturgeon life stages were entrained during either study nor were any caught in the 

14 samples collected outside the baffle wall in the 2006–2007 study. Because sturgeon eggs and 

15 larvae do not move from rivers into estuaries, no shortnose sturgeon life stages near the Calvert 

16 Cliffs site are small enough to be entrained by the proposed new unit. Likewise, no turtle life 

17 stage is small enough to be subject to entrainment at the proposed new unit. 

18 5.2.2 Impingement and Entrapment 

19 Impingement sampling was conducted at CCNPP Units 1 and 2 from 1975 through 1995 

20 (Ringger 2000). Ringger (2000) did not report any shortnose sturgeon or sea turtle 

21 impingement. An unidentified species of sea turtle was impinged at the trash racks at the 

22 existing CCNPP facility in June 2001 (NRC 2001). However, blue crabs (Callinectes sapidus), 

23 prey for some sea turtles, were impinged, with the greatest occurrence generally in spring, 

24 summer, or fall. Blue crab impingement generally was lower after the mid 1980s than before. 

25 The apparent difference in impingement rates before and after the mid 1980s may be related to 

26 several operational and structural modifications to the intake and fish-return systems that were 

27 made from about 1984 to 1986, partly in response to severe impingement events that occurred 

28 in 1983 (Ringger 2000). 

29 The numbers of organisms impinged were normalized to intake cooling water withdrawal flow at 

30 CCNPP Units 1 and 2 and scaled to Unit 3 flow. The combined flow of CCNPP Units 1 and 2 is 

31 about 5332 cfs, whereas the projected intake flow for proposed Unit 3 is about 96.8 cfs. 

32 Because the projected intake flow volume for Unit 3 is about 1.82 percent of that at CCNPP 

33 Units 1 and 2 and assuming that the relationship between flows is linear, the projected 

34 impingement and mortality rates at Unit 3 are correspondingly small. The average annual blue 

35 crab impingement rate predicted for Unit 3 is 11,403 crabs. However, because of the high 

36 survival rate (99.5 percent) following impingement (Ringger 2000), the estimated average 

37 annual impingement mortality rate at Unit 3 is 62 crabs. The impingement mortality estimates 

38 for blue crabs probably are somewhat conservative because the entire 21-year data set was 

39 used for the calculations regardless of apparently reduced impingement after modifications 

40 made in the mid-1980s. Also, the Unit 3 intake approach velocities within the forebay would be 

Appendix F

Draft NUREG-1936 F-56 April 2010
1 less than 0.5 ft/sec (0.15 m/sec), which would allow more crabs to avoid impingement. Unit 3 

2 would incorporate a fish-return system in the common CWS/UHS forebay that may help 

3 increase survival following impingement by returning crabs beneath the surface of the Bay. 

4 Water enters the wedge-shaped pool from the intake embayment for Units 1 and 2 by passing 

5 under a sheet-pile wall. Some protected species, particularly turtles, could enter the wedge6 shaped pool and become trapped there. Water from the wedge-shaped pool passes through 

7 fixed trash racks into the two intake pipes that carry water to a common forebay that would 

8 supply water to the CWS and UHS (Section 3.1 of this BA). Protected species could become 

9 impinged on the trash racks and would require rescue because there is no method for removing 

10 organisms from the racks. Because traveling screens and the fish-return system would be 

11 located off the common forebay, organisms able to pass through the trash racks covering the 

12 intake pipe openings would enter the common forebay and could become trapped there. There 

13 would be no mechanism to remove entrapped organisms from the common forebay other than 

14 the fish-return system associated with the CWS pumps (UniStar 2009c). Some blue crabs 

15 could become entrapped, but the number is not possible to estimate confidently. It is unlikely 

16 that any of the protected species that could occur near Calvert Cliffs would be small enough to 

17 fit through the trash racks. Therefore, entrapment in the common forebay is not expected to be 

18 a dominant concern for shortnose sturgeon and sea turtles. 

19 5.2.3 Aquatic Thermal Impacts 

20 The effluent discharge from Unit 3 would be directly into the Chesapeake Bay. CORMIX 

21 modeling showed that the expected discharge plume from proposed Unit 3 would be small and 

22 would not interact with the plume from Units 1 and 2. Abbe (1987) evaluated the potential 

23 effects of the thermal discharge from CCNPP Units 1 and 2 and concluded that the thermal 

24 discharge from CCNPP Units 1 and 2 had no important adverse impacts on fish or key 

25 invertebrate species, such as blue crabs. The Maryland Power Plant Research Program 

26 (PPRP) concluded that the effects of thermal discharges from the power plants into 

27 Chesapeake Bay habitats were localized and not considered significant (MDNR PPRP 2008). 

28 The waste heat from the Unit 3 discharge would dissipate quickly because of the small size of 

29 the thermal plume and would not affect protected species. 

30 Cold shock occurs when aquatic organisms that have been acclimated to warm water, such as 

31 fish in a power plant’s discharge canal, are exposed to a sudden temperature decrease. This 

32 sometimes occurs when power plants shut down suddenly in winter. Abbe (1987) concluded 

33 that the potential for cold shock associated with the discharge plume from CCNPP Units 1 and 2 

34 probably was not significant because the relatively small area of warmer water did not attract 

35 many fish during the winter. Cold shock is also unlikely to affect shortnose sturgeons at the Unit 

36 3 site because the discharge volume is small in comparison to the volume of the Bay (UniStar 

37 2009a). Sea turtles would not be exposed to cold shock because they do not live in the Bay 

38 during the winter. 

Appendix F

April 2010 F-57 Draft NUREG-1936
1 5.2.4 Chemical Impacts 

2 The UniStar application indicates that chemicals, such as anti-scaling compounds, corrosion 

3 inhibitors, and biocides, would be added to the CWS and the essential service water system 

4 (ESWS) (UniStar 2009a). Biofouling in the CWS would be controlled by the limited application 

5 of chlorine or bromine (UniStar 2009a). The CWS would provide about 90 percent of the 

6 effluent discharged to the Chesapeake Bay, with the desalinization plant contributing another 9 

7 percent (UniStar 2008a). UniStar provided estimated concentrations of various constituents in 

8 the waste stream based on design data. To illustrate the expected low concentrations of these 

9 constituents, UniStar compared expected concentrations of five metal contaminants (arsenic, 

10 chromium, copper, nickel, and zinc) to aquatic life chronic salt water limits specified by the State 

11 of Maryland (COMAR 2008). Predicted concentrations within the discharge from proposed Unit 

12 3 would be substantially less than the State aquatic life limits (UniStar 2008a). UniStar would 

13 calculate more precise estimates of constituent concentrations in the effluent as part of the 

14 NPDES permitting process for Unit 3. The NRC determined that the effluent discharge from 

15 CCNPP Units 1 and 2 would not significantly change the salinity gradients near the Calvert Cliffs 

16 site (NRC 2000). The addition of the relatively small discharge volume from Unit 3 would not be 

17 expected to alter this determination. 

18 UniStar expects that the NPDES permit for Unit 3 would require bioassay testing, as does the 

19 permit for CCNPP Units 1 and 2, to assess the potential toxicity of the discharge and provide for 

20 corrective action if necessary. To date, the bioassay testing performed for CCNPP Units 1 and 

21 2 has not indicated any toxicity to test organisms (UniStar 2009a). Therefore, the plume from 

22 proposed Unit 3 is not likely to be toxic to sturgeons or sea turtles. 

23 5.2.5 Physical Impacts from Discharge 

24 The NRC determined that the effluent discharge from CCNPP Units 1 and 2 would not 

25 significantly change the current patterns near the Calvert Cliffs site (NRC 2000). The addition of 

26 the relatively small discharge volume from Unit 3 would not be expected to alter this 

27 determination. The primary physical and ecological impacts from the CCNPP Units 1 and 2 

28 cooling water discharge are from sediment scour near the high-velocity discharge ports. The 

29 bottom scour associated with the discharge from CCNPP Units 1 and 2 was about 42 ac 

30 (UniStar 2008a). The sand substrate present prior to the operation of CCNPP Units 1 and 2 

31 was scoured by the discharge, leaving a hard clay substrate. The benthic community changed 

32 from one characterized by burrowing soft-bottom organisms to one dominated by fouling 

33 organisms (Abbe 1987; UniStar 2008a). 

34 The physical impacts associated with Unit 3 cooling water discharge would be limited to 

35 sediment scour of a small area. The area of Bay bottom that may be scoured would be 

36 minimized by the placement of riprap for about 10 ft on either side of the diffuser (UniStar 

2008b). The potential scour area was estimated to be 13,256 ft2 37 (0.3 ac) (UniStar 2008a). If the 

38 sediment becomes scoured near the discharge for Unit 3, a change in benthic habitat that would 

39 be similar to, but much less extensive than, that observed at the discharge for Units 1 and 2 

40 would occur. This scouring of the bottom would not adversely affect the protected species in 

41 the area. 

Appendix F

Draft NUREG-1936 F-58 April 2010
1 5.3 Effects of the Proposed Actions on Federally Protected Species 

2 This section describes the potential impacts to Federally proposed, threatened, or endangered 

3 aquatic species resulting from the construction and operation of the new unit at the Calvert Cliffs 

4 site. 

5 5.3.1 Shortnose Sturgeon 

6 The primary activities associated with the construction of a new unit at the Calvert Cliffs site that 

7 could affect the shortnose sturgeon are the installation of the intake and discharge systems. 

8 Construction of the intake would include installation of a sheet-pile baffle wall that would 

9 generate short-term noise levels sufficient to affect many fish, although the sensitivity of 

10 shortnose sturgeon to noise is not known. Baffle wall installation would occur over a relatively 

11 short time period, and sturgeons would be expected to avoid the area. 

12 Dredging to refurbish the barge dock area or to install the discharge pipeline and fish-return 

13 system could affect sturgeons by increasing the sediment loads in the water column. UniStar 

14 would use methods, such as turbidity curtains, to minimize this sedimentation. Because the 

15 area near the construction activities is not highly productive, disruption of the benthic habitats 

16 would not indirectly affect shortnose sturgeons by altering a food resource. 

17 The operational factor that poses the most risk to shortnose sturgeon is the potential for 

18 impingement on the trash racks that guard the intake pipelines. Despite the occurrence of many 

19 fish species in the impingement samples collected at CCNPP Units 1 and 2 from 1975 to 1995, 

20 no shortnose sturgeon were found (Ringger 2000). The benthic prey of juvenile and adult 

21 shortnose sturgeons likely would not be impinged. The small numbers of shortnose sturgeon in 

22 the Chesapeake Bay and their occurrence primarily in the upper Bay, coupled with the low 

23 intake velocity proposed for the new unit at Calvert Cliffs site, substantially lower the likelihood 

24 that impingement would occur. It is not likely that benthic-dwelling sturgeons would become 

25 entrapped for extended time periods within the wedge-shaped intake area for Unit 3 because 

26 the low current velocities through the intake embayment would not prevent sturgeons from 

27 swimming out of the area. Sturgeon eggs and larvae do not occur near the Calvert Cliffs site, 

28 and sturgeons that may occur there would be too large to pass through the trash racks and 

29 enter the common forebay. Therefore, shortnose sturgeons would not be entrained into the 

30 CWS or entrapped within the common forebay. 

31 5.3.2 Sea Turtles 

32 The construction and operation of a new unit at the Calvert Cliffs site would be most likely to 

33 affect the loggerhead and Kemp’s Ridley turtles. The green and leatherback turtles are 

34 relatively rare in the Bay, typically occurring in the lower Bay, and the likelihood that populations 

35 or individuals of either species would be significantly affected by the new unit is highly unlikely. 

36 The primary construction activities that would affect sea turtles entering the Bay are similar to 

37 those that would affect shortnose sturgeons. Increased vessel activity could affect sea turtles in 

38 the area, but this could be minimized by careful vessel operations. The potential effects of pile 

Appendix F

April 2010 F-59 Draft NUREG-1936
1 driving noise during the installation of the baffle wall on turtles are difficult to evaluate. There 

2 are indications that turtles would initially avoid the noise, but eventually could become 

3 habituated to it. The relatively short duration proposed for this activity would help reduce the 

4 potential that turtles would become habituated. Increased sedimentation during dredging could 

5 affect turtles, but UniStar proposes to uses methods to reduce the spread of water column 

6 sediment. 

7 As with shortnose sturgeon, the principal causes of adverse impact to sea turtles are 

8 impingement on the intake pipe trash racks and entrapment in the wedge-shaped pool. Smaller 

9 turtles could become trapped by the trash racks because their heads likely would fit between the 

10 trash rack bars. Because of the relative rarity of sea turtles in the part of the Bay near the 

11 Calvert Cliffs site, and the proposed low velocities at the intake system, the likelihood of sea 

12 turtle impingement is low. A search of the event logs maintained by the NRC revealed the 

13 occurrence of sea turtle impingement at the existing trash racks for operating Units 1 and 2 

14 (NRC 2001). The impinged species was not identified. Impingement could indirectly affect 

15 Kemp’s ridley turtles. Historical records showed large numbers of blue crabs, one of the major 

16 food items of Kemp’s ridley turtles, as being impinged by CCNPP Units 1 and 2 (Section 5.2.2), 

17 but the new Unit 3 would not add significantly to that total because of the small volume of water 

18 required for the cooling system. The potential effect on the turtles is lessened by the high rate 

19 at which the crabs survive impingement. Sea turtles could become entrapped within the wedge20 shaped pool by swimming under the sheet-pile wall separating the embayment for CCNPP Units 

21 1 and 2 from the Unit 3 wedge-shaped pool where turtles could surface and be unable to find 

22 the path back under the wall to the embayment for Units 1 and 2 and then also back to the Bay. 

23 No information could be found about such occurrences of turtle entrapment by the similarly 

24 designed baffle wall for CCNPP Units 1 and 2. Turtles would likely be too large to pass through 

25 the trash racks at the intake pipe openings and enter the common forebay. Therefore, 

26 impingement on the trash racks at the CWS and UHS intake structures would not be likely. 

27 6.0 Cumulative Effects on Federally Protected Species 

28 The NRC and the Corps review team considered potential cumulative effects on Federally 

29 protected species in conjunction with building and operating a new nuclear unit at the Calvert 

30 Cliffs site. For this analysis, past and present actions create the existing baseline conditions, 

31 and cumulative effects include the effects of future State, tribal, local, and private actions that 

32 are reasonably certain to occur in the action area considered in this biological assessment. 

33 Future Federal actions that are not related to the proposed action are not considered because 

34 they require separate consultation pursuant to Section 7 of the ESA (FWS and NMFS 1998). 

35 The future is defined as the start of construction of the proposed Unit 3 until the conclusion of 

36 decommissioning. The action area for this evaluation is the Calvert Cliffs site and the 

37 mesohaline (salinity ranges from about 5 to 19 parts per thousand) western portion of the 

38 Chesapeake Bay. The extent of the mesohaline zone in the Chesapeake Bay varies 

39 seasonally, but, at its maximum, includes the western Bay shore from near the mouth of the 

40 Rappahannock River to Baltimore (MDNR PPRP 2008; CBP 2009). 

Appendix F

Draft NUREG-1936 F-60 April 2010
1 Two future non-Federal projects were identified within the action area. Reinforcing an existing 

2 pier at the Cove Point Liquefied Natural Gas (LNG) terminal, about 3.5 mi southeast of the 

3 Calvert Cliffs site, would involve the installing 108-in.-diameter tubular steel monopile mooring 

4 dolphins, reinforcing existing and installing new breasting dolphins, installing walkways, and 

5 dredging about 30 ac of Bay bottom around the pier to a depth of about 45.0 ft mean low water 

6 (USCG and USACE 2009). Suitable dredged material would be placed in a stone-reinforced 

7 area along 2513 ft of shoreline and extending an average of 225 ft channelward to create a tidal 

8 marsh. The construction and operation of the proposed Unit 3 at the Calvert Cliffs site would 

9 not interact with reinforcing the pier at the Cove Point terminal because the effects of both 

10 projects would be relatively localized. Both are in areas of the Bay that could be avoided by 

11 protected species. Operation of the terminal would not be likely to adversely affect protected 

12 species (USCG and USACE 2009). 

13 Building and operating a new nuclear reactor on the Calvert Cliffs site could interact with a part 

14 of the proposed Mid-Atlantic Power Pathway (MAPP) project, which proposes to build a 500-kV 

15 transmission line from Possum Point, Virginia, to Salem, New Jersey (MAPP 2009a). The 

16 second part of the MAPP project would involve building an underwater crossing through the 

17 Chesapeake Bay extending from Calvert Cliffs to the Maryland eastern shore. The route could 

18 include broadband fiber optic cables (PHI 2009). Details of this part of the project are not yet 

19 available, but the installation of underwater cables could involve horizontal directional drilling 

20 from the shore into the Bay and some type of trenching to install the cable within the Bay. The 

21 schedule suggests that the crossing under the Bay is expected to be completed in 2014 (MAPP 

22 2009b). Both projects could affect benthic habitats in the same nearshore area off the Calvert 

23 Cliffs site but would not significantly affect protected species occurring in the area. 

24 CCNPP Units 1 and 2 will continue to operate during the construction and operation of proposed 

25 Unit 3. The two units have requested power uprates that will increase the generating capacity 

26 of each unit by about 1.38 percent (NRC 2009). The uprate was approved in December 2009 

27 for Unit 2 and a decision is expected by the end of summer 2010 for Unit 1 (NRC 2009). The 

28 uprates would likely result in a small increase in water withdrawn from the Bay and a small 

29 increase in the temperature of water discharged to the Bay. Neither increase would be 

30 expected to significantly add to the present effects of Units 1 and 2 on the Bay, nor the 

31 combined effects of Units 1, 2, and 3. 

32 The Calvert Cliffs site operations, other anthropogenic stressors, and climatic events could 

33 combine to adversely affect the aquatic populations of the Chesapeake Bay. Commercial and 

34 recreational fishing pressure has significantly affected aquatic resources in the Bay causing 

35 population declines for several species (Greiner and Vogt 2009). Shortnose sturgeon 

36 populations declined because of direct fishing and because the species was often bycatch for 

37 other fisheries. Sea turtles in Chesapeake Bay have been affected by entrapment within pound 

38 nets. The operation of proposed Unit 3 at the Calvert Cliffs site could also contribute to 

39 population declines by impinging or entrapping protected species, but such events are 

40 anticipated to occur rarely, if at all. Sturgeons have not been impinged at CCNPP Units 1 and 

41 2, and there is only one documented record of turtle (unidentified) impingement. 

42 A significant issue facing the Chesapeake Bay is global climate change. The buildup of 

43 greenhouse gas emissions that occurred in the 20th century has assured that some climate 

Appendix F

April 2010 F-61 Draft NUREG-1936
1 change will occur within the 21st century, even without increasing the current rates of emissions 

2 (Teng et al. 2006). The projected climate changes are predicted to affect the Chesapeake Bay 

3 primarily through increasing sea level, air and water temperatures, and changes in precipitation 

4 (Jasinski and Claggett 2009). Increased water acidity, which is a looming issue in some ocean 

5 habitats (Doney et al. 2009), is considered a less important factor for the Chesapeake Bay at 

6 present (Jasinski and Claggett 2009). Wu et al. (2009) projected that the sea level at Solomons 

7 Island, about 7.5 mi south of CCNPP, is expected to rise by about 22 to 24 in. by the end of the 

8 21st century. However, the estimate did not consider that the melting of the West Antarctic Ice 

9 Sheet could cause regional differences in sea level rise, which implies that the projection may 

10 have underestimated the rise in sea level in the Chesapeake Bay area by as much as one-third 

11 (Mitrovica et al. 2009). Najjar et al. (2009) projected that air temperatures in the Chesapeake 

12 Bay region could rise by about 5°F to 12°F by the year 2100. Because surface-water 

13 temperature is roughly related to air temperature, a similar increase in water temperature could 

14 be expected (Wood et al. 2002). Changes in rainfall are difficult to predict and model results 

15 often disagree. Most models predict, with considerable variability, that precipitation in winter 

16 and spring in the latter part of the 21st century could change an average of 3 percent over 

17 current levels (Najjar et al. 2009). One of the effects of increased precipitation is a reduction in 

18 salinity, particularly in the winter and spring (Jasinski and Claggett 2009). 

19 The interaction of the operation of the proposed Unit 3 and the predicted rise in Bay water level 

20 is difficult to assess, but it is not likely that the plant’s operations would add significantly to the 

21 potential impacts of sea-level rise (e.g., increased shoreline erosion). Similarly, the small sizes 

22 of the discharge plumes from Units 1 and 2 and proposed Unit 3 compared to the volume of 

23 water in the Chesapeake Bay suggests that the thermal discharges from all three units would 

24 not add importantly to the thermal regime in the Bay. Salinity in the Bay is predominantly 

25 related to flow from the Susquehanna River (Gibson and Najjar 2000), and the comparatively 

26 small discharges from all three units would not contribute to significant salinity changes in the 

27 Bay. 

28 The review team concludes that the construction and operation of Unit 3 on the Calvert Cliffs 

29 site would not significantly add to the cumulative effects of the identified future projects or to the 

30 existing or future anthropogenic stresses on the protected aquatic resources in the Chesapeake 

31 Bay. 

32 7.0 Conclusions 

33 This BA has evaluated the potential impacts of the construction and operation of the proposed 

34 Unit 3 at the Calvert Cliffs site on shortnose sturgeon and sea turtles near the site. The known 

35 distributions and records of those species and the potential ecological impacts of the 

36 construction and operation to the species, their habitat, and their prey have been considered. 

37 Based on this review, the NRC and the Corps conclude that the overall effects of the 

38 construction and operation of the proposed new unit at the Calvert Cliffs site would not likely 

39 adversely affect or jeopardize the continued existence of the shortnose sturgeon or loggerhead, 

40 Kemp’s ridley, green, or leatherback turtles. 

Appendix F

Draft NUREG-1936 F-62 April 2010
1 8.0 References 

2 10 CFR Part 50. Code of Federal Regulations, Title 10, Energy, Part 50, “Domestic Licensing of 

3 Production and Utilization Facilities.” 

4 10 CFR Part 51. Code of Federal Regulations, Title 10, Energy, Part 51, “Environmental 

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

6 10 CFR Part 52. Code of Federal Regulations, Title 10, Energy, Part 52, “Licenses, 

7 Certifications, and Approvals for Nuclear Power Plants.” 

8 72 FR 57416. October 9, 2007. “Limited Work Authorizations for Nuclear Power Plants.” 

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

10 72 FR 67712. November 30, 2007. “Endangered and Threatened Species; Initiation of a Status 

11 Review for Shortnose Sturgeon.” Federal Register. U.S. Department of Commerce. 

12 73 FR 8719. February 14, 2008. “UniStar Nuclear, LLC; Calvert Cliffs Partial Combined 

13 License Application; Notice of Intent to Prepare an Environmental Impact Statement and 

14 Conduct Scoping Process.” Federal Register. U.S. Nuclear Regulatory Commission. 

15 Abbe, G.R. 1987. “Thermal and Other Discharge-Related Effects on the Bay Ecosystem.” 

16 Chapter 9 in Ecological Studies in the Middle Reach of Chesapeake Bay, Calvert Cliffs. K.L. 

17 Heck Jr., ed. Springer-Verlag, New York. 

18 Bartol, S.M. and J.A. Musick. 2002. “Sensory Biology of Sea Turtles.” Chapter 3 in The 

19 Biology of Sea Turtles Volume II. P.L. Lutz, J.A. Musick, and J. Wyneken, eds. CRC Press, 

20 Boca Raton, Florida. 

21 Bemis, W.E., and B. Kynard. 1997. “Sturgeon Rivers: An Introduction to Acipenseriform 

22 Biogeography and Life History.” Environmental Biology of Fishes 48:167-183. 

23 Bowen, B.W., A.L. Bass, S.-M. Chow, M. Bostrom, K.A. Bjorndal, A.B. Bolten, T. Okuyama, 

24 B.M. Bolker, S. Eperly, E. Lacasella, D. Shaver, M. Dodd, S.R. Hopkins-Murphy, J.A. Musick, M. 

25 Swingle, K. Rankin-Baransky, W. Teas, W.N. Witzell, and P.H. Dutton. 2004. “Natal Homing in 

26 Juvenile Loggerhead Turtles (Caretta caretta).” Molecular Ecology 13:1797-3808. 

27 Bowen, B.W., and S.A. Karl. 2007. “Population Genetics and Phylogeography of Sea Turtles.” 

28 Molecular Ecology 16:4886-4907. 

29 Broderick, A.C., R. Frauenstein, F. Glen, G.C. Hays, A.L. Jackson, T. Pelembe, G.D. Ruxton, 

30 and B.J. Godley. 2006. “Are Green Turtles Globally Endangered?” Global Ecology and 

31 Biogeography 15:21-26. 

32 Buchman, M.F. 2008. NOAA Screening Quick Reference Tables (SQuiRTs). NOAA Office of 

33 Response and Restoration Report 08-1, Seattle, Washington. 

Appendix F

April 2010 F-63 Draft NUREG-1936
1 Chesapeake Bay Program (CBP). 2009. Water Quality – Maps. Accessed September 1, 2009 

2 at http://www.chesapeakebay.net/maps.aspx?menuitem=15165. 

3 Clean Water Act. 33 U.S.C. 1251, et seq. (also referred to as the Federal Water Pollution 

4 Control Act [FWPCA]). 

5 COMAR 26.08.02.03-2. 2008. “Numerical Criteria for Toxic Substances in Surface Waters.” 

6 Code of Maryland Regulations. Accessed December 5, 2008 at 

7 http://www.dsd.state.md.us/comar/26/26.08.02.03-2.htm. 

8 Conant, T.A., P.H. Dutton, T. Eguchi, S.P. Epperly, C.C. Fahy, M.H. Godfrey, S.L. MacPherson, 

9 E.E. Possardt, B.A. Schroeder, J.A. Seminoff, M.L. Snover, C.M. Upite, and B.E. Witherington. 

10 2009. Loggerhead sea turtle (Caretta caretta) 2009 Status Review under the U.S. Endangered 

11 Species Act. Report of the Loggerhead Biological Review Team to the National Marine 

12 Fisheries Service. 

13 Dadswell, M.J., B.D. Taubert, T.S. Squiers, D. Marchette, and J. Buckley. 1984. Synoposis of 

14 Biological Data on Shortnose Sturgeon, Acipenser brevirostrum LeSueur 1818. NOAA 

15 Technical Report NMFS 14, National Marine Fisheries Service, Washington, D.C. 

16 Doney, S.C., V.J. Fabry, R.A. Feely, and J.A. Kleypas. 2009. “Ocean Acidification: The Other 

17 CO2 Problem.” Annual Review of Marine Science 1:169–192. 

18 EA Engineering Science and Technology Inc. (EA Engineering). 2007. Aquatic Field Studies 

19 for UniStar Calvert Cliffs Expansion Project May 2007. Prepared for UniStar Nuclear 

20 Development, LLC by EA Engineering Science and Technology, Sparks, Maryland. Accession 

21 No. ML090690170. 

22 Endangered Species Act of 1973 (ESA). 16 U.S.C. 1531 as amended. 

23 Ferraroli, S., J.-Y. Georges, P. Gaspar, and Y. Le Maho. 2004. “Where Leatherback Turtles 

24 Meet Fisheries.” Nature 429:521-522. 

25 Gibson, J.R. and R.G. Najjar. 2000. “The response of Chesapeake Bay salinity to climate26 induced changes in streamflow.” Limnology and Oceanography 45:1764–1772. 

27 Greiner, J. and B. Vogt. 2009. Habitat and Research Activities to Protect and Restore 

28 Chesapeake Bay Living Resources and Water Quality. A Revised Report Fulfilling Section 

29 202g of Executive Order 13508. U.S. Department of the Interior and U.S. Department of 

30 Commerce. 

31 Hardy, J.D. 1962. “Comments on the Atlantic Ridley Turtle, Lepidochelys olivacea kempi, in 

32 the Chesapeake Bay.” Chesapeake Science 3(3):217-220. 

33 Hays, G.C., V.J. Hobson, J.D. Metcalfe, D. Righton, and D.W. Sims. 2006. “Flexible Foraging 

34 Movements of Leatherback Turtles Across the North Atlantic Ocean.” Ecology 87(10):2647-

35 2656. 

Appendix F

Draft NUREG-1936 F-64 April 2010
1 Heithaus, M.R., A.J. Wirsing, J.A. Thomson, and D.A. Burkholder. 2008. “A Review of Lethal 

2 and Non-Lethal Effects of Predators on Adult Marine Turtles.” Journal of Experimental Marine 

3 Biology and Ecology 356(2008):43-51. 

4 Houghton, J.D.R., T.K. Doyle, M.W. Wilson, J. Davenport, and G.C. Hays. 2006. “Jellyfish 

5 Aggregations and Leatherback Turtle Foraging Patterns in a Temperate Coastal Environment.” 

6 Ecology 87(8):1967-1972. 

7 Jasinski, P and P. Claggett. 2009. Responding to Climate Change in the Chesapeake Bay 

8 Watershed: A draft report fulfilling Section 202(d) of Executive Order 13508. Department of 

9 Commerce and Department of the Interior. 

10 Keinath, J.A., D.E. Barnard, J.A. Musick, and B.A. Bell. 1994. “Kemp’s Ridley Sea Turtles from 

11 Virginia Waters.” in Proceedings of the Fourteenth Annual Symposium on Sea Turtle Biology 

12 and Conservation. K.A. Bjorndal, A.B. Bolten, D.A. Johnson, and P.J. Eliaza, eds. NOAA 

13 Memorandum NMFS-SEFSC-351. National Oceanographic and Atmospheric Administration, 

14 Miami, Florida. 

15 Kynard, B. 1997. “Life History, Latitudinal Patterns, and Status of the Shortnose Sturgeon, 

16 Acipenser brevirostrum.” Environmental Biology of Fishes 48: 319-334. 

17 Kynard, B., M. Breece, M. Atcheson, M. Kieffer, and M. Mangold. 2007. Status of Shortnose 

18 Sturgeon in the Potomac River: Part I – Field Studies. Final Report, U.S. National Park Service, 

19 National Capital Region, Washington, D.C. 

20 Kynard, B., M. Breece, M. Atcheson, M. Kieffer, and M. Mangold. 2009. “Life History and 

21 Status of Shortnose Sturgeon (Acipenser brevirostrum) in the Potomac River.” Journal of 

22 Applied Ichthyology 25(Supplement 2):34-38. 

23 Llansó, R.J., J. Dew, and L.C. Scott. 2007. Chesapeake Bay Water Quality Monitoring 

24 Program, Long-Term Benthic Monitoring and Assessment Component, Level I Comprehensive 

25 Report, July 1984-December 2006 (Volume 2). Prepared by Versar, Inc., for MDNR, Annapolis 

26 Maryland. 

27 Mansfield, K.L. 2006. Sources of Mortality, Movements and Behavior of Sea Turtles in Virginia.

28 PhD Dissertation, College of William and Mary, Williamsburg, Virginia. 

29 Maryland Department of Natural Resources (MDNR). 2007. Rare, Threatened, and 

30 Endangered Animals of Maryland. MDNR, Wildlife and Heritage Program, Annapolis, Maryland. 

31 Maryland Department of Natural Resources (MDNR). 2009a. Fixed Station Monthly Monitoring 

32 Chesapeake Bay Mainstem – Cove Point (CB4.4). Water Temperature. Accessed October 1, 

33 2009 at http://mddnr.chesapeakebay.net/bay_cond/bay_cond.cfm?param=wt&station=CB44. 

Appendix F

April 2010 F-65 Draft NUREG-1936
1 Maryland Department of Natural Resources (MDNR). 2009b. Fixed Station Monthly Monitoring 

2 Chesapeake Bay Mainstem – Cove Point (CB4.4). Salinity. Accessed October 1, 2009 at 

3 http://mddnr.chesapeakebay.net/bay_cond/bay_cond.cfm?param=sal&station=CB44. 

4 Maryland Department of Natural Resources (MDNR). 2009c. Fixed Station Monthly Monitoring 

5 Chesapeake Bay Mainstem – Cove Point (CB4.4). Dissolved Oxygen. Accessed October 1, 

6 2009 at http://mddnr.chesapeakebay.net/bay_cond/bay_cond.cfm?param=bdo&station=CB44. 

7 Maryland Department of Natural Resources, Maryland Public Power Research Program (MDNR 

8 PPRP). 2008. Maryland Power Plants and the Environment. A Review of the Impacts of 

9 Power Plants and Transmission Lines on Maryland’s Natural Resources. Maryland Cumulative 

Environmental Impact Report — 14th 10 Edition. MDNR Publication No. 12-1142008-271, PPRP11 CEIR-14. 

12 McClellan, C.M., and A.J. Read. 2007. “Complexity and Variation in Loggerhead Sea Turtle 

13 Life History.” Biology Letters 3:592-594. 

14 Mid-Atlantic Power Pathway (MAPP). 2009a. Project Overview. Accessed June 26, 2009 at 

15 http://www.powerpathway.com/overview.html. 

16 Mid-Atlantic Power Pathway (MAPP). 2009b. Project Schedule. Accessed November 4, 2009 

17 at http://www.powerpathway.com/schedule.html. 

18 Mitrovica, J.X., N. Gomez, and P.U. Clark. 2009. “The Sea-Level Fingerprint of West Antarctic 

19 Collapse.” Science 323:753. 

20 Morreale, S.J., and E.A. Standora. 2005. “Western North Atlantic Waters: Crucial 

21 Developmental Habitat for Kemp’s Ridley and Loggerhead Sea Turtles.” Chelonian 

22 Conservation and Biology 4(4):870–880. 

23 Murdy, E.O., R.S. Birdsong, and J.A. Musick. 1997. Fishes of the Chesapeake Bay. 

24 Smithsonian Institution Press, Washington, D.C. 

25 Musick, J.A. 1988. The Sea Turtles of Virginia with Notes on Identification and Natural History. 

26 Second Rev. Ed., Education Series Number 24, Virginia Institute of Marine Science, Gloucester 

27 Point, Virginia. 

28 Najjar, R., L. Patterson, and S. Graham. 2009. “Climate simulations of major estuarine 

29 watersheds in the Mid-Atlantic region of the US.” Climatic Change 95:139-168. 

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

31 National Marine Fisheries Service (NMFS). 1998. Final Recovery Plan for the Shortnose 

32 Sturgeon (Acipenser brevirostrum). Prepared by the Shortnose Sturgeon Recovery Team for 

33 the National Marine Fisheries Service, Silver Spring, Maryland. Accession No. ML070170263. 

Appendix F

Draft NUREG-1936 F-66 April 2010
1 National Marine Fisheries Service (NMFS). 2008. Email from J. Crocker (NMFS) to H. Nash 

2 (NRC), Subject: Turtles at Calvert Cliffs, December 4, 2008. Accession No. ML100710462. 

3 National Marine Fisheries Service and U.S. Fish and Wildlife Service (NMFS and FWS). 1991a. 

4 Recovery Plan for U.S. Population of Loggerhead Turtle Caretta caretta. National Marine 

5 Fisheries Service, Washington, D.C. and U.S. Fish and Wildlife Service, Atlanta, Georgia. 

6 National Marine Fisheries Service and U.S. Fish and Wildlife Service (NMFS and FWS). 1991b. 

7 Recovery Plan for U.S. Population of Atlantic Green Turtle Chelonia mydas. National Marine 

8 Fisheries Service, Washington, D.C. and U.S. Fish and Wildlife Service, Atlanta, Georgia 

9 National Marine Fisheries Service and U.S. Fish and Wildlife Service (NMFS and FWS). 1992a. 

10 Recovery Plan for the Kemp’s Ridley Sea Turtle (Lepidochelys kempii). National Marine 

11 Fisheries Service, Washington, D.C. and U.S. Fish and Wildlife Service, Bethesda, Maryland. 

12 National Marine Fisheries Service and U.S. Fish and Wildlife Service (NMFS and FWS). 1992b. 

13 Recovery Plan for Leatherback Turtles Dermochelys coriacea in the U.S. Caribbean, Atlantic 

14 and Gulf of Mexico. National Marine Fisheries Service, Washington, D.C. and U.S. Fish and 

15 Wildlife Service, Bethesda, Maryland. 

16 National Marine Fisheries Service and U.S. Fish and Wildlife Service (NMFS and FWS). 2007a. 

17 Loggerhead Sea Turtle (Caretta caretta), 5-Year Review: Summary and Evaluation. National 

18 Marine Fisheries Service, Silver Spring, Maryland and U.S. Fish and Wildlife Service, 

19 Jacksonville, Florida. 

20 National Marine Fisheries Service and U.S. Fish and Wildlife Service (NMFS and FWS). 2007b. 

21 Kemp's Ridley Sea Turtle (Lepidochelys kempii) 5-Year Review: Summary and Evaluation. 

22 National Marine Fisheries Service, Silver Spring, Maryland and U.S. Fish and Wildlife Service, 

23 Albuquerque, New Mexico. 

24 National Marine Fisheries Service and U.S. Fish and Wildlife Service (NMFS and FWS). 2007c. 

25 Leatherback Sea Turtle (Dermochelys coriacea) 5-Year Review: Summary and Evaluation. 

26 National Marine Fisheries Service, Silver Spring, Maryland and U.S. Fish and Wildlife Service, 

27 Jacksonville, Florida. 

28 National Marine Fisheries Service and U.S. Fish and Wildlife Service (NMFS and FWS). 2007d. 

29 Green Sea Turtle (Chelonia mydas) 5-Year Review: Summary and Evaluation. National Marine 

30 Fisheries Service, Silver Spring, Maryland and U.S. Fish and Wildlife Service, Jacksonville, 

31 Florida. 

32 National Marine Fisheries Service and U.S. Fish and Wildlife Service (NMFS and FWS). 2008. 

33 Recovery Plan for the Northwest Atlantic Population of Loggerhead Turtle (Caretta caretta). 

34 Second Revision. National Marine Fisheries Service, Silver Spring, Maryland and U.S. Fish and 

35 Wildlife Service, Atlanta, Georgia. 

36 National Oceanic and Atmospheric Administration (NOAA). 2008a. Loggerhead Turtle (Caretta 

37 caretta). Accessed September 30, 2008 at 

38 http://www.nmfs.noaa.gov/pr/species/turtles/loggerhead.htm. Accession No. ML093270448. 

Appendix F

April 2010 F-67 Draft NUREG-1936
1 National Oceanic and Atmospheric Administration (NOAA). 2008b. Kemp's Ridley Turtle 

2 (Lepidochelys kempii). Accessed September 30, 2008 at 

3 http://www.nmfs.noaa.gov/pr/species/turtles/kempsridley.htm. Accession No. ML093270433. 

4 National Oceanic and Atmospheric Administration (NOAA). 2008c. Leatherback Turtle 

5 (Dermochelys coriacea). Accessed September 30, 2008 at 

6 http://www.nmfs.noaa.gov/pr/species/turtles/leatherback.htm. Accession No. ML093270442. 

7 National Oceanic and Atmospheric Administration (NOAA). 2008d. Green Turtle (Chelonia 

8 mydas). Accessed September 30, 2008 at 

9 http://www.nmfs.noaa.gov/pr/species/turtles/green.htm. Accession No. ML093270453. 

10 Norrgard, J.W, and J.E. Graves. 1996. “Determination of the Natal Origin of a Juvenile 

11 Loggerhead Turtle (Caretta caretta) population in Chesapeake Bay Using Mitochondrial DNA 

12 Analysis.” Proceedings of the International Symposium on Sea Turtle Conservation Genetics.

13 129-136. 

14 North, E.W., and E.D. Houde. 2001. “Retention of White Perch and Striped Bass Larvae: 

15 Biological-Physical Interactions in Chesapeake Bay Estuarine Turbidity Maximum.” Estuaries

16 24(5):756-769. 

17 North, E.W., S.-Y. Chao, L.R Sanford, and R.R. Hood. 2004. “The Influence of Wind and River 

18 Pulses on an Estuarine Turbidity Maximum: Numerical Studies and Field Observations in 

19 Chesapeake Bay.” Estuaries 27(1):132-146. 

20 Pepco Holdings, Inc. (PHI). 2009. Pepco Holdings, Inc. & Maryland Broadband Cooperative 

21 Plan Single Chesapeake Bay Utility Crossing. News Release March 24, 2009. 

22 Popper, A.N., T.J. Carlson, A.D. Hawkins, B.L. Southall, and R.L. Gentry. 2006. Interim Criteria 

23 for Injury of Fish Exposed to Pile Driving Operations: A White Paper. Accessed at 

24 www.wsdot.wa.gov/NR/rdonlyres/84A6313A-9297-42C9-BFA6-

25 750A691E1DB3/0/BA_PileDrivingInterimCriteria.pdf. 

26 Renaud, M.L., and J.A. Williams. 2005. “Kemp’s Ridley Sea Turtle Movements and 

27 Migrations.” Chelonian Conservation and Biology 4(4):808-816. 

28 Ringger, T.G. 2000. “Investigations of Impingement of Aquatic Organisms at the Calvert Cliffs 

29 Nuclear Power Plant, 1975-1995.” Environmental Science & Policy 3 (Supplement 1):S261-

30 S273. 

31 Rivers and Harbors Appropriation Act of 1899 (Rivers and Harbors Act). 33 U.S.C. 403 as 

32 amended. 

33 Seney, E.E. 2003. Historical Diet Analysis of Loggerhead (Caretta caretta) and Kemp’s Ridley 

34 (Lepidochelys kempi) Sea Turtles in Virginia. MS Thesis, College of William and Mary, 

35 Williamsburg, Virginia. 

Appendix F

Draft NUREG-1936 F-68 April 2010
1 Seney, E.E., and J.A. Musick. 2007. “Historical Diet Analysis of Loggerhead Sea Turtles 

2 (Caretta caretta) in Virginia.” Copeia 2007(2):478-489. 

3 Teng, H. L.E. Buja, and G.A. Meehl. 2006. “Twenty-first-century climate change commitment 

4 from a multi-model ensemble.” Geophysical Research Letters 33:L07706, 

5 doi:10.1029/2005GL024766. 

6 Turtle Expert Working Group (TEWG). 2007. An Assessment of the Leatherback Turtle 

7 Population in the Atlantic Ocean. NOAA Technical Memorandum NMFS-SEFSC-555. 

8 UniStar Nuclear Energy (UniStar). 2008a. Letter from George Vanderheyden (UniStar) to NRC 

9 dated June 12, 2008, “Subject: UniStar Nuclear Energy, NRC Docket No. 52-016, Submittal of 

10 Response to Requests for Additional Information for the Calvert Cliffs Nuclear Power Plant, Unit 

11 3 and Request for Withholding of Documents.” NRC’s Request for Additional Information dated 

12 May 13, 2008. Accession No. ML100040300. 

13 UniStar Nuclear Development, LLC (UniStar). 2008b. Letter from Greg Gibson (UniStar, Vice 

14 President, Regulatory Affairs) to U.S. Nuclear Regulatory Commission dated September 29, 

15 2008, “Subject: UniStar Nuclear Energy, NRC Docket No. 52-016, Submittal of Response 

16 Requests for Additional Information for the Calvert Cliffs Nuclear Power Plant, Unit 3 – 

17 Supplemental Aquatic RAIs.” NRC’s Request for Additional Information dated May 13, 2008. 

18 Accession No. ML082760508. 

19 UniStar Nuclear Development, LLC (UniStar). 2008c. Letter from Greg Gibson (UniStar, Vice 

20 President, Regulatory Affairs) to U.S. Nuclear Regulatory Commission dated October 31, 2008 

21 in response to NRC letter dated October 14, 2008, “Subject: UniStar Nuclear Energy, NRC 

22 Docket No. 52-016, Calvert Cliffs Nuclear Power Plant, Unit 3, Submittal of Response to 

23 Requests for Additional Information, Environmental Impact Statement (EIS) Issues.” Accession 

24 No. ML083110676. 

25 UniStar Nuclear Development, LLC (UniStar). 2009a. Calvert Cliffs Nuclear Power Plant Unit 3 

26 Combined License Application, Part 3, Environmental Report. Revision 6. UniStar, Baltimore, 

27 Maryland. Accession No. ML092880921. 

28 UniStar Nuclear Development, LLC (UniStar). 2009b. Letter from Greg Gibson (UniStar) to 

29 U.S. Nuclear Regulatory Commission dated March 5, 2009. “Subject: UniStar Nuclear Energy, 

30 NRC Docket No. 52-016, Calvert Cliffs Nuclear Power Plant, Unit 3, Environmental RAIs No. 

31 1001 through 1011.” In response to NRC’s Request for Additional Information dated February 

32 3, 2009. Accession No. ML090710146. 

33 UniStar Nuclear Development, LLC (UniStar). 2009c. Letter from Greg Gibson (UniStar) to 

34 U.S. Nuclear Regulatory Commission dated July 24, 2009. “Subject: UniStar Nuclear Energy, 

35 NRC Docket No. 52-016, Calvert Cliffs Nuclear Power Plant, Unit 3, Follow-up Responses to 

36 Environmental Report RAI NO.1 003-2, Aquatic Ecology and RAI NO.1 008-4, Ecological 

37 Impacts (Fish Return System).” In response to NRC’s Request for Additional Information dated 

38 February 3, 2009. Accession No. ML092150721. 

Appendix F

April 2010 F-69 Draft NUREG-1936
1 UniStar Nuclear Development, LLC (UniStar). 2009d. Letter from Greg Gibson (UniStar) to 

2 U.S. Nuclear Regulatory Commission In response to NRC’s Request for Additional Information 

3 dated February 3, 2009. “Subject: UniStar Nuclear Energy, NRC Docket No. 52-016, Calvert 

4 Cliffs Nuclear Power Plant, Unit 3, Follow-up Response to Requests for Additional Information 

5 Nos. 1001-14 and 1008-6.” July 29, 2009. Accession No. ML092120061. 

6 U.S. Army Corps of Engineers (USACE). 2008. Public Notice in Reply to Application Number 

7 CENAB-OP-RMS NAB-2007-01823-M05 (Calvert Cliff’s 3 Nuclear Project, LLC/Unistar Nuclear 

8 Operating Services, LLC). September 3, 2008. Accession No. ML082550288. 

9 U.S. Coast Guard and U.S. Army Corps of Engineers (USCG and USACE). 2009. Cove Point 

10 Pier Reinforcement Project Environmental Assessment. Federal Energy Regulatory 

11 Commission, Dominion Cove Point LNG, LP Docket No. CP09-60-000. 

12 U.S. Fish and Wildlife Service (FWS). 2009. Shortnose Sturgeon in the Potomac River. U.S. 

13 Fish and Wildlife Service Update. Maryland Fishery Resources Office, Annapolis, Maryland. 

14 U.S. Fish and Wildlife Service and National Marine Fisheries Service (FWS and NMFS). 1998. 

15 Endangered Species Act Consultation Handbook. Washington, D.C. 

16 U.S. Nuclear Regulatory Commission (NRC). 2000. Calvert Cliffs Nuclear Power Plant, Units 1 

17 and 2 – Renewal of Operating License. Accessed at http://www.nrc.gov/reading-rm/doc18 collections/commission/secys/2000/secy2000-0010/2000-0010scy.html. 

19 U.S. Nuclear Regulatory Commission (NRC). 2001. Calvert Cliffs Nuclear Power Plant 

20 Impingement Incidents Event Number: 38049. Available at http://www.nrc.gov/reading-rm/doc21 collections/event-status/event/2001/20010605en.html. 

22 U.S. Nuclear Regulatory Commission (NRC). 2009. Calvert Cliffs Nuclear Power Plant, Unit 

23 Nos. 1 and 2 Amendment RE: Measurement Uncertainty Recapture Power Uprate (TAC NOS. 

24 MD9554 AND MD9555). Accession No. ML091820366. 

25 Viada, S.T., R.M. Hammer, R. Racca, D. Hannay, M.J. Thompson, B.J. Balcom, N.W. Phillips. 

26 2008. “Review of potential impacts to sea turtles from underwater explosive removal of offshore 

27 structures.” Environmental Impact Assessment Review 28:267–285. 

28 Virginia Institute of Marine Science (VIMS). 2000. Help Virginia’s Sea Turtles!, Support the 

29 VIMS Sea Turtle Stranding Program Brochure. Gloucester Point, Virginia. 

30 Walsh, M.G., M.B. Bain, T. Squiers, Jr., J.R. Waldman, and I. Wirgin. 2001. “Morphological 

31 and Genetic Variation among Shortnose Sturgeon Acipenser brevirostrum from Adjacent and 

32 Distant Rivers.” Estuaries 24(1):41-48. 

33 Welsh, S.A., M.F. Manfold, J.E. Skjeveland, and A.J. Spells. 2002. “Distribution of Movement 

34 of Shortnose Sturgeon (Acipenser brevirostrum) in the Chesapeake Bay.” Estuaries 25(1):101-

35 104. 

Appendix F

Draft NUREG-1936 F-70 April 2010
1 Wicks, C., D. Jasinski, and B. Longstaff. 2007. Breath of Life: Dissolved Oxygen in 

2 Chesapeake Bay. Chesapeake EcoCheck. Available at 

3 http://www.chesapeakebay.net/dissolvedoxygen.aspx?menuitem=14654. 

4 Wirgin, I., C. Grunwald, E. Carlson, J. Stabile, D.L. Peterson, and J. Waldman. 2005. “Range5 Wide Population Structure of Shortnose Sturgeon Acipenser brevirostrum Based on Sequence 

6 Analysis of the Mitochondrial DNA Control Region.” Estuaries 28(3):406-421. 

7 Wirgin, I., C. Grunwald, J. Stabile, and J.R. Waldman. 2009. “Delineation of discrete population 

8 segments of shortnose sturgeon Acipenser brevirostrum based on mitochondrial DNA control 

9 region sequence analysis.” Conservation Genetics published online February 19, 2009. 

10 DOI:10.1007/s10592-009-9840-1. 

11 Witzell W.N., and J.R. Schmid. 2005. “Diet of Immature Kemp’s Ridley Turtles (Lepidochelys 

12 kempi) from Gullivan Bay, Ten Thousand Islands, Southwest Florida.” Bulletin of Marine 

13 Science 77(2):191-199. 

14 Wood, R.J., D.F. Boesch, and V.S. Kennedy. 2002. “Future consequences of climate change 

15 for the Chesapeake Bay Ecosystem and its fisheries.” American Fisheries Society Symposium

16 32:171-184. 

17 Wu, S-Y., R. Najjar, and J. Siewert. 2009. “Potential impacts of sea-level rise on the Mid- and 

18 Upper-Atlantic Region of the United States.” Climatic Change 95:121–138. 

Appendix F

April 2010 F-71 Draft NUREG-1936

1 Essential Fish Habitat 

2 Assessment 

3 

4 

5 National Marine Fisheries Service

6 

7 

8 Calvert Cliffs Nuclear Power Plant Unit 3 

9 Calvert County, Maryland 

10 

11 

12 U.S. Nuclear Regulatory Commission Combined License Application 

13 Docket No. 52-016 

14 

15 

16 U.S. Army Corps of Engineers Permit Application 

17 Permit Application No. NAB-2007-08123-M05 (Calvert Cliffs 3 Nuclear 

18 Project, LLC/UniStar Nuclear Operating Services, LLC) 

19 

20 

21 

22 April 2010 

23 

24 

25 

26 

27 U.S. Nuclear Regulatory Commission 

28 Rockville, Maryland 

29 

30 U.S. Army Corps of Engineers 

31 Baltimore District

Appendix F

April 2010 F-73 Draft NUREG-1936

1 1.0 Introduction 

2 The Magnuson-Stevens Fishery Conservation and Management Act of 1976 (16 U.S.C. 1801 

3 et seq.), as amended (MSFCMA), recognizes that habitat is important for the protection of 

4 healthy fisheries and established procedures to identify, conserve, and enhance essential fish 

5 habitat (EFH) for Federally managed fish and shellfish species (NEFMC 1998). EFH is defined 

6 as “those waters and substrate necessary to fish for spawning, breeding, feeding, or growth to 

7 maturity” (16 U.S.C. 1801 et seq.; NMFS 2004). Federal agencies must consult with the 

8 Secretary of Commerce on all actions, or proposed actions, authorized, funded, or undertaken 

9 by the agency that may adversely affect EFH (NMFS 2004). 

10 The U.S. Nuclear Regulatory Commission (NRC) is reviewing an application from Calvert Cliffs 

11 3 Nuclear Project, LLC and UniStar Nuclear Operating Services, LLC (applicant or UniStar) for a 

12 combined license (COL) to construct and operate a new nuclear reactor with a design-rated 

13 gross electrical output of approximately 1710 megawatts-electric (MW(e)) on the Calvert Cliffs 

14 site. The U.S. Army Corps of Engineers (USACE or Corps) is reviewing an application from 

15 UniStar for a Department of the Army (DA) Individual Permit pursuant to Section 10 of the 

16 Rivers and Harbors Appropriation Act of 1899 (33 U.S.C. 403 et seq.) (Rivers and Harbor Act) 

17 and Section 404 of the Clean Water Act (33 U.S.C. 1251 et seq.) to perform site preparation 

18 and construction activities for the proposed new unit at the Calvert Cliffs site. Currently, there 

19 are two operating nuclear reactors on the site, Calvert Cliffs Nuclear Power Plant (CCNPP) 

20 Units 1 and 2. The proposed project is to construct and operate a new unit, Unit 3, which would 

21 be located adjacent to CCNPP Units 1 and 2, to provide for additional baseload electrical 

22 generating capacity to meet the growing demand for electricity in the State of Maryland. 

23 The site is located about 60 mi south of Baltimore and 40 mi southeast of Washington, D.C. 

24 (Figure 1). It is about 10.5 mi southeast of Prince Frederick, Maryland, and 7.5 mi north of 

25 Solomons, Maryland. 

26 Pursuant to National Environmental Policy Act of 1969, as amended (NEPA), the NRC and the 

27 Corps are cooperating agencies with the NRC being the lead agency, and they are preparing an 

28 environmental impact statement (EIS) as part of the agencies’ review of the COL and DA permit 

29 applications. The Corps is cooperating with the NRC to ensure that the information presented in 

30 the EIS is adequate to fulfill the requirements of Corps regulations; the Clean Water Act Section 

31 404(b)(1) Guidelines, which contain the substantive environmental criteria used by the Corps in 

32 evaluating discharges of dredged or fill material into waters of the United States; and the Corps’ 

33 public interest review process. As required by Title 10 of the Code of Federal Regulations 

34 (CFR) Part 51.26, the NRC has published in the Federal Register a Notice of Intent (73 FR 

35 8719) to prepare an EIS and to conduct scoping. The final EIS will be issued after considering 

36 public comments on the draft EIS. The impact analysis in the EIS includes an assessment of 

37 the potential environmental impacts of the construction and operation of a new nuclear power 

38 unit at the Calvert Cliffs site and along the associated transmission line corridors, including 

39 potential impacts to the threatened and endangered species. If issued, the COL would 

40 authorize UniStar to construct and operate the new unit. The Corps will finalize its Record of 

41 Decision after issuance of the final EIS. 

Appendix F

April 2010 F-75 Draft NUREG-1936
1 

2 Figure 1. Location of the Calvert Cliffs Site, 50-mi Region (UniStar 2009a) 

3 The NRC and the Corps have prepared this EFH assessment to support their joint consultation 

4 with the National Marine Fisheries Service (NMFS) in accordance with the MSFCMA. The 

5 proposed action may adversely affect EFH in the project area. The proposed project has the 

6 potential to cause temporary and permanent adverse impacts to spawning, nursery, forage, and 

7 shelter activities and habitats. The NRC and Corps review team considered the designated 

8 EFH in the Chesapeake Bay, and this EFH assessment examines the potential impacts of the 

9 proposed actions on nine species: black sea bass (Centropristis striata), bluefish (Pomatomus 

10 saltatrix), butterfish (Peprilus triacanthus), clearnose skate (Raja eglanteria), little skate 

Appendix F

Draft NUREG-1936 F-76 April 2010
1 (Leucoraja erinacea), red drum (Sciaenops ocellatus), summer flounder (Paralichthys dentatus), 

2 windowpane flounder (Scophthalmus aquosus), and winter skate (Leucoraja ocellata). These 

3 species are described further in Section 4.0, and the impacts to them and their EFH, including 

4 their prey, are discussed in Section 5.0 of this EFH assessment. 

5 2.0 Calvert Cliffs Site Description 

6 

7 The Calvert Cliffs site is located on the Chesapeake Bay about 60 mi south of Baltimore; 40 mi 

8 southeast of Washington, D.C.; 10.5 mi southeast of Prince Frederick, Maryland; and 7.5 mi 

9 north of Solomons, Maryland (Figure 1). The site comprises about 2070 ac adjacent to 

10 Chesapeake Bay in an unincorporated area of Calvert County, Maryland. The NRC has 

11 licensed two existing nuclear generating units at the Calvert Cliffs site, CCNPP Units 1 and 2, 

12 which have a combined net electric generating capacity of approximately 1700-1780 MW(e). 

13 Units 1 and 2 use once-through cooling systems and obtain water from the Chesapeake Bay. 

14 The combined flow of CCNPP Units 1 and 2 intakes is about 5332 cubic feet per second (cfs). 

15 There are two shoreline water intake structures for the existing units that share a common 

16 forebay, and each unit has its own fish-return system. The two existing units also share a 

17 discharge pipe that enters the Chesapeake Bay north of the intake structure. South of the 

18 intake structure is a barge slip for offloading heavy replacement components. The barge slip 

19 has been used several times since 2001 to receive replacement steam generators, 

20 transformers, and vessel reactor heads, and it is likely that there would be occasional use of the 

21 facility in the future for continued operation of CCNPP Units 1 and 2, which could require future 

22 maintenance dredging (UniStar 2009b). Both existing units would remain and continue to 

23 operate and would not be affected by the proposed action. 

24 There is no submerged aquatic vegetation (SAV) within the proposed project area or near the 

25 Calvert Cliffs site (EA Engineering 2007b), and there are no habitat areas of particular concern 

26 (HAPC) within the proposed project area or near the Calvert Cliffs site. The project site is a 

27 high-energy wave area with about a 6-mi fetch across the Chesapeake Bay. The project area 

28 waterway is used throughout the year for recreational and commercial boating, fishing activities, 

29 and commercial shipping. The shoreline at the proposed project site is protected by stone 

30 revetment and bulkheads and includes some natural beach shoreline along eroding 70-ft-high 

31 cliffs. 

32 2.1 Chesapeake Bay Conditions 

33 The Chesapeake Bay is one of the largest estuary systems in the world and currently supplies 

34 cooling water for CCNPP Units 1 and 2. The Bay is very productive and is an important part of 

35 the cultural and economic fabric of the area. Much of the Chesapeake Bay, including the reach 

36 that encompasses Calvert County, is considered impaired, primarily because of low dissolved 

37 oxygen (DO) and increased nutrients and sedimentation from human activities. The 

38 Chesapeake Bay Program (CBP) oversees monitoring at selected locations throughout the Bay 

39 and has developed average seasonal conditions from 1985 to 2008. One station, known as 

40 CB4.4, is in the middle of the Bay, east of the Calvert Cliffs site. The average monthly surface 

41 water temperature at this location has ranged from about 38°F (February) to about 81°F (July, 

Appendix F

April 2010 F-77 Draft NUREG-1936
1 August) (MDNR 2009a). The average monthly surface water salinity at station CB4.4 is typically 

2 lowest in late spring, ranging from about 10 to 11 ppt (April through June), and highest in late 

3 fall, ranging from about 15 to 16 ppt (September through November) (MDNR 2009b). Average 

4 monthly DO concentrations at station CB4.4 have ranged from about 0.3–0.4 mg/L (July; 

5 August) to 9.0–10.0 mg/L (January through March) (MDNR 2009c). Average June through 

6 September DO concentrations have been hypoxic (less than 2.0 mg/L) (Wicks et al. 2007). The 

7 minimum DO concentrations during those months occasionally may be anoxic (less than 

8 0.2 mg/L). 

9 Water depths near the Calvert Cliffs site are generally less than 30 ft (EA Engineering 2007a). 

10 Sediments near the CCNPP barge dock area primarily are composed of sand (94 to 96 percent) 

11 and gravel (2 to 5 percent) with a small percentage of clay (EA Engineering 2007a). Total 

12 organic carbon (TOC) in the sediments ranged from about 2.4 to 3.1 percent. The sediment 

13 type sampled near the barge area was typical for the general region. The two stations located 

14 just north of the Calvert Cliffs site that have been sampled under the Maryland Department of 

15 Natural Resources (Maryland DNR) water quality monitoring program are also very sandy with a 

16 very small silt/clay fraction (Llansó et al. 2007). However, the TOC content of the CCNPP 

17 sediments was much higher than that of the two Maryland DNR stations (<1 percent each). 

18 Most organic compounds analyzed in the CCNPP sediments were reported as not detected (EA 

19 Engineering 2007a). The few organic compounds that were detected in the sediments occurred 

20 at concentrations less than the respective method detection limits. Of the seven metal 

21 compounds analyzed, six occurred at levels greater than the method detection limits, but all 

22 were substantially less than their respective threshold effects levels (the concentration below 

23 which effects are expected to be rare) (Buchman 2008). 

24 The benthic infaunal community found near the barge dock was generally sparse and 

25 composed of relatively few taxa. Infaunal abundance varied from 32 to 85 individuals per 

0.05 m2

 samples (about 640 to 1700 individuals per m2 26 ) (EA Engineering 2007a). These 

27 samples contained from 9 to 13 species. The abundances of infauna inhabiting the CCNPP 

28 sediments were generally similar to those reported for the two Maryland DNR stations sampled 

29 in summer 2006 (Llansó et al. 2007). However, species numbers at the CCNPP stations were 

30 slightly greater than those for the Maryland DNR stations. The infaunal community at the two 

31 CCNPP stations near the site of the proposed cooling water discharge pipe primarily was 

32 composed of the small clam Gemma gemma and polychaete worms, such as Streblospio 

33 benedicti and Glycinde solitaria. The small clam was not found at the station south of the barge 

34 dock near the area proposed to be dredged. The infaunal community there consisted 

35 predominantly of polychaete worms, such as S. benedicti. The general infaunal community 

36 composition at the CCNPP stations was similar to those at the two Maryland DNR stations. 

37 Gemma gemma was predominant at both Maryland DNR stations in summer 2006. Polychaete 

38 worms, such as S. benedicti, were common. Another small clam, Mulinia lateralis, was common 

39 at the Maryland DNR stations, but was not common at the CCNPP stations. 

Appendix F

Draft NUREG-1936 F-78 April 2010
1 3.0 Proposed Federal Actions 

2 The proposed Federal actions are (1) issuance of a COL for the construction and operation of a 

3 new nuclear reactor at the Calvert Cliffs site pursuant to 10 CFR 52.97 and (2) a decision 

4 regarding a DA Individual Permit pursuant to Section 404 of the Clean Water Act and Section 10 

5 of the Rivers and Harbors Act. 

6 The NRC, in a final rule dated October 9, 2007 (72 FR 57416), limited the definition of 

7 “construction” to those activities that fall within its regulatory authority, as written in 10 CFR 

8 51.4. Many of the activities required to construct a nuclear power plant are not part of the NRC 

9 action to license the plant. Activities associated with building the plant that are not within the 

10 purview of the NRC action are grouped under the term “preconstruction.” Preconstruction 

11 activities include clearing and grading, excavating, erection of support buildings and 

12 transmission lines, and other associated activities. These preconstruction activities may take 

13 place before the application for a COL is submitted, during the staff’s review of a COL 

14 application, or after a COL is granted. Although preconstruction activities are outside the NRC’s 

15 regulatory authority, many of them are within the regulatory authority of local, State, or other 

16 Federal agencies. This EFH assessment does not differentiate between construction and 

17 preconstruction, and they are being discussed together as construction activities. 

18 The Corps action is the decision whether to issue a permit pursuant to Section 404 of the Clean 

19 Water Act and Section 10 of the Rivers and Harbors Act for proposed structures in and under 

20 navigable waters and the discharge of dredged, excavated, and/or fill material into waters of the 

21 United States, including jurisdictional wetlands.

22 Prerequisites to construction activities include, but are not limited to, documentation of existing 

23 site conditions within the Calvert Cliffs site and acquisition of the necessary permits (e.g., COL, 

24 local building permits, a National Pollutant Discharge Elimination System permit, a Clean Water 

25 Act Section 404 permit, a General Stormwater permit, and other State and local permits). After 

26 these prerequisites are completed, planned construction activities could proceed and would 

27 include all or some of all the activities pursuant to 10 CFR 50.10(a)(1), although no separate 

28 operating license would be required. Briefly, the construction and operation activities that could 

29 affect Federally managed estuarine and marine species based on habitat affinities and life30 history characteristics and the nature and spatial and temporal considerations of the activity are: 

31 Construction 

32 Dredging and modification of the existing barge slip, including a sheet-pile wall and a stone 

33 apron, on the Chesapeake Bay shoreline 

34 Installation of the cooling water intake system including new sheet pile, armor removal, 

35 armor installation, dredging, and the fish-return system 

36 Installation of the cooling water discharge system 

37 Increased vessel traffic associated with the construction activities. 

38 Operation

Appendix F

April 2010 F-79 Draft NUREG-1936
1 Impingement, entrainment, and entrapment associated with the cooling water intake system 

2 Discharge plume from the cooling water system (thermal, chemical, and physical effects) 

3 Maintenance dredging of barge slip. 

4 The construction footprint for the proposed Unit 3 would cover about 460 ac, including about 

5 175 ac of previously disturbed ground. UniStar has proposed to build and operate an AREVA 

6 NP, Inc., U.S. EPR design pressurized water reactor steam electric system, which is rated at 

7 4590 MW(t) with a net electrical output of 1562 MW(e). Unit 3 would require cooling water 

8 intake and fish-return facilities that are separate from CCNPP Units 1 and 2 and would also 

9 have a separate plant access road and protected area. The proposed circulating water supply 

10 system (CWS) would be closed-cycle using a mechanical-draft cooling tower with plume 

abatement (UniStar 2009a). The proposed project would affect about 5.7 ac (248,000 ft2 11 ) of 

12 tidal open waters and would affect intertidal, subtidal, and water-column zones within the 

13 proposed project area. The existing waterway depths within the proposed work area range from 

14 about 0.0 to 16.0 ft mean low water. 

15 The existing transmission system for CCNPP Units 1 and 2, which consists of two circuits, 

16 would also be used to service the proposed Unit 3. No new transmission corridors would be 

17 constructed outside the construction footprint. Operation of the transmission system is not 

18 expected to affect Federally managed estuarine or marine species in the Chesapeake Bay. 

19 3.1 Cooling Water Intake System 

20 A 180-ft-long sheet-pile wall, embedded 15 ft into the Bay bottom, would be built to extend from 

21 the existing baffle wall for CCNPP Units 1 and 2 to the shoreline south of the present intake 

forebay to create a 9000-ft2 22 (0.21-ac) wedge-shaped pool that would be the intake embayment 

23 for the new unit (Figure 2). The wall would be built of steel sheet piling supported by 30-in.-

24 diameter soldier piles placed on 10-ft centers. The new baffle wall would not have an opening 

25 that would allow the new wedge-shaped pool to communicate directly with the Bay. Therefore, 

26 Unit 3 would share the embayment now used by CCNPP Units 1 and 2. A 50-ft section of 

27 shoreline armoring would be removed prior to the wall installation. The construction of the 

28 sheet-pile wall would take about 2 months. Once the wall is in place, about 60 ft of shoreline 

29 armor within the wedge-shaped pool would be removed, and a temporary sheet-pile wall would 

30 be installed upland along the intake water pipe route. The upland sheet-pile wall would extend 

31 about 30 ft into the wedge-shaped pool to create a small area that would be dewatered to 

32 facilitate dredging of a 30-ft by 30-ft area to a depth of 25 ft. This excavation would house two 

33 60-in.-diameter intake pipes that would extend about 20 ft channelward. The pipes would have 

34 trash racks but no screens at their openings. The trash bar spacing is expected to be 3.5 in. 

35 from center to center. Debris collected by the trash racks would be collected in a debris basin 

36 for cleanout and disposal as solid waste. The expected flow into the Unit 3 intake pipes is 

Appendix F

Draft NUREG-1936 F-80 April 2010
1 

2 Figure 2. Site Plan at the Unit 3 Intake Structure (UniStar 2009d) 

Appendix F

April 2010 F-81 Draft NUREG-1936
1 less than 0.5 fps. About 80 ft of the shoreline within the pool would be armored, with the 

2 armoring extending about 10 ft from shore. The new sheet-pile wall would be armored by 

3 placing riprap on the Bay bottom, extending about 75 ft from the shoreline and about 25 to 95 ft 

4 toward the channel (UniStar 2009d). The armoring would be added to the Bay bottom as a 

5 series of four overlying layers, ranging from washed gravel on the bottom to large quarry rock 

6 (average about 2 tons each rock) on the top (UniStar 2009d). The overall thickness of the 

armoring would vary according to the water depth. About 4652 ft2 7 (0.11 ac) of the Bay bottom 

8 would be armored (Figure 2). The temporary sheet-pile wall within the wedge-shaped pool 

9 would be removed. The construction of the intake system would take about 4 months. 

10 The two intake pipes would be placed in trenches dug on land and would extend about 500 ft 

11 south to the location of common forebay for the Unit 3 CWS and ultimate heat sink (UHS) 

12 makeup water intake structures (UniStar 2009a). The common forebay would be 100 ft long by 

13 80 ft wide and would be about 12 ft deep (UniStar 2009a). The Unit 3 CWS makeup water 

14 intake structure would be a concrete structure about 78 ft long and 55 ft wide with individual 

15 pump bays. Three 50-percent capacity, vertical, wet-pit CWS makeup pumps would provide up 

16 to 44,000 gpm of makeup water. The Unit 3 UHS makeup water intake structure would be a 

17 concrete structure about 75 ft long and 60 ft wide with individual pump bays. Four 100-percent 

18 capacity, vertical, wet-pit UHS water makeup pumps would provide up to 3000 gpm of makeup 

19 water. Flow velocities at the CWS and UHS makeup structures would be less than 0.3 fps and 

20 less than 0.1 fps, respectively. 

21 For the CWS makeup water intake structure, water would flow from the common forebay 

22 through trash racks and two traveling screens and trash racks into a smaller forebay that feeds 

23 the three CWS makeup pumps. The traveling screens for each system would be dual-flow 

24 screens with a double-entry/center-exit flow pattern. The screen panels would be metallic or 

25 plastic mesh with a mesh size of 3/8 in. or smaller (UniStar 2009b). The screens would be 

26 mechanically rotated above the water for cleaning with a pressurized water spray. Screen wash 

27 water would be supplied by two screen wash pumps. Through-screen flow velocities would be 

28 less than 0.5 fps. For the UHS makeup intake structure, water flows from the common forebay 

29 directly to each makeup pump after passing through trash racks and a dual-flow screen. The 

30 screens for the UHS pumps would not be equipped with a fish-return system (UniStar 2009c). 

31 3.2 Fish-Return System 

32 A fish-return system similar to those for CCNPP Units 1 and 2 would be built (UniStar 2009a) for 

33 the CWS pumps. The final design details have not been determined. Organisms would enter 

34 the return system at the intake screens for the CWS intake structure located at the common 

35 forebay after the organisms traveled through the pipe originating at the shoreline intake about 

36 500 ft north of the forebay. The UHS pumps would not be connected to the fish-return system 

37 because the UHS makeup system only operates periodically or in the case of a design-based 

38 accident (DBA) (UniStar 2009c). The return system would be located on the east (Bay) side of 

39 the Unit 3 intake forebay about midway between the CCNPP Units 1 and 2 intake embayment 

40 and the existing barge dock. The proposed 18-in.-diameter high-density polyethylene fish41 return outfall pipe would extend about 40 ft into the Bay with end of the pipe emerging from the 

42 Bay floor, but remaining below mean lower low tide level (UniStar 2009a). This design was 

Appendix F

Draft NUREG-1936 F-82 April 2010
1 chosen to minimize any drop at the exit point to facilitate the returning of the fish to the 

2 Chesapeake Bay (UniStar 2009a). Any bends in the pipes would be greater than 90 degrees to 

3 facilitate fish passage. The pipes would be smooth-walled and smooth-jointed to reduce 

4 potential fish abrasion (UniStar 2009b). About 40 linear ft of shoreline armoring would be 

5 removed to allow installation of the return pipe. A 6-ft-deep trench extending 40 ft from shore 

6 would be dredged to house the return pipe. The trench would be about 5 ft wide at the bottom 

and about 65 ft wide at the level of the Bay floor (Figure 3). An area of about 2600 ft2 7 would be 

8 directly disturbed by the dredging. After the return pipe is placed in the trench, the trench would 

9 be backfilled with the dredged sand and stone material. A 10-ft by 10-ft section of the Bay 

10 bottom would be covered to a depth of 2 ft by a riprap apron. The shoreline armoring would be 

11 replaced. The existing fish-return system for CCNPP Units 1 and 2 would not be modified. 

12 3.3 Cooling Water Discharge Structure 

13 The 30-in.-diameter high-density polyethylene cooling water discharge pipe would be placed in 

14 a 550-ft-long trench dredged in a trapezoidal form at a 5:1 side slope to prevent sloughing of the 

15 trench sides (UniStar 2008b). The trench bottom would range from 3 to 6 ft wide, and the 

16 maximum width of the trench at the level of the Bay bottom would be about 70 ft. UniStar 

17 proposes to use a three-port diffuser, which, at 550 ft from the shoreline, would rise 3 ft above 

18 the bed of the Chesapeake Bay. Each diffuser port would direct water out of the pipe at an 

angle of 22.5 degrees above horizontal (Figure 4). A minimum area of about 38,500 ft2 19 (0.88 

ac) of Bay bottom would be directly disturbed by the pipeline installation. About 7000 yd3 20 of 

material would be dredged for the pipe installation. About 5800 yd3 21 of this material would be 

reused as trench fill with the remainder (about 1200 yd3 22 ) being deposited at an existing upland 

23 (non-wetland), environmentally controlled disposal area at the Lake Davies laydown area on the 

24 site. Riprap with a median diameter of 12 in. and filter fabric would be placed on top of the 

25 backfilled material to provide a minimum 4 ft cover over the pipe. The riprap would be placed 

26 within discharge pipe trench to the top of the trench at the original grade of the Bay bottom, but 

27 would not extend above the existing Bay bottom. A 2-ft-deep riprap area would be placed to 

28 extend approximately 10 ft on each side of the 40-ft-long multiport diffuser. The area of Bay 

bottom covered by this riprap is about 800 ft2 29 . 

30 3.4 Barge Dock Improvements 

31 The existing barge slip for CCNPP Units 1 and 2 would be restored and extended to reestablish 

32 use during the construction of Unit 3. An area about 1500 ft long by 130 ft wide (average width), 

covering about 195,000 ft2 33 (4.5 ac) of Bay bottom would be dredged to a bottom depth of 16 ft 

34 mean low water (UniStar 2008b). This would require the mechanical dredging of about 

50,000 yd3 35 of bottom substrates. UniStar considers the removal of sediment from about 1065 ft 

of the total length (about 45,000 yd3 36 ) as maintenance dredging, with the removal of material 

from the remaining 435 ft (about 5000 yd3 37 ) as new dredging beyond the original dredging limits 

38 of 16 ft mean low water. This extension is necessary to extend the proposed channel to tie 

39 into the same depth as the existing natural depth contour. Prior to dredging, two existing crane 

40 piles and one mooring bollard may be removed from the channel area (UniStar 2008b) (Figure 5 

41 and Figure 6). Additional maintenance dredging would remove silt that has accumulated in the 

Appendix F

April 2010 F-83 Draft NUREG-1936
1 

2 Figure 3. Fish-return System Discharge Piping for the Unit 3 Intake Structure (UniStar 2008c) 

3 

Appendix F

Draft NUREG-1936 F-84 April 2010
1 

2 Figure 4. Details of the Unit 3 Cooling Water Discharge Outfall (UniStar 2008c)

Appendix F

April 2010 F-85 Draft NUREG-1936
1 

2 Figure 5. Proposed Restoration of Barge Slip (with existing contours) for the Construction of 

3 Unit 3 (UniStar 2008b) 

Appendix F

Draft NUREG-1936 F-86 April 2010
1 

2 Figure 6. Proposed Modifications at the Existing Barge Unloading Facility for the Construction 

3 of Unit 3 (UniStar 2008b) 

Appendix F

April 2010 F-87 Draft NUREG-1936
1 shoreward portion of the barge dock area during the past 30 years, altering the normal flow 

2 pattern from an existing culvert outfall. The area would be restored by installing a 12 ft by 90 ft 

3 concrete apron and a 90-ft-wide sheet-pile wall at the beach end of the area and building a 40-ft 

4 long by 40-ft wide by 2-ft deep riprap apron that would extend about 40 ft into the Bay covering 

about 1600 ft2 5 (0.04 ac). The sheet-pile wall would be constructed of steel sheet piling 

6 supported by 30-in.-diameter soldier piles. The restoration would allow the discharge from the 

7 culvert outfall to flow directly in the Bay. The restoration is expected to take about 2 weeks. 

8 Once the barge dock area has been refurbished, it would be used by barges that may be as 

9 large as 200 ft long and 50 ft wide. Typically, the barges used are about 35 ft wide. Barge 

10 drafts range from 2 ft to 11 ft, depending on the load. UniStar expects that the barge dock 

11 would be in use for about 5 years during the construction but stated that although there are no 

12 specific plans for maintenance dredging, eventual replacement of major components could 

13 require dredging in the future. UniStar has requested permission from the Corps to conduct 

14 maintenance dredging for 10 years (USACE 2008). The dredged material removed from the 

15 barge slip would be used during the plant construction as sand bedding for underground pipe 

16 installation or deposited at Lake Davies, an existing upland (non-wetland) environmentally 

17 controlled disposal area on site that was also used for previous dredge disposal. The dredged 

18 material would be characterized prior to use or disposal. 

19 4.0 Essential Fish Habitat Species Descriptions 

20 The proposed new unit at the Calvert Cliffs site is located in an area that is designated as EFH 

21 for species managed by the Mid-Atlantic Fishery Management Council. The NRC and the 

22 Corps conducted an evaluation by identifying and considering all designated EFH that occurs 

23 near the Calvert Cliffs site. The Maryland portion of the Chesapeake Bay was selected as the 

24 primary basis for the evaluation. The area of evaluation was further narrowed to the 

25 Chesapeake mainstem, the area most likely applicable to the Calvert Cliffs site (NMFS 2008a). 

26 The Patuxent River section of the Chesapeake Bay was also checked but did not add species to 

27 the list of those to be evaluated (NMFS 2008b). Only species having EFH within the mixing 

28 water/brackish salinity zone (0.5 to 25 parts per thousand) of the Bay or the Patuxent River 

29 were included in the final assessment. A separate list of skate habitats was checked for species 

30 with EFH in the Chesapeake Bay (NMFS 2009a). 

31 The original list of candidates for EFH evaluation included 12 species (Table 1). However, the 

32 NMFS informed UniStar that the EFH designations for cobia, king mackerel, and Spanish 

33 mackerel were very broad and those species did not need to be considered further (UniStar 

34 2008b). Therefore, final EFH evaluation list includes nine species. 

Appendix F

Draft NUREG-1936 F-88 April 2010
1 Table 1. Species List of EFH Designations by Lifestage near Proposed CCNPP Unit 3

Species Eggs Larvae Juveniles Adults 

black sea bass (Centropristis striata) X X 

bluefish (Pomatomus saltatrix) X X 

butterfish (Peprilus triacanthus) X X X X 

clearnose skate (Raja eglanteria) X X 

little skate (Leucoraja erinacea) X X 

red drum (Sciaenops ocellatus) X X X X 

summer flounder (Paralichthys dentatus) X X X 

windowpane flounder (Scophthalmus aquosus) X X 

winter skate (Leucoraja ocellata) X X 

cobia (Rachycentron canadum)

(a) X X X X 

king mackerel (Scomberomorus cavalla)

(a) X X X X 

Spanish mackerel (Scomberomorus maculatus)

(a) X X X X 

Sources: NMFS 2008a, NMFS 2008b, NMFS 2009a, b, c, d, e, f and UniStar 2008b. 

(a) Not considered further because of very broad EFH designations. 

2 4.1 Black Sea Bass (Centropristis striata) 

3 The black sea bass range along the east coast of North America from Nova Scotia to Florida 

4 (Drohan et al. 2007). The species occurs in the Chesapeake Bay from spring to late fall and is 

5 common in the mid and lower Bay (Murdy et al. 1997). Black sea bass migrate offshore in 

6 winter. Adults are typically found near structured habitats, such as shipwrecks, pilings, rocky 

7 areas and jetties, and shellfish beds (Murdy et al. 1997; Drohan et al. 2007). Some juveniles 

8 may overwinter in deeper waters in the Bay during mild years (Drohan et al. 2007). Juveniles in 

9 the Chesapeake Bay are closely associated with vegetated areas. Black sea bass are visual 

10 predators that feed during the day. Juveniles feed primarily on shrimp and small crustaceans, 

11 whereas adults eat mainly crabs, clams, and fish. Black sea bass are hermaphroditic with 

12 individuals maturing first as females. Most fish smaller than 7.5 in. long are females; larger fish 

13 are males (Drohan et al. 2007). Black sea bass may live as long as 20 years and reach a 

14 length of about 24 in. (Murdy et al. 1997). Spawning occurs in late spring to early fall over 

15 nearshore continental shelf habitats near large estuaries (Drohan et al. 2007). Development 

16 from egg through larval stages occurs in offshore water with juveniles (1.2 to 2.4 in. in length) 

17 migrating into estuaries during summer. There is a small commercial fishery for black sea bass 

18 in the Chesapeake Bay, and there is a popular sport fishery for the species (Murdy et al. 2007). 

19 Three stocks of black sea bass are used to manage the fishery. The mid-Atlantic stock includes 

20 the Chesapeake Bay. Recent year classes within this stock have shown strong growth in 

21 contrast to that for the south Atlantic stock (Drohan et al. 2007). The black sea bass 

22 recreational fishery has declined recently, although this may have resulted from increased 

23 minimum size limits (Kerns 2006). 

24 EFH that includes Chesapeake Bay has been designated for black sea bass juveniles and 

25 adults. Inshore EFH for juveniles includes estuaries where black sea bass are identified as 

26 being common, abundant, or highly abundant for the mixing (0.5 to 25.0 ppt) and seawater 

27 (greater than 25 ppt) salinity zones. In general, juvenile black sea bass are found in waters 

Appendix F

April 2010 F-89 Draft NUREG-1936
1 warmer than 43°F with salinities greater than 18 ppt. Inshore EFH for adult black sea bass is 

2 similar to that designated for juveniles (NMFS 2009b). 

3 4.2 Bluefish (Pomatomus saltatrix) 

4 Bluefish are found on the western Atlantic coast from Nova Scotia to Brazil, but are rare in the 

5 Caribbean (Murdy et al. 1997). Bluefish of similar sizes form schools and migrate along the 

6 Atlantic coast moving up the Middle Atlantic Bight in spring from wintering grounds off Florida, 

7 then returning south in fall (Shepherd and Packer 2006). Schools can be large, often covering 

8 tens of square miles (Murdy et al. 1997). Bluefish visit the Chesapeake Bay from spring to 

9 autumn (Murdy et al. 1997). Spawning occurs in offshore waters during the northward migration 

10 with peak spawning off Chesapeake Bay occurring in July (Murdy et al. 1997; ASMFC 2006a). 

11 After spawning, smaller fish enter nearshore bays, such as Chesapeake Bay and Delaware 

12 Bay, while larger fish swim northward. Juveniles (1.8 to 2.4 in. long) move into estuaries and 

13 nearshore environments that serve as nursery grounds in late summer and eventually migrate 

14 out of the Bay in the autumn (Harding and Mann 2001; Shepherd and Packer 2006). In 

15 Chesapeake Bay, bluefish are abundant near the mouth of the Bay and common in the upper 

16 Bay in some years, but rarely occur north of Baltimore (Murdy et al. 1997). Bluefish reach a 

17 maximum length of about 45 in. and a weight of about 15 lbs (Shepherd and Packer 2006). 

18 Bluefish are voracious top-level predators. Bluefish larvae feed on planktonic copepods and 

19 transition to a fish diet at length of about 1.1 in., after which juveniles move into estuaries 

20 (Shepherd and Packer 2006). Bluefish feed opportunistically on whatever fish species are 

21 abundant (Shepherd and Packer 2006) and also eat invertebrates, such as blue crabs 

22 (Callinectes sapidus) (Buckel et al. 1999). In Chesapeake Bay, bluefish diet varies with location 

23 as fish feeding near oyster reefs eat more invertebrates than fish in the middle Chesapeake Bay 

24 (Harding and Mann 2001). This species is one of the most important recreational and 

25 commercial species in Chesapeake Bay with the recreational catch exceeding the commercial 

26 catch by an estimated five to six times (Murdy et al. 1997; ASMFC 2006a; Harding and Mann 

27 2001). Bluefish are managed as a single stock, and the most recent review concluded that the 

28 species was not being overfished (Nygard 2005). Recreational and commercial catches in 

29 Maryland have decreased substantially since peak values in the late 1980s but have remained 

30 relatively stable since the mid 1990s (MDNR 2008). Despite reduced catches, the bluefish 

31 population estimates reflect a substantial increase in biomass from 1997 to 2004 (NOAA 2005). 

32 EFH that includes Chesapeake Bay has been designated for bluefish juveniles and adults. 

33 Inshore EFH for juvenile and adult bluefish includes all major estuaries between Penobscot Bay, 

34 Maine and the St. Johns River, Florida (NMFS 2009c). Bluefish adults are highly migratory and 

35 distribution varies seasonally and according to the size of the individuals composing the 

36 schools. Bluefish generally are found where salinities exceed 25 ppt. 

37 4.3 Butterfish (Peprilus triacanthus) 

38 Butterfish range from Nova Scotia to Florida into the Gulf of Mexico (Murdy et al. 1997), but are 

39 most abundant between Cape Hatteras and the Gulf of Maine (Cross et al. 1999). Butterfish 

40 move into Chesapeake Bay about March and remain until about November. They are most 

41 abundant in the lower Bay, but occasionally may be common in the upper Bay as far north as 

Appendix F

Draft NUREG-1936 F-90 April 2010
1 the Patapsco River (Murdy et al. 1997). They overwinter in deep offshore waters. Butterfish are 

2 pelagic and form large, loosely structured schools. The short-lived species spawns offshore 

3 from May to July in the mid-Atlantic area with eggs remaining offshore during the 48-hr 

4 incubation period (Cross et al. 1999). Larvae eventually congregate around floating items, such 

5 as jellyfish, seaweed, and other debris. Juveniles, which range from 0.6 to 4.7 in. long (Cross et 

6 al. 1999), move into nearshore waters, including estuaries (Murdy et al. 1997) and still may be 

7 associated with jellyfish. Adults may reach a length of about 12 in. and, in the Chesapeake Bay, 

8 mature by their third summer (Cross et al. 1999). Juvenile butterfish feed on smaller plankton, 

9 whereas adults feed more broadly on pelagic tunicates, jellyfish, crustaceans, and small fish. 

10 Many predatory fish, including weakfish and bluefish, feed on butterfish. Commercial catches of 

11 butterfish peaked about 1973 along the Atlantic coast and have declined fairly steadily since, 

12 with the lowest landings occurring in 2005 (Overholtz 2006). Butterfish were of minor 

13 commercial importance in the Chesapeake Bay in the late 1990s, with most of the catch coming 

14 from Virginia waters (Murdy et al. 1997). There is little recreational fishing for butterfish. 

15 EFH that includes Chesapeake Bay has been designated for butterfish eggs, larvae, juveniles, 

16 and adults. Inshore EFH for all butterfish life stages includes the mixing and/or seawater 

17 portions of all the estuaries where butterfish eggs are common, abundant, or highly abundant on 

18 the Atlantic coast, from Passamaquoddy Bay, Maine to James River, Virginia (NMFS 2009d). 

19 Butterfish eggs usually are found from shore to 6000 ft. Butterfish larvae typically are found at 

20 water depths between 33 ft and 6000 ft. Juveniles and adults usually are found in depths 

21 between 33 ft and 1200 ft. The only portion of the Bay near the Calvert Cliffs site deeper than 

22 33 ft is in the channel that was dredged for the intake system of Units 1 and 2 (EA Engineering 

23 2007a). 

24 4.4 Clearnose Skate (Raja eglanteria) 

25 Clearnose skates are broadly distributed in coastal waters from Massachusetts to Texas, 

26 although they are rare in the northern parts of the range (Murdy et al. 1997; Packer et al. 

27 2003a). Clearnose skates are primarily summer-to-fall residents of the Chesapeake Bay and 

28 are most abundant in the lower Bay (Murdy et al. 1997). These skates move out of the Bay to 

29 shallow offshore waters in the fall. Clearnose skates generally occur in waters with salinities 

30 greater than 22 ppt, particularly in the Chesapeake Bay (Packer et al. 2003a). Reproduction in 

31 waters north of Cape Hatteras occurs in spring and summer with each fertilized egg enclosed in 

32 a rectangular egg case that is deposited on the sea bottom (Packer et al. 2003a). Juveniles 

33 hatch from the egg cases after about 3 months and may eventually reach a length of about 

34 30 in. at an age of more than 6 years. Clearnose skates are nocturnal feeders on many types of 

35 benthic invertebrates and small fish. Sharks are the main predators of clearnose skates. 

36 Clearnose skate eggs may be attacked by snails capable of boring into the capsules (Cox and 

37 Koob 1993). A relatively small fishery exists for skates with smaller skates primarily caught for 

38 lobster bait (Packer et al. 2003a; Sosebee 2006). Clearnose skates do not contribute much to 

39 the total skate catch and are not being overfished (Sosebee 2006). In the Chesapeake Bay, 

40 clearnose skates are considered a nuisance catch (Murdy et al. 1997). 

41 EFH that includes Chesapeake Bay has been designated for clearnose skate juveniles and 

42 adults. EFH for juveniles includes soft-bottom substrates along the continental shelf and rocky 

Appendix F

April 2010 F-91 Draft NUREG-1936
1 or gravelly bottom, ranging from the Gulf of Maine south along the continental shelf to Cape 

2 Hatteras, North Carolina (NMFS 2009a). Clearnose skate juveniles and adults are most 

3 abundant from nearshore to waters less than 360 ft deep. 

4 4.5 Little Skate (Leucoraja erinacea) 

5 Little skates occur from Nova Scotia to Cape Hatteras and are most abundant between Georges 

6 Back and Delaware Bay (Murdy et al. 1997; Packer et al. 2003b). Little skates occasionally 

7 occur in the lower Chesapeake Bay in the winter and spring (Murdy et al. 1997). Although little 

8 skates tolerate relatively low salinities (about 20 ppt), they are most commonly found where 

9 salinities are about 30 ppt (Packer et al. 2003b). Like clearnose skates, little skates enclose a 

10 single fertilized egg within a capsule that is deposited on the sea floor. Reproduction may occur 

11 throughout the year. Development time varies depending on the season in which the capsule is 

12 deposited, but typically extends at least 6 months (Packer et al. 2003b). Juveniles are about 

13 4 in. long at hatching. Adults may reach a total length of about 24 in. Little skates feed primarily 

14 on benthic invertebrates, particularly crabs and polychaete worms, but also may feed on fish. 

15 Little skates are eaten by sharks, other skates, and several boney fish species (Packer et al. 

16 2003b). Little skate eggs may be attacked by snails capable of boring into the capsules 

17 (Cox and Koob 1993). Little skates are fished primarily for use as lobster bait and account for 

18 most of the bait fishery. They are not presently being overfished (Sosebee 2006). In the 

19 Chesapeake Bay, little skates are occasionally caught as bycatch in trawls and by hook and line 

20 (Murdy et al. 1997). 

21 EFH that includes Chesapeake Bay has been designated for little skate juveniles and adults. 

22 EFH for juvenile and adult little skates includes muddy, sandy, or gravelly bottom habitats from 

23 Georges Bank to Cape Hatteras, North Carolina (NMFS 2009a). Both life stages are found in 

24 shallow nearshore waters, but generally are most abundant in waters from 240 to 299 ft deep. 

25 4.6 Red Drum (Sciaenops ocellatus) 

26 Although red drum are found from the Gulf of Maine to the northern coast of Mexico, they are 

27 less abundant along the Atlantic coast than in the Gulf of Mexico (Murdy et al. 1997). Adults 

28 occur in Chesapeake Bay from May to November, with the highest numbers near the mouth in 

29 spring and fall with salinities at greater than 15 ppt (Murdy et al. 1997). Red drum may occur as 

30 far up the Bay as the Patuxent River. Spawning occurs at night in nearshore coastal waters 

31 from late summer through autumn, and tidal currents carry larvae to nursery habitats in 

32 estuaries where they stay through the juvenile stage (Murdy et al. 1997; ASMFC 2006b; Rooker 

33 et al. 1999). Adult red drum may reach a maximum size of 5 ft and weigh up to 92 lb. Red 

34 drum are predators feeding primarily on crustaceans, such as blue crabs, and fish, such as bay 

35 anchovy (Anchoa mitchilli) and menhaden (Brevoortia tyrannus) (Scharf and Schlicht 2000). 

36 There is a small red drum fishery in Chesapeake Bay with a small catch in Maryland waters in 

37 2006; an important red drum fishery throughout the Gulf of Mexico; and, to some extent, on the 

38 south Atlantic coast (Murdy et al. 1997). 

39 EFH has been designated for red drum eggs, larvae, juveniles, and adults and includes tidal 

40 freshwater, emergent vegetated wetlands in estuaries, mangrove fringe in estuaries, submerged 

Appendix F

Draft NUREG-1936 F-92 April 2010
1 rooted vascular plants, oyster reefs and shell banks, soft-bottom sediments, ocean surf zones, 

2 and artificial reefs (NMFS 2009e). Many of these habitats, especially submerged vegetation 

3 and oyster reefs, occur in Chesapeake Bay. There is an oyster reef but no SAV near the 

4 Calvert Cliffs site. EFH for red drum is also included within the Patuxent River (NMFS 2008b). 

5 4.7 Summer Flounder (Paralichthys dentatus) 

6 Summer flounder range from Nova Scotia to South Florida, and most only visit Chesapeake Bay 

7 from spring to autumn, although some have been known to overwinter in the Bay (Murdy et al. 

8 1997). Summer flounder migrate out of estuaries in late summer to early fall, but some may 

9 leave as late as early winter (Sackett et al. 2007). Tagging studies showed that many 

10 individuals return to the same estuary from which they emigrated (Sackett et al. 2007). Summer 

11 flounder are more common in the lower Chesapeake Bay than in the upper Bay. Spawning 

12 occurs during the migration offshore in the autumn with larvae typically most abundant about 

13 15 to 50 mi from shore (NMFS 2009f). Recently settled juveniles enter Virginia waters in the 

14 lower Bay between October and May (Norcross and Wyanski 1994). They remain in inshore 

15 areas for the first year of life (Murdy et al. 1997; ASMFC 2007). The maximum adult size is 

16 about 37 in. Young-of-the-year (about 1 in. long) may reach the Calvert Cliffs site area 

17 sometime in spring (Nichols 2008). Juveniles (about 3 to 10 in. long) may occur in the area 

18 from spring through fall (Nichols 2008). Summer flounder are ambush predators that feed on 

19 many fish and invertebrate species, although bay anchovy and mysid shrimp (Neomysis spp.) 

20 make up about half their diet (Latour et al. 2008). 

21 The summer flounder constitutes major commercial and recreational fisheries and is a highly 

22 sought food fish (Murdy et al. 1997; ASMFC 2007). The commercial fishery is primarily 

23 offshore, whereas the recreational fishery is in estuaries and bays (Latour et al. 2008). Though 

24 the summer flounder recreational catch has varied over the years, it approaches the commercial 

25 catch because of its popularity with anglers (Murdy et al. 1997; ASMFC 2007). Summer 

26 flounder are not yet overfished, but overfishing is occurring (Terceiro 2006). The estimated 

27 stock biomass increased substantially during the 1990s and through 2005, but it decreased 

28 slightly in 2006. 

29 EFH that includes Chesapeake Bay has been designated for summer flounder larvae, juveniles, 

30 and adults (NMFS 2009f). Inshore EFH for summer flounder larvae, juveniles, and adults 

31 includes all the estuaries where summer flounder were identified as being present in the mixing 

32 and seawater salinity zones. HAPCs that include all native species of SAV, such as 

33 macroalgae, seagrasses, and freshwater and tidal macrophytes in beds of any size or in loose 

34 aggregations within juvenile and adult summer flounder EFH, have been designated (NMFS 

35 2009f). SAV was not found during recent surveys conducted in the area of the Calvert Cliffs site 

36 (EA Engineering 2007b). 

37 4.8 Windowpane Flounder (Scophthalmus aquosus) 

38 Windowpane flounder (or windowpane) range from the Gulf of St. Lawrence to Florida (Murdy et 

39 al. 1997) and are most common around Georges Bank (Chang et al. 1999). Windowpane live 

40 year round in Chesapeake Bay and may be common as far north as the Choptank River (Murdy 

Appendix F

April 2010 F-93 Draft NUREG-1936
1 et al. 1997). The species can be abundant in the lower Bay. Windowpane spawn from spring to 

2 autumn, but they may not spawn during the middle of summer (Murdy et al. 1997; Chang et al. 

3 1999). Eggs float and are about 0.06 in. in diameter. Larvae range in length from about 0.08 to 

4 0.8 in., and juveniles reach lengths of up to about 8 in. (Morse and Able 1995). Adult 

5 windowpane can reach a total length of about 18 in. Juveniles and adults have broad diets, but 

6 they feed primarily on small crustaceans and worms, with small fish secondarily important 

7 (Chang et al. 1999; Link et al. 2002). The main predators of windowpane are spiny dogfish 

8 (Squalus acanthias), thorny skates (Amblyraja radiata), and other fish species (Chang et al. 

9 1999). Windowpane in the mid-Atlantic region are managed as the Southern New 

10 England/Middle Atlantic (SNE-MA) stock (Hendrickson 2006). Windowpane catches are not 

11 typically targeted but are primarily bycatch for other fisheries probably because of the thinness 

12 of the fish. There is no commercial or recreational windowpane fishery in Chesapeake Bay 

13 (Murdy et al. 1997). Landings of the SNE-MA windowpane stock increased from the 1970s 

14 through 1985 but have since declined to a record low value in 2005 (Hendrickson 2006). 

15 Because there is no targeted fishery, the main cause of fishery mortality is probably as 

16 discarded bycatch from other targeted fishing. The most recent evaluation showed the stock 

17 was overfished, although overfishing was not occurring (Hendrickson 2006). 

18 EFH that includes Chesapeake Bay has been designated for windowpane juveniles and adults. 

19 EFH for juveniles and adults includes muddy or fine-grained sandy bottom habitats (NEFMC 

20 1998). Both life stages typically occur where waters are cooler than about 84°F, and salinities 

21 range between 5.5 and 36 ppt (NEFMC 1998). 

22 4.9 Winter Skate (Leucoraja ocellata) 

23 Winter skates range from the Gulf of St. Lawrence to Cape Hatteras and are most abundant on 

24 Georges Bank and in the northern Mid-Atlantic Bight (Packer et al. 2003c). In the lower 

25 Chesapeake Bay, winter skates are occasional residents from winter to spring (Murdy et al. 

26 1997). Winter skates may reproduce all year, although there seems to be peak reproductive 

27 activity in summer and fall (Packer et al. 2003c). Fully developed juveniles hatch from egg 

28 capsules at about 4 to 5 in. in total length. Adults are relatively large, reaching lengths of about 

29 3 to 4 ft. Winter skates have a diverse diet of invertebrates and fish, the latter being particularly 

30 important food for larger skates (Packer et al. 2003c). Sharks, other skates, and gray seals are 

31 the main predators of winter skates. Winter skates are fished as part of the export market for 

32 skate wings. The biomass of large skates, including winter skates, has decreased since the 

33 1980s, and winter skates are considered as being overfished throughout most of the northwest 

34 Atlantic (Sosebee 2006). However, there are no commercial or recreational winter skate 

35 fisheries in the Chesapeake Bay (Murdy et al. 1997). 

36 EFH that includes Chesapeake Bay has been designated for winter skate juveniles and adults. 

37 EFH for juvenile and adult winter skates includes muddy, sandy, or gravelly bottom habitats in 

38 Cape Cod Bay, on Georges Bank, the southern New England shelf, and through the Mid39 Atlantic Bight to North Carolina (NMFS 2009a). Winter skate juveniles and adults frequent 

40 nearshore waters and are most abundant at depths less than 364 ft. 

Appendix F

Draft NUREG-1936 F-94 April 2010
1 5.0 Potential Environmental Effects of the 

2 Proposed Federal Actions 

3 This section describes the potential impacts from the construction and operation of the 

4 proposed Unit 3 at the Calvert Cliffs site to Federally managed estuarine and marine species 

5 and their habitats in Chesapeake Bay. 

6 5.1 General Construction Impacts 

7 Impacts to the EFH in Chesapeake Bay from construction of Unit 3 would be associated mainly 

8 with the construction of new water intake and discharge systems; construction of a new fish9 return system; and the refurbishing of the existing barge dock area, including dredging in 

10 Chesapeake Bay. These activities would result in temporary and permanent loss or conversion 

11 of aquatic habitat in the Chesapeake Bay. 

12 The major construction events associated with building Unit 3 that would affect EFH in the 

13 Chesapeake Bay share certain construction activities, such as dredging, pile driving, and 

14 armoring. All work would be conducted in accordance with Federal, State, and local permits 

15 that would be obtained by the applicant. EFH in Chesapeake Bay likely would not be adversely 

16 affected by the installation of new transmission facilities for Unit 3 because the facilities would 

17 be built on the uplands part of the Calvert Cliffs site. 

The total proposed project dredging would permanently affect about 248,000 ft2 18 (5.7 ac) of tidal 

open waters. About 52,500 ft2 19 (1.2 ac) of the dredging would be backfilled. 

20 5.1.1 Dredging and Pipeline Trenching 

21 Dredging of the Bay bottom would be done by using shore-based or barge-mounted clamshell 

22 dredges to reestablish the channel on the south side of the existing CCNPP Units 1 and 2 barge 

23 dock and to create the trenches for the fish-return and the cooling water discharge pipelines. 

24 Dredging or pipeline trenching constitutes a major, localized impact to the benthos. Additional 

25 Bay bottom next to the pipeline trenches would be disturbed by the placement of the dredged 

26 material for later use in the backfilling the trenches. Effects of dredging for the installation of the 

27 Unit 3 intake pipes would be minimized by construction of a sheet-pile cofferdam and 

28 dewatering system. The benthic infauna community in the areas proposed for dredging or 

29 trenching for the construction of Unit 3 is similar to the community elsewhere in the region and 

30 also to the community type that has been in the area for many years. The community is 

31 moderately degraded to degraded (EA Engineering 2007a). Although this community probably 

32 provides some forage for fish, the area is not one of high benthic productivity. 

33 In addition to the physical removal of Bay bottom, dredging, pipeline trenching, and backfilling 

34 increase the suspended sediment load in the water column. Suspended sediment may affect 

35 fish by clogging the gills and altering the feeding behavior of visual predators. It also may affect 

36 filter-feeding invertebrates and fish. However, the surficial sediments in the area that would be 

37 dredged are primarily sandy (refer to Section 2.1 of this EFH assessment) and likely would 

Appendix F

April 2010 F-95 Draft NUREG-1936
1 settle out of the water column relatively quickly. Some dredged material and water can be lost 

2 from the clam dredge as it is raised and deposited into the barge or as material is transferred 

3 from the barge to trucks. The potential resuspension of contaminants would not be a concern 

4 for the proposed dredging or trenching because the contaminant loads in the sediments in the 

5 barge dock area were shown to be very low (EA Engineering 2007a). 

6 5.1.2 Pile Driving 

7 Pile driving would be used in three project areas, all involving the installation of the sheet-pile 

8 walls. A vibratory hammer would be used to install the sheet piling and a conventional pile9 driving hammer to install the 30-in.-diameter steel soldier piles that would be placed on 10-ft 

10 centers to support the sheet piling. The principal impact would be the generation of noise at 

11 levels that may be harmful to fish. 

12 Pile driving noise may affect fish by causing temporary hearing loss, auditory tissue damage, 

13 and damage to non-auditory tissue, such as the swim bladder (Popper et al. 2006). Two 

14 criteria, both measured at a standard distance of 10 m (32.8 ft) from the pile-driving activity, are 

15 used to estimate the sound and vibration levels from pile driving that would injure fish. The 

16 peak sound-pressure level (peak pressure or peak), measured as decibels (dB) relative to 

17 reference level of one micro Pascal (dB re 1 Papeak), is maximum excursion of pressure 

18 associated with the sound (Popper et al. 2006). Peak pressure determines the likelihood that 

19 the swim bladder and ear would be exposed to extreme mechanical stress (Popper et al. 2006). 

20 The sound exposure level (SEL), measured as dB re 1 Pa2•s, is the constant sound level of 

21 1-second duration that would contain the same acoustic energy as the originally produced 

22 sound. 

23 The interim criteria (Popper et al. 2006) specified a peak level of 206 dB and a cumulative SEL 

24 level of 187 dB for fish weighing 2 gm and heavier or a cumulative SEL of 183 dB for fish lighter 

25 than 2 gm. The noise levels for the pile driving proposed for Unit 3 construction were estimated 

26 by applying compilations of measurements of noise and vibration impacts associated with 

27 various methods of pile driving, types of materials, and water depth. The estimated peak and 

28 cumulative SEL values for driving 24- to 36-in.-diameter steel piles with a conventional pile29 driving hammer in about 5-m water depth are about 203 to 208 dB and 177 to 180 dB, 

30 respectively. These values suggest that driving 30-in.-diameter steel piles with conventional 

31 hammers at the Calvert Cliffs site may produce sound impacts that approach or exceed the 

32 peak pressure guidance criterion of 206 dB, but would not likely exceed the minimum SEL 

33 criterion of 183 dB for fish lighter than 2 gm. Sheet-pile driving produces peak pressures 

34 ranging from 175 dB to 180 dB and cumulative SEL values ranging from 160 dB to 165 dB, 

35 which are below the respective interim criteria values (UniStar 2008b). Noise from pile driving 

36 would most likely affect small EFH species or those with small lifestages (e.g., butterfish; black 

37 sea bass) in the area. Prey of some species also could be affected (e.g., bluefish; red drum). 

38 5.1.3 Armoring 

39 Key underwater structures in the project area would be armored with imported rocks, 

permanently converting the benthic substrate to rocky bottom. The largest area, about 4652 ft2 40 

Appendix F

Draft NUREG-1936 F-96 April 2010
1 (0.11 ac), that would receive rock armor is next to the new sheet-pile wall that would be installed 

2 to create the wedge-shaped pool for Unit 3. The armoring in the area next to the baffle wall 

3 would be added to the Bay bottom as a series of four overlying layers, ranging from washed 

4 gravel on the bottom to large quarry rock (average about 2 tons each rock) on the top (UniStar 

5 2009d). The overall thickness of the armoring would vary according to the water depth. Armor 

6 would also be added to the Bay bottom at the end of the fish-return system, the cooling water 

7 discharge diffuser, and the nearshore area of the barge dock. Although some sediment 

8 suspension would occur during installation of the rock armor, the major effect would be the 

9 conversion of the benthic habitat from a soft-bottom infaunal community to a hard-bottom 

10 epifaunal community, which eventually is expected to colonize the rocks. The epifaunal 

11 community probably would include oysters, barnacles, mussels, and sea anemones, all of which 

12 colonized new hard-bottom habitat near the CCNPP Units 1 and 2 discharge pipe (Abbe 1987). 

13 The loss of soft-bottom habitat would likely reduce the potential forage area for some benthic14 feeding EFH fish species (e.g., summer flounder, winter flounder, and skates). However, the 

15 area is not one of high benthic productivity, and the area that would be lost is relatively small. 

16 5.1.4 Vessel Movements 

17 Vessel use during the dredging or the installation of the in-water structures for Unit 3 would 

18 affect the aquatic resources of the area, particularly the benthos. The main effects from using 

19 vessels would include turbulence from propellers (prop wash), anchor cable scraping across the 

20 Bay bottom, and accidental spills of materials overboard. Vessels would be used during the 

21 installation of the cooling water discharge pipeline; during the offloading of materials from 

22 barges; and, probably, during the installation of the sheet-pile wall at the new intake area and 

23 the fish-return system outfall. The primary occurrence of vessels would be during the operation 

24 of the barge dock, which is expected to last about 5 years during construction of the proposed 

25 Unit 3. The proposed barge docking procedures would minimize the potential impacts from 

26 prop wash (UniStar 2008b). Vessel operation during construction would cause short-term, 

27 localized impacts to EFH near the Calvert Cliffs site. These impacts are not expected to affect 

28 the general resources in the area of the site or the region along this coast of the Chesapeake 

29 Bay. 

30 5.2 General Operational Impacts 

31 For EFH in Chesapeake Bay, the primary concerns related to water intake and consumption are 

32 those related to the relative amount of cooling water drawn from the Chesapeake Bay and the 

33 potential for organisms to be entrained into the cooling water system, impinged on the trash 

34 racks or intake screens, or entrapped in the wedge-shaped pool or common forebay. 

35 Entrainment and impingement have the potential to affect EFH species indirectly by reducing 

36 key prey species or directly by entrainment or impingement of the EFH species themselves. 

37 Entrapment in the wedge-shaped pool is possible but unlikely because fish may be able to swim 

38 back out to the Bay following the same route of entry. Entrapment in the common forebay for 

39 Unit 3 would not have an escape route with the exception of the fish-return system for 

40 organisms impinged on the CWS intake screens. 

Appendix F

April 2010 F-97 Draft NUREG-1936
1 The intake system design for Unit 3 includes a fish-return system located at the CWS intake 

2 screens in the common forebay. There is no fish-return mechanism at the intake pipe openings 

3 in the wedge-shaped pool or at the UHS intake screens in the common forebay. The fish-return 

4 system may help increase survival following impingement by returning fish and crabs beneath 

5 the surface of the Bay. 

6 UniStar stated that a closed-cycle, recirculating, wet cooling system with a cooling tower would 

7 be used for Unit 3 (UniStar 2009a). The intake system for Unit 3 would incorporate fish and 

8 invertebrate protection measures that may reduce entrainment and impingement. The 

9 estimated maximum intake volume of 47,383 gpm for Unit 3 would not exceed the EPA 1-

10 percent water column criterion (UniStar 2009a). Unit 3 would have a fish-return system similar 

11 to the one used at existing CCNPP Units 1 and 2. Moreover, the through-screen flow velocity 

12 would be less than 0.5 ft/sec (0.15 m/sec) under the worst-case scenario of minimum 

13 Chesapeake Bay level with highest makeup demand flow (UniStar 2009a). The projected intake 

14 flow for Unit 3 is about 96.8 cfs, which is considerably less than the CCNPP Units 1 and 2 

15 combined flow of 5332 cfs. Because the projected intake flow volume for Unit 3 is about 1.82 

16 percent of that at CCNPP Units 1 and 2 and assuming that the relationship between flows is 

17 linear, the projected entrainment and impingement rates at Unit 3 would be correspondingly 

18 small. 

19 5.2.1 Entrainment 

20 The EFH species listed do not feed directly on plankton, but some are predators that consume 

21 planktivorous fish. The potential impact of Unit 3 from the entrainment of organisms into the 

22 cooling water system was evaluated by using historical (1974–1980) data collected at CCNPP 

23 Units 1 and 2. Sellner and Kachur (1987) determined that phytoplankton density in the 

24 discharge stream for Units 1 and 2 was significantly reduced compared to that in the intake 

25 stream. Phytoplankton photosynthesis metabolism was changed during passage through the 

26 plant such that carbon fixation was reduced. Importantly, however, Sellner and Kachur (1987) 

27 determined that these changes had no discernable effect on the phytoplankton densities or 

28 metabolism in the Chesapeake Bay waters near the Calvert Cliffs site. Olson (1987) found that 

29 zooplankton densities were less at the discharge point than they were at the intake point, which 

30 suggests that entrainment causes some zooplankton cropping. Olson also indicated survival 

31 after entrainment is typically very high and that no important changes in the zooplankton 

32 community could be detected. However, for this entrainment analysis, the review team used the 

33 conservative assumption of 100 percent mortality for entrained organisms. 

34 The potential for direct effects on EFH species can be evaluated by considering information 

35 from the ichthyoplankton entrainment sampling that was conducted at the intake system of 

36 CCNPP Units 1 and 2 from March 2006 through September 2007 (UniStar 2008c). Additional 

37 ichthyoplankton samples were collected just outside the existing baffle wall separating the 

38 intake area from the open waters of the Bay from April to December 2006. 

39 The total ichthyoplankton entrainment from March 2006 to September 2007, estimated at the 

40 maximum design flow for the intake systems of CCNPP Units 1 and 2, was at least 11.9 billion 

41 organisms, including fish eggs, larvae, juveniles, and adults (UniStar 2008c). This value is a 

Appendix F

Draft NUREG-1936 F-98 April 2010
1 minimum estimate of the total potential entrainment because daytime samples were not 

2 collected in March 2006, October through December 2006, and January through March 2007. 

3 Most of the entrainment during the study occurred from May to September. The bay anchovy 

4 (all life stages), a key prey item for some EFH species, was the predominant taxon entrained, 

5 accounting for about 75 percent and 69 percent of the total organisms estimated as entrained 

6 during 2006 and 2007, respectively. About 5.7 million adult and 9.2 billion eggs, larvae, and 

7 juvenile bay anchovies were estimated to be entrained at the maximum design flow rate for 

8 CCNPP Units 1 and 2 during the 19-month study. In 2006, Sciaenid eggs, Atlantic menhaden 

9 eggs and larvae (another prey species for some EFH taxa), and naked goby larvae and 

10 juveniles (Gobiosoma bosc) accounted for about 18.5 percent, 3.3 percent, and 1.5 percent of 

11 the entrained organisms, respectively. Hogchoker eggs (Trinectes maculatus), sciaenid eggs, 

12 and Atlantic menhaden eggs and larvae accounted for about 14.1 percent, 6.0 percent, and 4.9 

13 percent of the organisms, respectively, estimated entrained in 2007. Bay anchovy (all life 

14 stages), sciaenid eggs, Atlantic menhaden eggs and larvae, and naked goby larvae and 

15 juveniles were the predominant organisms collected just outside the intake system baffle wall, 

16 although the proportional contribution of each varied somewhat (UniStar 2008c). Comparisons 

17 of the intake and baffle-wall samples showed that most taxa entrained at rates relative to their 

18 occurrence in the Bay waters. However, juvenile bay anchovies, American eel (Anguilla 

19 rostrata) juveniles, Atlantic menhaden eggs and larvae, and sciaenid eggs were more abundant 

20 at the intake than they were at the baffle wall. 

21 The April through September Units 1 and 2 entrainment data for each year were used to 

22 estimate the potential total entrainment by the Unit 3 intake system because only those months 

23 had samples collected during the day and night. The April through September time period was 

24 the main period of entrainment captured by the study. Entrainment of most species and 

25 lifestages, except Atlantic croaker (Micropogonias undulatus) juveniles, was nonexistent or very 

26 reduced between October and March. Total estimated entrainment by Units 1 and 2 during 

27 April to September varied considerably between the 2 years, with 7.3 billion organisms 

28 entrained in 2006 and 759 million entrained in 2007. The estimate also considered that the 

29 projected intake flow volume for Unit 3 would be about 1.82 percent of that at CCNPP Units 1 

30 and 2 and assumed that the relationship between flows is linear. The projected April through 

31 September ichthyoplankton entrainment by the Unit 3 intake system would range from about 

32 83 million to about 132 million organisms. These values are much less than the variability in 

33 entrainment by the two existing units. The projected annual entrainment by Unit 3 would not be 

34 much greater than the April to September estimates, with the possible exception of Atlantic 

35 croaker juveniles, because entrainment at Units 1 and 2 from April through September is much 

36 greater than it is during the rest of the year. The projected combined April through September 

37 ichthyoplankton entrainment for all three units during those months would range from about 4.6 

38 billion to 7.4 billion organisms. 

39 5.2.2 Impingement and Entrapment 

40 Impingement sampling was conducted at CCNPP Units 1 and 2 from 1975 through 1995 

41 (Ringger 2000). Peak fish impingement occurred during the spring and summer. Blue crab, a 

42 potential prey species for some EFH species, impingement was greatest in spring, summer, or 

Appendix F

April 2010 F-99 Draft NUREG-1936
1 fall. There did not to appear to be annual trends, except that impingement generally appeared 

2 to be less after 1986 than it was before. The apparent difference in impingement rates before 

3 and after the mid-1980s may be related to several operational and structural modifications to the 

4 intake and fish-return systems that were made from about 1984 to 1986, partly in response to 

5 severe impingement events that occurred in 1983 (Ringger 2000). The most commonly 

6 impinged fish during the 21-year period were bay anchovy, hogchoker, spot (Leiostomus 

7 xanthurus), and Atlantic menhaden. Blue crab impingement, as that for fish, generally was 

8 lower after the mid 1980s than before. 

9 The average annual fish and blue crab impingement rates predicted for Unit 3 are 23,683 fish 

10 and 11,403 crabs. These resulted in estimated average annual impingement mortality rates at 

11 Unit 3 of 6327 fish and 62 crabs. The impingement mortality estimate for fish and crabs 

12 probably is somewhat conservative because the entire 21-year data set was used for the 

13 calculations regardless of apparently reduced impingement after modifications made in the mid 

14 1980s. Also, the Unit 3 intake approach velocities within the forebay would be less than 

15 0.5 ft/sec (0.15 m/sec), which would allow more crabs to avoid impingement. 

16 Special Condition N of the NPDES permit for CCNPP Units 1 and 2 requires notification within 

17 24 hours of any impingement on the water intake apparatus of aquatic organisms substantial 

18 enough to cause modification to plant operations (UniStar 2009a). Significant fish kills involving 

19 cownose rays (Rhinoptera bonasus) that were impinged on the trash racks of Units 1 and 2 

20 were reported in summer 2005 (80 to 100 rays) and 2006 (50 to 200 rays) (NRC 2005, NRC 

21 2006a, b). 

22 Water from the wedge-shaped pool would enter the common forebay that would supply water to 

23 the CWS and UHS intakes (Section 3.1 of this EFH assessment). Organisms impinged on the 

24 trash racks at the intake pipe openings would likely die because there is no rake or return 

25 system at that interface with the Bay. Such organisms would likely be larger than 3.5-in., which 

26 is the spacing between the trash bars. Because traveling screens and the fish-return system 

27 would be located at the CWS intake, smaller organisms would enter the common forebay. 

28 Organisms pulled toward the CWS pumps would be entrained as already discussed, impinged 

29 at the CWS trash rack, or impinged at the CWS traveling screens then delivered to the fish30 return system for passage to the Bay. Organisms pulled toward the UHS pumps during its 

31 periodic operation would be lost to impingement at the UHS trash racks or traveling screens 

32 because that system would not be connected to a fish-return system. The common forebay 

33 would hold a large volume of water, and it is likely that some organisms entering the forebay 

34 could become trapped within it without necessarily being entrained or impinged at CWS or UHS 

35 intakes. All approach velocities would be small, and all organisms would not be pulled into the 

36 pump system. There would be no mechanism to remove entrapped organisms from the 

37 common forebay other than the fish-return system associated with the CWS traveling screens 

38 (UniStar 2009c). It is not possible to accurately estimate the numbers of the individuals that 

39 would be entrapped. The species most likely to become entrapped would be those that were 

40 represented in results of entrainment and impingement studies conducted at Units 1 and 2 

41 (Section 5.2.1). Some species may thrive in the common forebay, while others may not. 

42 Regardless, all organisms entrapped in the forebay would be effectively removed from the Bay 

43 ecosystem. 

Appendix F

Draft NUREG-1936 F-100 April 2010
1 5.2.3 Aquatic Thermal Impacts 

2 The effluent discharge from Unit 3 would be directly into the Chesapeake Bay and would include 

3 blowdown from the CWS cooling tower, the essential service water system (ESWS) cooling 

4 towers, the desalination plant, liquid radiological effluent, and site waste streams. CORMIX 

5 modeling showed that the expected discharge plume from Unit 3 would be small and would not 

6 interact with the plume from Units 1 and 2. Abbe (1987) evaluated the potential effects of the 

7 thermal discharge from CCNPP Units 1 and 2, which is almost 1 mi north of the Unit 3 discharge 

8 location, and concluded that the thermal discharge from CCNPP Units 1 and 2 had no important 

9 adverse impacts on fish or key invertebrate species, such as eastern oysters (Crassostrea 

10 virginica) and blue crabs. The Maryland Power Plant Research Program (PPRP) concluded 

11 that the effects of thermal discharges from the power plants into Chesapeake Bay habitats were 

12 localized and not considered significant (MDNR PPRP 2008a). The waste heat from the Unit 3 

13 discharge would dissipate quickly because of the small size of the thermal plume and would not 

14 likely affect EFH taxa or habitat significantly. 

15 Cold shock occurs when aquatic organisms that have been acclimated to warm water, such as 

16 fish in a power plant’s discharge canal, are exposed to a sudden temperature decrease. This 

17 sometimes occurs when power plants shut down suddenly in winter. Abbe (1987) concluded 

18 the potential for cold shock associated with the discharge plume from CCNPP Units 1 and 2 

19 probably was not significant because the relatively small area of warmer water did not attract 

20 many fish during the winter. The volume of effluent discharge from Unit 3 would be much 

21 smaller than that from Units 1 and 2 and small in comparison to the volume of the Bay (UniStar 

22 2009a). Therefore, the warmer effluent water would mix quickly with the cooler ambient water 

23 given normal Bay flow patterns so that the thermal discharge would not attract many organisms. 

24 Cold shock is unlikely to be a factor for EFH species at the Unit 3 site. 

25 5.2.4 Chemical Impacts 

26 UniStar indicates that chemicals, such as anti-scaling compounds, corrosion inhibitors, and 

27 biocides, would be added to the CWS and the ESWS (UniStar 2009a). Biofouling normally 

28 would be controlled by injecting chlorine or bromine into the Chesapeake Bay influent water 

29 during the spring through fall (UniStar 2009a). The CWS would provide about 90 percent of the 

30 effluent discharged into the Chesapeake Bay, with the desalinization plant contributing another 

31 9 percent (UniStar 2008a). UniStar provided estimated concentrations of various constituents in 

32 the waste stream, which would include a small radioactive effluent (with a dose low enough not 

33 to affect biota), based on design data. To illustrate the expected low concentrations of these 

34 constituents, UniStar compared expected concentrations of five metal contaminants (arsenic, 

35 chromium, copper, nickel, and zinc) to aquatic life chronic salt water limits specified by the State 

36 of Maryland (COMAR 2008). Predicted concentrations within the discharge from Unit 3 would 

37 be substantially less than the State aquatic life limits (UniStar 2008a). UniStar would calculate 

38 more precise estimates of constituent concentrations in the effluent as part of the permitting 

39 process for Unit 3. The NRC determined that the effluent discharge from Units 1 and 2 would 

40 not significantly change the salinity gradients near the CCNPP site (NRC 2000). The addition of 

41 the relatively small discharge volume from Unit 3 would not be expected to alter this 

42 determination. 

Appendix F

April 2010 F-101 Draft NUREG-1936
1 UniStar expects that the NPDES permit for Unit 3 would require bioassay testing, as does the 

2 permit for Units 1 and 2, to assess the potential toxicity of the discharge and provide for 

3 corrective action if necessary. To date, the bioassay testing performed for CCNPP Units 1 and 

4 2 has not indicated any toxicity to test organisms (UniStar 2009a). 

5 5.2.5 Physical Impacts from Discharge 

6 The NRC determined that the effluent discharge from Units 1 and 2 would not significantly 

7 change the current patterns near the Calvert Cliffs site (NRC 2000). The addition of the 

8 relatively small discharge volume from Unit 3 would not be expected to alter this determination. 

9 The primary physical and ecological impacts from the CCNPP Units 1 and 2 cooling water 

10 discharge are sediment scour near the high-velocity discharge ports. The bottom scour 

11 associated with the discharge from CCNPP Units 1 and 2 was about 42 ac (UniStar 2008a). 

12 The sand substrate present prior to the operation of CCNPP Units 1 and 2 was scoured by the 

13 discharge, leaving a hard clay substrate. The benthic community changed from one 

14 characterized by burrowing soft-bottom organisms to one dominated by fouling organisms 

15 (UniStar 2008a). 

16 The area of Bay bottom that may be scoured would be minimized by the placement of riprap for 

17 about 10 ft on either side of the diffuser (UniStar 2008b). The potential scour area was 

18 estimated by comparing the sediment type to expected discharge flow velocities. Sediments in 

19 the area are primarily sandy (see Section 2.1 of this EFH assessment), and UniStar calculated 

20 that a water velocity of about 1 ft/sec would be required to move sand particles of a size 

21 between 0.210 mm and 0.177 mm (0.008 and 0.007 in.) (UniStar 2008a). The distance beyond 

22 which water velocities are expected to drop below the 1 ft/sec threshold was estimated to be 

about 92 ft, which resulted in an estimated potential scour area of 13,256 ft2 23 (0.3 ac). Therefore, 

24 the physical impacts associated with Unit 3 cooling water discharge would be limited to 

25 sediment scour of a small area. 

26 The infaunal community inhabiting the area near the discharge point, which was characterized 

27 during 2006 and 2007 (EA Engineering 2007a), was moderately degraded to degraded 

28 (Section 2.1 of this EFH assessment). The community had low organism abundance and few 

29 species. The predominant taxa were polychaete worms (Streblospio benedicti; Glycinde 

30 solitaria) and a small clam species (Gemma gemma). A historical study of benthic fish feeding 

31 at a location north of the Calvert Cliffs site (Kenwood Beach) found that nematode worms and 

32 polychaetes were among the predominant prey (UniStar 2008a). 

33 The bottom scouring near the discharge from CCNPP Units 1 and 2 caused the habitat to 

34 change from sandy sediment to hard clay and also caused a change from a sand-inhabiting 

35 infaunal community to an epifaunal community consisting of oysters, mussels, barnacles, and 

36 sea anemones (Abbe 1987). A similar, but much less extensive, change is likely if the sediment 

37 becomes scoured near the discharge for Unit 3. The small predicted size of the potential scour 

38 area and relative impoverishment of the infaunal community that would be replaced would not 

39 have much effect on the regional infaunal populations or their predators. 

Appendix F

Draft NUREG-1936 F-102 April 2010
1 5.3 Potential Effects of the Proposed Federal Actions on EFH 

2 Species 

3 5.3.1 Black Sea Bass 

4 The construction activities with the greatest potential to affect black sea bass EFH would be the 

5 pile driving associated with the installation of the sheet-pile wall at the proposed wedge-shaped 

6 pool and the dredging for the refurbishment of the barge dock, installation of the fish-return 

7 pipeline, and installation of the cooling water discharge and fish-return pipelines. The noises 

8 from pile driving likely would be loud enough to affect small black sea bass juveniles as 

9 described in Section 5.1.2. Increased water column sediment loads from dredging could affect 

10 juveniles and adults, which are visual predators. The overall effects of these would be reduced 

11 by the relatively short time over which pile driving would occur and the use of turbidity curtains 

12 during dredging and pipeline installation. Armoring near the new baffle wall, the fish-return 

13 discharge point, and the cooling water discharge diffuser could provide habitat for black sea 

14 bass. 

15 Direct operational impacts to black sea bass EFH would most likely be from impingement and 

16 possibly entrapment. Black sea bass occurred in 6 of the 21 yearly impingement samples 

17 collected from CCNPP Units 1 and 2 between 1975 and 1995 (Ringger 2000). However, the 

18 species only occurred in 1 year from 1984 to 1995, which could indicate a reduced likelihood of 

19 impingement and entrapment. Black sea bass eggs and larvae do not occur near Calvert Cliffs 

20 (Drohan et al. 2007). Therefore, entrainment or entrapment of early life stages is not expected. 

21 Black sea bass eggs, larvae, and juveniles were not found in the entrainment samples collected 

22 in the CCNPP Units 1 and 2 intake system or at the baffle wall in 2006 and 2007 (UniStar 

23 2008c), which indicates that there is a low likelihood of entrainment by the Unit 3 CWS. Some 

24 juvenile and adult black sea bass prey, such as bay anchovy and scup (Stenotomus chrysops), 

25 likely would be entrained, impinged, and/or entrapped by the Unit 3 cooling water system. 

26 However, black sea bass diets are diverse (Drohan et al. 2007), and the overall effects likely 

27 would not be important. Therefore, the construction and operation of the proposed new Unit 3 

28 at the Calvert Cliffs site are likely to have a more than minimal, although not substantial, 

29 adverse effect on EFH for black sea bass. 

30 5.3.2 Bluefish 

31 The construction activities with the greatest potential to affect bluefish EFH would be the pile 

32 driving associated with the installation of the sheet-pile wall at the new intake location and the 

33 dredging for the refurbishment of the barge dock and installation of the cooling water discharge 

34 and fish-return pipelines. The noises from pile driving likely would be loud enough to affect 

35 small bluefish juveniles as described in Section 5.1.2. Increased water column sediment loads 

36 from dredging could affect juveniles and adults, which are visual predators. The overall effects 

37 of these would be reduced by the relatively short time over which pile driving would occur and 

38 the use of turbidity curtains during dredging and pipeline installation. 

39 Direct operational impacts to bluefish EFH would most likely be from impingement and possibly 

40 entrapment. Bluefish occurred in the impingement samples collected from the CCNPP Units 1 

Appendix F

April 2010 F-103 Draft NUREG-1936
1 and 2 intake system in 9 of the 21 years from 1975 to 1995 (Ringger 2000), although they 

2 occurred in only 1 year after 1984, which could indicate a reduced likelihood of impingement 

3 and entrapment. Bluefish were not found in the entrainment samples collected in the CCNPP 

4 Units 1 and 2 intake system or at the baffle wall in 2006 and 2007 (UniStar 2008c), which 

5 indicates that there is a low likelihood of entrainment by the Unit 3 CWS. Impingement, 

6 entrainment, and entrapment could indirectly affect bluefish EFH because some of the key 

7 bluefish prey species, Atlantic menhaden and bay anchovy (Hartman and Brandt 1995), are 

8 captured by the intake system for CCNPP Units 1 and 2 and, therefore, would likely be affected 

9 by CCNPP Unit 3. However, bluefish feed opportunistically on abundant species and likely 

10 would feed on prey other than menhaden and bay anchovy if necessary (Shepherd and Packer 

11 2006). Also, the intake system for Unit 3 would draw much less water than that for Units 1 and 

12 2 and would not be expected to add significantly to the numbers of these prey species 

13 impinged, entrained, or entrapped. Therefore, the construction and operation of the proposed 

14 new Unit 3 at the Calvert Cliffs site are likely to have a more than minimal, although not 

15 substantial, adverse effect on EFH for bluefish. 

16 5.3.3 Butterfish 

17 The construction activities with the greatest potential to affect butterfish EFH would be the pile 

18 driving associated with the installation of the sheet-pile wall at the new intake location and the 

19 dredging for the refurbishment of the barge dock and installation of the cooling water discharge 

20 and fish-return pipelines. The noises from pile driving likely would be loud enough to affect 

21 butterfish larvae and juveniles as described in Section 5.1.2. Increased water column sediment 

22 loads from dredging could affect larvae, juveniles, and adults as described in Section 5.1.1. 

23 However, these life stages typically occur in waters deeper than where pile driving or dredging 

24 would occur. The overall effects of these would be reduced further by the relatively short time 

25 over which pile driving would occur and the use of turbidity curtains during dredging and pipeline 

26 installation. 

27 Direct operational impacts to butterfish EFH would most likely be from impingement and 

28 possibly entrapment. Butterfish occurred in 15 of the 21 yearly impingement samples collected 

29 from CCNPP Units 1 and 2 between 1975 and 1995 (Ringger 2000). However, the species only 

30 occurred in 5 years from 1984 to 1995, which could indicate a reduced likelihood of 

31 impingement and entrapment. The intake system for Unit 3 would draw much less water than 

32 that for Units 1 and 2 and would not be expected to add significantly to the numbers of butterfish 

33 impinged. Butterfish were not caught in entrainment samples collected from the intake for Units 

34 1 and 2 or at the baffle wall in 2006 and 2007 (UniStar 2008c), which indicates that there is a 

35 low likelihood of entrainment by the Unit 3 CWS. The planktonic prey of butterfish may be 

36 entrained or entrapped by the Unit 3 cooling water system. Entrainment studies conducted at 

37 CCNPP Units 1 and 2 showed no significant effects on plankton communities in the area 

38 (Section 5.2). The small water volume withdrawn by the Unit 3 intake system reduces the 

39 potential for important effects on butterfish prey. Therefore, the construction and operation of 

40 the proposed new Unit 3 at the Calvert Cliffs site are likely to have a more than minimal, 

41 although not substantial, adverse effect on EFH for the butterfish. 

Appendix F

Draft NUREG-1936 F-104 April 2010
1 5.3.4 Clearnose Skate 

2 The construction activities with the greatest potential to affect clearnose skate EFH would be the 

3 dredging for the refurbishment of the barge dock and installation of the cooling water discharge 

4 and fish-return pipelines. Increased water column sediment loads from dredging could affect 

5 larvae, juveniles, and adults as described in Section 5.1.1. The overall effects of dredging 

6 would be reduced by the use of turbidity curtains during dredging and pipeline installation. 

7 Noise from pile-driving activities is not expected to adversely affect clearnose skates because 

8 the individuals most likely in the area would be relatively large and not as susceptible as smaller 

9 fish. Armoring near the new baffle wall, the fish-return discharge point, and the cooling water 

10 discharge diffuser would make the habitat less suitable for clearnose skates. Disturbances to 

11 the benthos, including armoring, could affect benthic prey resources for clearnose skates. 

12 However, the benthic habitat near the Calvert Cliffs site is not highly productive and constitutes 

13 only a relatively small portion of the available benthic habitat in the Bay. 

14 Direct operational impacts to clearnose skate EFH would most likely be from impingement on 

15 the trash racks. Clearnose skates were not listed in the yearly impingement samples collected 

16 from the CCNPP Units 1 and 2 traveling screens between 1975 and 1995 (Ringger 2000). 

17 However, other large elasmobranchs (cownose ray) occasionally have impinged in large 

18 numbers on the trash racks at the existing CCNPP Units 1 and 2, probably as a result of low 

19 oxygen levels during the summer (NRC 2005, NRC 2006a, b). Clearnose skates were not 

20 caught in entrainment samples collected from the intake for Units 1 and 2 or at the baffle wall in 

21 2006 and 2007 (UniStar 2008c), which indicates that there is a low likelihood of entrainment by 

22 the Unit 3 CWS. Clearnose skates are benthic feeders whose diets would not be adversely 

23 affected by the potential entrainment, impingement, and entrapment of prey by the Unit 3 

24 cooling water intake system. Therefore, the construction and operation of the proposed new 

25 Unit 3 at the Calvert Cliffs site are likely to have a more than minimal, although not substantial, 

26 adverse effect on EFH for the clearnose skate. 

27 5.3.5 Little Skate 

28 The construction activities with the greatest potential to affect little skate EFH would be the 

29 dredging for the refurbishment of the barge dock and installation of the cooling water discharge 

30 and fish-return pipelines. Increased water column sediment loads from dredging could affect 

31 larvae, juveniles, and adults as described in Section 5.1.1. The overall effects of dredging 

32 would be reduced by the use of turbidity curtains during dredging and pipeline installation. 

33 Noise from pile-driving activities is not expected to adversely affect little skates because the 

34 individuals most likely in the area would be relatively large and not as susceptible as smaller 

35 fish. Armoring near the new baffle wall, the fish-return discharge point, and the cooling water 

36 discharge diffuser would make the habitat less suitable for little skates. Disturbances to the 

37 benthos, including armoring, could affect benthic prey resources for little skates. However, the 

38 benthic habitat near the CCNPP site is not highly productive and constitutes only a relatively 

39 small portion of the available benthic habitat in the Bay. 

40 Direct operational impacts to little skate EFH would most likely be from impingement on the 

41 trash racks. Little skates were not listed in the yearly impingement samples collected from the 

Appendix F

April 2010 F-105 Draft NUREG-1936
1 CCNPP Units 1 and 2 traveling screens between 1975 and 1995 (Ringger 2000). However, 

2 other large elasmobranchs (cownose ray) occasionally have impinged in large numbers on the 

3 trash racks at the existing CCNPP Units 1 and 2, probably as a result of low oxygen levels 

4 during the summer (NRC 2005, NRC 2006a, b). Little skates were not caught in entrainment 

5 samples collected from the intake for Units 1 and 2 or at the baffle wall in 2006 and 2007 

6 (UniStar 2008c), which indicates that there is a low likelihood of entrainment by the Unit 3 CWS. 

7 Little skates are benthic feeders whose diets would not be adversely affected by the potential 

8 entrainment, impingement, and entrapment of prey by the Unit 3 cooling water intake system. 

9 Therefore, the construction and operation of the proposed new Unit 3 at the Calvert Cliffs site 

10 are likely to have a more than minimal, although not substantial, adverse effect on EFH for the 

11 little skate. 

12 5.3.6 Red Drum 

13 The construction activities with the greatest potential to affect red drum EFH would be the pile 

14 driving associated with the installation of the sheet-pile wall at the new intake location and the 

15 dredging for the refurbishment of the barge dock and installation of the cooling water discharge 

16 and fish-return pipelines. The noises from pile driving likely would be loud enough to affect red 

17 drum larvae and juveniles as described in Section 5.1.2. Increased water column sediment 

18 loads from dredging could affect larvae, juveniles, and adults as described in Section 5.1.1. The 

19 overall effects of these would be reduced further by the relatively short time over which pile 

20 driving would occur and the use of turbidity curtains during dredging and pipeline installation. 

21 Armoring near the new baffle wall, the fish-return discharge point, and the cooling water 

22 discharge diffuser would make the habitat less suitable for red drum. 

23 Direct operational impacts to red drum EFH would most likely be from impingement and 

24 entrapment. Red drum occurred in the impingement samples collected from CCNPP Units 1 

25 and 2 only in 1983 (Ringger 2000), which could indicate a low likelihood of impingement and 

26 entrapment. Red drum were not specifically identified in the entrainment samples collected in 

27 the CCNPP Units 1 and 2 intake system or from the baffle wall in 2006 and 2007 (UniStar 

28 2008c). However, sciaenid eggs, which were not identified further, were the second most 

29 common organism entrained. These were not likely red drum eggs because red drum spawn 

30 primarily in nearshore coastal waters. Impingement, entrainment, and entrapment could 

31 indirectly affect red drum EFH because some of the potential prey species in the Chesapeake 

32 Bay, such as Atlantic menhaden and bay anchovy, are captured by the intake system for 

33 CCNPP Units 1 and 2. However, the intake system for Unit 3 would draw much less water than 

34 that for Units 1 and 2 and would not be expected to add significantly to the numbers of these 

35 prey species impinged, entrained, or entrapped. Therefore, the construction and operation of 

36 the proposed new Unit 3 at the Calvert Cliffs site are likely to have a more than minimal, 

37 although not substantial, adverse effect on EFH for the red drum. 

38 5.3.7 Summer Flounder 

39 The construction activities with the greatest potential to affect summer flounder EFH would be 

40 the pile driving associated with the installation of the sheet-pile wall at the new intake location 

41 and the dredging for the refurbishment of the barge dock and installation of the cooling water 

Appendix F

Draft NUREG-1936 F-106 April 2010
1 discharge and fish-return pipelines. The noises from pile driving likely would be loud enough to 

2 affect summer flounder juveniles of the size potentially found near the site as described in 

3 Section 5.1.2. Increased water column sediment loads from dredging could affect larvae, 

4 juveniles, and adults as described in Section 5.1.1. The overall effects of these would be 

5 reduced further by the relatively short time over which pile driving would occur and the use of 

6 turbidity curtains during dredging and pipeline installation. Armoring near the new baffle wall, 

7 the fish-return discharge point, and the cooling water discharge diffuser would make the habitat 

8 less suitable for summer flounder. Disturbances to the benthos, including armoring, could affect 

9 benthic prey resources for summer flounder. However, the benthic habitat near the Calvert 

10 Cliffs site is not highly productive and constitutes only a relatively small portion of the available 

11 benthic habitat in the Bay. 

12 Direct operational impacts to summer flounder EFH would most likely be from impingement and 

13 entrapment. Summer flounder occurred in impingement samples collected from the CCNPP 

14 Units 1 and 2 intake system in 18 of the 21 years from 1975 to 1995 and was the fifth most15 impinged species in 1984 (Ringger 2000). About 90 percent of impinged summer flounder 

16 survive. Despite the possible occurrence of smaller individuals at the Calvert Cliffs site, summer 

17 flounder were not caught in entrainment samples collected from the intake for Units 1 and 2 or 

18 at the baffle wall in 2006 and 2007 (UniStar 2008c), which indicates that there is a low likelihood 

19 of entrainment by the Unit 3 CWS. Impingement, entrainment, and entrapment could indirectly 

20 affect summer flounder EFH because one of the key prey species, bay anchovy (Latour et al. 

21 2008), is captured by the intake system for CCNPP Units 1 and 2. However, the intake system 

22 for Unit 3 would draw much less water than that for Units 1 and 2 and would not be expected to 

23 add significantly to the numbers of these prey species impinged, entrained, or entrapped. 

24 Therefore, the construction and operation of the proposed new Unit 3 at the Calvert Cliffs site 

25 are likely to have a more than minimal, although not substantial, adverse effect on EFH for the 

26 summer flounder. 

27 5.3.8 Windowpane Flounder 

28 The construction activities with the greatest potential to affect windowpane flounder EFH would 

29 be the pile driving associated with the installation of the sheet-pile wall at the new intake 

30 location and the dredging for the refurbishment of the barge dock and installation of the cooling 

31 water discharge and fish-return pipelines. The noises from pile driving likely would be loud 

32 enough to affect windowpane flounder juveniles as described in Section 5.1.2. Increased water 

33 column sediment loads from dredging could affect juveniles and adults as described in 

34 Section 5.1.1. The overall effects of these would be reduced further by the relatively short time 

35 over which pile driving would occur and the use of turbidity curtains during dredging and pipeline 

36 installation. Armoring near the new baffle wall, the fish-return discharge point, and the cooling 

37 water discharge diffuser would make the habitat less suitable for windowpane flounder. 

38 Disturbances to the benthos, including armoring, could affect benthic prey resources for 

39 windowpane flounder. However, the benthic habitat near the Calvert Cliffs site is not highly 

40 productive and constitutes only a relatively small portion of the available benthic habitat in the 

41 Bay. 

Appendix F

April 2010 F-107 Draft NUREG-1936
1 Direct operational impacts to windowpane flounder EFH would most likely be from impingement 

2 and entrapment. Windowpane flounder occurred in 5 of the 21 yearly impingement samples 

3 collected from CCNPP Units 1 and 2 between 1975 and 1995 (Ringger 2000). However, the 

4 species only occurred in 1 year from 1981 to 1995, which could indicate a reduced likelihood of 

5 impingement and entrapment. Windowpane flounder were not caught in entrainment samples 

6 collected from the intake for Units 1 and 2 or at the baffle wall in 2006 and 2007 (UniStar 

7 2008c), which indicates that there is a low likelihood of entrainment by the Unit 3 CWS. 

8 Windowpane flounder are benthic feeders whose diets would not be adversely affected by the 

9 potential entrainment, impingement, or entrapment of prey by the Unit 3 cooling water intake 

10 system. Therefore, the construction and operation of the proposed new Unit 3 at the Calvert 

11 Cliffs site are likely to have a more than minimal, although not substantial, adverse effect on 

12 EFH for the windowpane flounder. 

13 5.3.9 Winter Skate 

14 The construction activities with the greatest potential to affect winter skate EFH would be the 

15 dredging for the refurbishment of the barge dock and installation of the cooling water discharge 

16 and fish-return pipelines. Increased water column sediment loads from dredging could affect 

17 larvae, juveniles, and adults as described in Section 5.1.1. The overall effects of dredging 

18 would be reduced by the use of turbidity curtains during dredging and pipeline installation. 

19 Noise from pile-driving activities is not expected to adversely affect winter skates because the 

20 individuals most likely in the area would be relatively large and not as susceptible as smaller 

21 fish. Armoring near the new baffle wall, the fish-return discharge point, and the cooling water 

22 discharge diffuser would make the habitat less suitable for winter skates. Disturbances to the 

23 benthos, including armoring, could affect benthic prey resources for winter skates. However, 

24 the benthic habitat near the Calvert Cliffs site is not highly productive and constitutes only a 

25 relatively small portion of the available benthic habitat in the Bay. 

26 Direct operational impacts to winter skate EFH would most likely be from impingement on the 

27 trash racks. Winter skates were not listed in the yearly impingement samples collected from the 

28 CCNPP Units 1 and 2 traveling screens between 1975 and 1995 (Ringger 2000). However, 

29 other large elasmobranchs (cownose ray) occasionally have been impinged in large numbers on 

30 the trash racks at the existing CCNPP Units 1 and 2, probably as a result of low oxygen levels 

31 during summer (NRC 2005, NRC 2006a, b). Winter skates were not caught in entrainment 

32 samples collected from the intake for Units 1 and 2 intake system or at the baffle wall in 2006 

33 and 2007 (UniStar 2008c), which indicates that there is a low likelihood of entrainment by the 

34 Unit 3 CWS. Winter skates are benthic feeders whose diets would not be adversely affected by 

35 the potential entrainment and impingement of prey by the Unit 3 cooling water intake system. 

36 Therefore, the construction and operation of the proposed new Unit 3 at the Calvert Cliffs site 

37 are likely to have a more than minimal, although not substantial, adverse effect on EFH for the 

38 winter skates. 

39 6.0 Cumulative Effects 

40 

41 The NRC and the Corps review team considered potential cumulative effects on EFH and 

42 Federally managed fish and shellfish species in conjunction with building and operating a new 

Appendix F

Draft NUREG-1936 F-108 April 2010
1 nuclear unit at the Calvert Cliffs site. For this analysis, past and present actions create the 

2 existing baseline conditions, and cumulative effects include the effects of future State, Tribal, 

3 local, and private actions that are reasonably certain to occur in the action area considered in 

4 this assessment. The future is defined as the start of construction of the proposed Unit 3 until 

5 the conclusion of decommissioning. The action area for this evaluation is the Calvert Cliffs site 

6 and the mesohaline (salinity ranges from about 5 to 19 ppt) western portion of the Chesapeake 

7 Bay. The extent of the mesohaline zone in the Chesapeake Bay varies seasonally, but at its 

8 maximum, includes the western Bay shore from near the mouth of the Rappahannock River to 

9 Baltimore (MDNR PPRP 2008a; CBP 2009). 

10 Two future non-Federal projects were identified within the action area. Reinforcing an existing 

11 pier at the Cove Point liquefied natural gas (LNG) terminal, about 3.5 mi southeast of the 

12 Calvert Cliffs site, would involve installing 108-in.-diameter tubular steel monopile mooring 

13 dolphins, reinforcing existing and installing new breasting dolphins, installing walkways, and 

14 dredging about 30 ac of Bay bottom around the pier to a depth of about 45.0 ft mean low water 

15 (USACE 2009). Suitable dredged material would be placed in a stone-reinforced area along 

16 2513 ft of shoreline and extending an average of 225 ft channelward to create a tidal marsh. 

17 The effects of this project on EFH would be similar to the effects from construction of the in18 water components described for the proposed Unit 3. Because the Cove Point LNG terminal is 

19 close to the Calvert Cliffs site, it is likely that similar species and habitats would exist and 

20 experience similar localized effects. In additionally, ongoing operation of the terminal could 

21 affect EFH as a result of vessel operation, most notably through the use of Chesapeake Bay 

22 water for ballast. The addition of ballast water to a vessel would likely remove certain life stages 

23 of certain species from the immediate area. Such removal could have similar effects on the 

24 populations as impingement, entrapment, and entrainment from operation of the proposed 

25 CCNPP Unit 3. 

26 Building and operating a new nuclear reactor on the Calvert Cliffs site could interact with a part 

27 of the proposed Mid-Atlantic Power Pathway (MAPP) project, which proposes to build a 500-kV 

28 transmission line from Possum Point, Virginia to Salem, New Jersey (MAPP 2009a). The 

29 second part of the MAPP project would involve building an underwater crossing through the 

30 Chesapeake Bay, extending from Calvert Cliffs to the Maryland eastern shore. The route could 

31 include broadband fiber optic cables (PHI 2009). Details of this part of the project are not yet 

32 available, but the installation of underwater cables could involve horizontal directional drilling 

33 from the shore into the Bay and some type of trenching to install the cable within the Bay. The 

34 schedule suggests that the crossing under the Bay is expected to be completed in 2014 (MAPP 

35 2009b). The MAPP project could affect benthic habitats and noise-sensitive species in the 

36 same nearshore area off the Calvert Cliffs site, but such impacts are expected to be temporary 

37 as benthic organisms would recolonize the area, and mobile organisms would avoid noisy 

38 construction areas. 

39 CCNPP Units 1 and 2 will continue to operate during the construction and operation of proposed 

40 Unit 3. Calvert Cliffs Nuclear Power Plant, Inc. requested power uprates for the two units that 

41 will increase the generating capacity of each unit by about 1.38 percent. The uprate was 

42 completed in December 2009 for Unit 2, and a decision is expected by the end of summer 2010 

43 for Unit 1 (NRC 2009). The uprates would likely result in a small increase in water withdrawn 

44 from the Bay and a small increase in the temperature of water discharged to the Bay. Neither 

Appendix F

April 2010 F-109 Draft NUREG-1936
1 increase would be expected to add significantly to the present effects of Units 1 and 2 on the 

2 Bay, nor the combined effects of Units 1, 2, and 3. 

3 The Calvert Cliffs site operations, other anthropogenic stressors, and climatic events could 

4 combine to adversely affect EFH and Federally managed fish and shellfish species of the 

5 Chesapeake Bay. Commercial and recreational fishing pressure, the most noticeable 

6 anthropogenic stressor, has significantly affected aquatic resources in the Bay, causing 

7 population declines for several species (Greiner and Vogt 2009). Heavy fishing pressure, in 

8 conjunction with habitat loss and pollution, has caused serious reductions in the populations of 

9 many species inhabiting the Bay. Notable among these are the eastern oyster (Crassostrea 

10 virginica), blue crab (Callinectes sapidus), striped bass (Morone saxatilis), and several species 

11 of forage fish (CBP 2007). Other species, including weakfish (Cynoscion regalis), summer 

12 flounder (Paralichthys dentatus), and Atlantic croaker (Micropogonias undulatus), have been 

13 affected primarily by overfishing (McBride 2006). Steps to reduce fishing pressure, such as 

14 catch limits and moratoria, have contributed to population increases of some of these species 

15 (McBride 2006). The operation of proposed Unit 3 at the Calvert Cliffs site could also contribute 

16 to population declines by impinging, entrapping, or entraining species, but the effects would be 

17 minor relative to the existing Units 1 and 2, which operate using once-through cooling systems. 

18 A significant issue facing the Chesapeake Bay is global climate change. The buildup of 

19 greenhouse gas emissions that occurred in the 20th century has assured that some climate 

20 change will occur within the 21st century, even without increasing the current rates of emissions 

21 (Teng et al. 2006). The projected climate changes are predicted to affect the Chesapeake Bay 

22 primarily through increasing sea level, air and water temperatures, and changes in precipitation 

23 (Jasinski and Claggett 2009). Increased water acidity, which is a looming issue in some ocean 

24 habitats (Doney et al. 2009), is considered a less important factor for the Chesapeake Bay at 

25 present (Jasinski and Claggett 2009). Wu et al. (2009) projected that the sea level at Solomons 

26 Island, about 7.5 mi south of CCNPP, is expected to rise by about 22 to 24 in. by the end of the 

27 21st century. However, the estimate did not consider that the melting of the West Antarctic Ice 

28 Sheet could cause regional differences in sea level rise, which implies that the projection may 

29 have underestimated the rise in sea level in the Chesapeake Bay area by as much as one-third 

30 (Mitrovica et al. 2009). Najjar et al. (2009) projected that air temperatures in the Chesapeake 

31 Bay region could rise by about 5°F to 12°F by the year 2100. Because surface-water 

32 temperature is roughly related to air temperature, a similar increase in water temperature could 

33 be expected (Wood et al. 2002). Changes in rainfall are difficult to predict and model results 

34 often disagree. Most models predict, with considerable variability, that precipitation in winter 

35 and spring in the latter part of the 21st century could change an average of 3 percent over 

36 current levels (Najjar et al. 2009). One of the effects of increased precipitation is a reduction in 

37 salinity, particularly in the winter and spring (Jasinski and Claggett 2009). 

38 The interaction of the operation of the proposed Unit 3 and the predicted rise in Bay water level 

39 is difficult to assess, but it is not likely that the plant’s operations would add significantly to the 

40 potential impacts of sea-level rise (e.g., increased shoreline erosion). Similarly, the small sizes 

41 of the discharge plumes from Units 1 and 2 and proposed Unit 3 compared to the volume of 

42 water in the Chesapeake Bay suggests that the thermal discharges from all three units would 

43 not add importantly to the thermal regime in the Bay. Salinity in the Bay is predominantly 

44 related to flow from the Susquehanna River (Gibson and Najjar 2000), and the comparatively 

Appendix F

Draft NUREG-1936 F-110 April 2010
1 small discharges from all three units would not contribute to significant salinity changes in the 

2 Bay. 

3 The review team concludes that the incremental contribution of construction and operation of 

4 Unit 3 on the Calvert Cliffs site to the cumulative effects on EFH and Federally managed fish 

5 and shellfish species in the Chesapeake Bay would be unlikely to noticeably alter populations. 

6 7.0 Mitigation Measures 

7 The primary factors that could affect EFH in the CCNPP Unit 3 project area would be 

8 construction activities, such as dredging for the barge dock restoration or pipeline installation 

9 and pile driving for the wedge-shaped pool and barge dock renovation. Increased water column 

10 turbidity is a primary effect from dredging. UniStar proposes to use methods such as turbidity 

11 curtains to reduce the potential turbidity impacts to aquatic resources in Chesapeake Bay 

12 (UniStar 2008d). This would include the use of turbidity curtains around dredges or active 

13 dredge areas. The State of Maryland, as a condition on granting a Certificate of Public 

14 Convenience and Necessity (CPCN), stipulated that UniStar conduct dredging at times of the 

15 year that are appropriate to avoid impacts to Natural Oyster Bar (NOB) 19-2, part of which is 

16 within the dredging area (MDNR PPRP 2008b). 

17 Pile driving would be a relatively short-term activity with unavoidable adverse impacts. 

18 However, the extent of the adverse impacts is mitigable to some degree. UniStar has 

19 acknowledged that the effects of noise and vibrations could be reduced by various means, but 

20 has not committed to any for the proposed project at this time (UniStar 2008d). These could 

21 include placing bubble curtains around large piles and switching to hammers that produce less 

22 sound. Turbidity curtains would be used around pile driving areas to reduce the potential for 

23 increased water column sediment (UniStar 2008d). Buffered sound and less extensive 

24 sediment suspension would result in fewer adverse impacts on designated EFH and on 

25 Federally managed fish and shellfish species in the Chesapeake Bay. 

26 There are also potential mitigation measures for operation of the proposed Unit 3 that may 

27 reduce adverse effects on designated EFH and on Federally managed fish and shellfish species 

28 in the Chesapeake Bay. Although the proposed new unit would include a fish-return system at 

29 the CWS intake, there is no proposed fish-return system at the UHS intake or at the entrance to 

30 the intake pipelines at the wedge-shaped pool. The UHS intake would not be operated often, so 

31 there would not be as great a need for a fish-return system at that location. However, the 

32 openings of the intake pipelines are the point of no return for many organisms as they are 

33 delivered into the common forebay. The trash racks at the pipe openings would prevent large 

34 organisms from being delivered to the common forebay. However, large organisms could be 

35 impinged on those trash racks. Any organisms smaller than the trash rack spacing (3.5 in.) 

36 likely would be drawn into the common forebay, where they would be subjected to entrainment, 

37 impingement, and/or entrapment. Installation of travelling screens and a fish-return system at 

38 the pipe openings in the wedge-shaped pool would reduce impingement and entrapment in the 

39 common forebay. In addition, to reduce effects of entrapment in the wedge-shaped pool and in 

40 the common forebay, a monitoring and rescuing program could be implemented to transfer such 

41 organisms back to the Bay. Such a program could include visual inspection, collection with nets 

Appendix F

April 2010 F-111 Draft NUREG-1936
1 or other devices, and delivery by a fish-return pipe or by direct transfer to the Bay in a location 

2 less likely to be affected by the intake area for Units 1, 2, and 3. 

3 Although the NRC lacks the statutory authority to require any of the above potential mitigation 

4 measures, the staff recognizes that such potential mitigation could further reduce adverse 

5 impacts on designated EFH and on Federally managed fish and shellfish species in the 

6 Chesapeake Bay. The Corps permit, if issued, could include special conditions such as time-of7 year restrictions or specific methods of work to ameliorate potential impacts to EFH for the 

8 authorized construction and maintenance dredging activities. EFH Conservation 

9 Recommendations necessary to protect EFH may also be included in the Corps DA permit. 

10 Mitigation may only be employed after all appropriate and practical steps to avoid and minimize 

11 adverse impacts to aquatic resources have been taken. All remaining unavoidable impacts 

12 must be compensated to the extent appropriate and practicable. 

13 8.0 Conclusions 

14 The potential impacts of the construction and operation of the proposed Unit 3 at the Calvert 

15 Cliffs site on Federally managed species and their designated EFH near the site have been 

16 evaluated. The known distributions and records of those species, the potential adverse impacts 

17 of the construction and operation to the species, their habitat, and their prey have been 

18 considered in this EFH assessment. 

19 The disturbance created by the project, including sediment resuspension, would temporarily 

20 disturb EFH species in the area. Wave patterns and littoral drift patterns would be multi21 directionally deflected and interrupted by the proposed structures and stone revetment. The 

22 proposed project would reduce the benefits and habitat that open water areas provide. 

23 However, motile species can move out of the project area during project construction and are 

24 expected to return following completion of the project. Benthic repopulation is expected to occur 

25 and benthic communities usually recover quickly from the impacts associated with similar 

26 projects, where depths dredged to bottom contours are not markedly different from pre-dredge 

27 depths. The overall effects of the dredging on the ecosystem and EFH are temporary, and the 

28 area proposed to be dredged would continue to be similar depth habitat. The proposed project 

29 area could either revert to current depths if maintenance dredging is not conducted through the 

30 years, or the waterway ecosystem would adjust to the depth change in the waterway and reach 

31 an equilibrium, providing habitat for those fish and wildlife communities that develop with the 

32 changes in the waterway. 

33 Vessel traffic at the barge area is limited to the facility uses, and use of the channel may result 

34 in the discharge of small amounts of gas, oil, and grease from motors, as well as littering of the 

35 waterway with debris. It is expected that vessel traffic in the area and its associated pollution 

36 would increase due to improved access. The proposed depth increase would allow for larger 

37 vessels to navigate the waterway area, although access would be limited to vessels associated 

38 with the nuclear facility property. Increasing depths at the dredge site may reduce 

39 concentrations of dissolved oxygen available and reduce light penetration to the bottom, 

40 reducing photosynthesis opportunities. However, the proposed depths are similar to the 

Appendix F

Draft NUREG-1936 F-112 April 2010
1 existing waterway depths in the majority of the project area. Also, there is no SAV in the 

2 shallower depths closer to the shoreline. 

3 Mechanical dredging uses a crane and bucket to excavate and transfer bottom sediments to a 

4 barge for transport to the disposal area. Some dredged material and water can be lost from the 

5 bucket as it is raised and deposited into the barge. The amount of material re-entering the 

6 water column as it is transferred from the barge to trucks is considered to be de minimus. The 

7 suspended sediment levels are also expected to return to normal when the off-loading activities 

8 are terminated. No toxic substances in toxic amounts are expected to be in the dredged 

9 material. 

10 Water quality is expected to change. However, the alteration may not be considerably 

11 beneficial or detrimental. Dredging, structures, and stone revetment may not substantially 

12 improve water quality or offset other impacts to water quality. In general, the project and 

13 resultant uses may have impacts on water quality that may not be discernable from normal 

14 water quality fluctuations. 

15 The primary effect of operation of the proposed Unit 3 on EFH would be the removal of water 

16 from the Bay and the associated entrainment, impingement, and entrapment of water-dwelling 

17 biota. Entrainment and impingement by the cooling water system of the proposed new unit 

18 would be much less than that generated by existing Units 1 and 2. 

19 The NRC and the Corps have determined the construction and operation of the proposed Unit 3 

20 at the Calvert Cliffs site would have more than minimal, although not substantial, adverse effect 

21 on EFH within the Chesapeake Bay by loss of spawning, nursery, forage, and/or shelter habitat 

22 for all of the nine species considered. The NRC lacks the statutory authority to require any 

23 mitigation measures that would minimize adverse effects on EFH. The Corps does not 

24 recommend any mitigative measures to minimize adverse effects on EFH at this time. This 

25 determination may be modified if additional information indicates otherwise and would change 

26 the preliminary determination. 

27 9.0 References 

28 10 CFR Part 50. Code of Federal Regulations, Title 10, Energy, Part 50, “Domestic Licensing of 

29 Production and Utilization Facilities.” 

30 10 CFR Part 51. Code of Federal Regulations, Title 10, Energy, Part 51, “Environmental 

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

32 10 CFR Part 52. Code of Federal Regulations, Title 10, Energy, Part 52, “Licenses, 

33 Certifications, and Approvals for Nuclear Power Plants.” 

34 72 FR 57416. October 9, 2007. “Limited Work Authorizations for Nuclear Power Plants.” 

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

Appendix F

April 2010 F-113 Draft NUREG-1936
1 73 FR 8719. February 14, 2008. “UniStar Nuclear, LLC; Calvert Cliffs Partial Combined 

2 License Application; Notice of Intent to Prepare an Environmental Impact Statement and 

3 Conduct Scoping Process.” Federal Register. U.S. Nuclear Regulatory Commission. 

4 Abbe, G.R. 1987. “Thermal and Other Discharge-Related Effects on the Bay Ecosystem.” 

5 Chapter 9 in Ecological Studies in the Middle Reach of Chesapeake Bay, Calvert Cliffs. Editor 

6 K. L. Heck Jr., Springer-Verlag, New York. 

7 Atlantic States Marine Fisheries Commission (ASMFC). 2006a. “Species Profile: Bluefish Joint 

8 Plan Seeks to Restore Premier Fighting Fish.” ASMFC Fisheries Focus 15(4):1-2. 

9 Atlantic States Marine Fisheries Commission (ASMFC). 2006b. “Species Profile: Red Drum 

10 Amendment Seeks to Increase Recruitment and Protect Reproductive Adults.” ASMFC 

11 Fisheries Focus 15(1):1-3. 

12 Atlantic States Marine Fisheries Commission (ASMFC). 2007. “Species Profile: Summer 

13 Flounder Lawmakers and Managers Strive to Stay on Track with Species Rebuilding While 

14 Addressing Industry Concerns Summer Flounder Paralichthys dentatus.” ASMFC Fisheries 

15 Focus 16(2):1-3. 

16 Buchman, M.F. 2008. NOAA Screening Quick Reference Tables (SQuiRTs). NOAA Office of 

17 Response and Restoration Report 08-1, Seattle, Washington. 

18 Buckel, J.A., M.J. Fogarty, and D.O. Conover. 1999. “Foraging Habits of Bluefish, Pomatomus 

19 saltatrix, on the U.S. East Coast Continental Shelf.” Fishery Bulletin 97(4):758-775. 

20 Chang, S., P.L. Berrien, D.L. Johnson, and W.W. Morse. 1999. Essential Fish Habitat Source 

21 Document: Windowpane, Scophthalmus aquosus, Life History and Habitat Characteristics. 

22 NOAA Technical Memorandum NMFS-NE-137. Woods Hole, Massachusetts. 

23 Chesapeake Bay Program (CBP). 2007. Chesapeake Bay 2006 Health & Restoration 

24 Assessment Part One: Ecosystem Health. Accessed May 29, 2007 at 

25 http://www.chesapeakebay.net. 

26 Chesapeake Bay Program (CBP). 2009. Water Quality – Maps. Accessed September 1, 2009 

27 at http://www.chesapeakebay.net/maps.aspx?menuitem=15165. 

28 Clean Water Act. 33 U.S.C. 1251, et seq. (also referred to as the Federal Water Pollution 

29 Control Act [FWPCA]). 

30 COMAR 26.08.02.03-2. 2008. “Numerical Criteria for Toxic Substances in Surface Waters.” 

31 Code of Maryland Regulations. Accessed December 5, 2008 at 

32 http://www.dsd.state.md.us/comar/26/26.08.02.03-2.htm. 

33 Cox, D.L. and T.J. Koob. 1993. “Predation on Elasmobranch Eggs.” Environmental Biology of 

34 Fishes 38:117-12. 

Appendix F

Draft NUREG-1936 F-114 April 2010
1 Cross, J.N., C.A. Zetlin, P.L. Berrien, D.L. Johnson, and C. McBride. 1999. Essential Fish 

2 Habitat Source Document: Butterfish, Peprilus triacanthus, Life History and Habitat 

3 Characteristics. NOAA Technical Memorandum NMFS-NE-145. Woods Hole, Massachusetts. 

4 Doney, S.C., V.J. Fabry, R.A. Feely, and J.A. Kleypas. 2009. “Ocean Acidification: The Other 

5 CO2 Problem.” Annual Review of Marine Science 1:169-192. 

6 Drohan, A.F., J.P. Manderson, and D.B. Packer. 2007. Essential Fish Habitat Source 

7 Document: Black Sea Bass, Centropristis striata, Life History and Habitat Characteristics. 

8 Second Edition. NOAA Technical Memorandum NMFS-NE-200. Woods Hole, Massachusetts. 

9 EA Engineering Science and Technology Inc. (EA Engineering). 2007a. Aquatic Field Studies 

10 for UniStar Calvert Cliffs Expansion Project May 2007. Prepared for UniStar Nuclear 

11 Development, LLC by EA Engineering Science and Technology, Sparks, Maryland. 

12 EA Engineering Science and Technology Inc. (EA Engineering). 2007b. Submerged Aquatic 

13 Vegetation Surveys for UniStar Calvert Cliffs Expansion Project June 2007. Prepared for 

14 UniStar Nuclear Development, LLC by EA Engineering Science and Technology Sparks, 

15 Maryland. Accession No. ML100040305. 

16 Gibson, J.R. and R.G. Najjar. 2000. “The Response of Chesapeake Bay Salinity to Climate17 induced Changes in Streamflow.” Limnology and Oceanography 45:1764-1772. 

18 Greiner, J. and B. Vogt. 2009. Habitat and Research Activities to Protect and Restore 

19 Chesapeake Bay Living Resources and Water Quality. A Revised Report Fulfilling Section 

20 202g of Executive Order 13508. U.S. Department of the Interior and U.S. Department of 

21 Commerce. 

22 Harding, J.M. and R. Mann. 2001. “Diet and Habitat Use by Bluefish (Pomatomus saltatrix) in a 

23 Chesapeake Bay Estuary.” Environmental Biology of Fishes 60:401–409. 

24 Hartman, K.J. and S.B. Brandt. 1995. “Trophic Resource Partitioning, Diets, and Growth of 

25 Sympatric Estuarine Predators.” Transactions of the American Fisheries Society 124:520-537. 

26 Hendrickson, L. 2006. Windowpane flounder. Status of Fishery Resources off the 

27 Northeastern US. NEFSC–Resource Evaluation and Assessment Division. Accessed 

28 November 11, 2008 at 

29 http://www.nefsc.noaa.gov/sos/spsyn/fldrs/window/archives/12_WindowpaneFlounder_2006.pdf 

30 Jasinski, P and P. Claggett. 2009. Responding to Climate Change in the Chesapeake Bay 

31 Watershed: A draft report fulfilling Section 202(d) of Executive Order 13508. U.S. Department 

32 of Commerce and U.S. Department of the Interior. 

33 Kerns, T. 2006. Review of the Atlantic States Marine Fisheries Commission Fishery 

34 Management Plan for Black Sea Bass (Centropristis striata). Atlantic States Marine Fisheries 

35 Commission, Washington, D.C. 

Appendix F

April 2010 F-115 Draft NUREG-1936
1 Latour, R.J., J. Gartland, C.F. Bonzek, R.A. Johnson. 2008. “The Trophic Dynamics of 

2 Summer Flounder (Paralichthys dentatus) in Chesapeake Bay.” Fishery Bulletin 106:47-57. 

3 Link, J.S., K. Bolles, and C.G. Milliken. 2002. “The Feeding Ecology of Flatfish in the 

4 Northwest Atlantic.” Journal of Northwest Atlantic Fisheries Science 30:1-17. 

5 Llansó, R.J., J. Dew, and L.C. Scott. 2007. Chesapeake Bay Water Quality Monitoring 

6 Program, Long-Term Benthic Monitoring and Assessment Component, Level I Comprehensive 

7 Report, July 1984-December 2006 (Volume 2). Prepared by Versar, Inc., for Maryland 

8 Department of Natural Resources, Annapolis Maryland. 

9 Magnuson-Stevens Fishery Conservation and Management Act (MSFCMA). 16 U.S.C. 1801 et 

10 seq. 

11 Maryland Department of Natural Resources (MDNR). 2008. A Chesapeake Bay Fishery 

12 Management Update, Section 8. Bluefish. Accessed September 26, 2008 at 

13 http://www.dnr.state.md.us/fisheries/FMP/FMPBluefish04.pdf. Accession No. ML100480425. 

14 Maryland Department of Natural Resources (MDNR). 2009a. Fixed Station Monthly Monitoring 

15 Chesapeake Bay Mainstem – Cove Point (CB4.4). Water Temperature. Accessed October 1, 

16 2009 at http://mddnr.chesapeakebay.net/bay_cond/bay_cond.cfm?param=wt&station=CB44. 

17 Maryland Department of Natural Resources (MDNR). 2009b. Fixed Station Monthly Monitoring 

18 Chesapeake Bay Mainstem – Cove Point (CB4.4). Salinity. Accessed October 1, 2009 at 

19 http://mddnr.chesapeakebay.net/bay_cond/bay_cond.cfm?param=sal&station=CB44. 

20 Maryland Department of Natural Resources (MDNR). 2009c. Fixed Station Monthly Monitoring 

21 Chesapeake Bay Mainstem – Cove Point (CB4.4). Dissolved Oxygen. Accessed October 1, 

22 2009 at http://mddnr.chesapeakebay.net/bay_cond/bay_cond.cfm?param=bdo&station=CB44. 

23 Maryland Department of Natural Resources Power Plant Research Program (MDNR PPRP). 

24 2008a. Maryland Power Plants and the Environment. A review of the impacts of power plants 

25 and transmission lines on Maryland’s natural resources. Maryland Cumulative Environmental 

Impact Report — 14th 26 Edition. MDNR Publication No. 12-1142008-271. PPRP-CEIR-14. 

27 Maryland Department of Natural Resources Power Plant Research Program (MDNR PPRP). 

28 2008b. Environmental Review of Unit 3 at Calvert Cliffs Nuclear Power Plant. PSC Case No. 

29 9127. Maryland Power Plant Research (PPRP). 

30 McBride, M. 2006. Managed Fisheries of the Chesapeake Bay. In Fisheries ecosystem 

31 planning for Chesapeake Bay, Trends in Fisheries Management 3, American Fisheries Society, 

32 Bethesda, Maryland. 

33 Mid-Atlantic Power Pathway (MAPP). 2009a. Project Overview. Accessed June 26, 2009 at 

34 http://www.powerpathway.com/overview.html. 

Appendix F

Draft NUREG-1936 F-116 April 2010
1 Mid-Atlantic Power Pathway (MAPP). 2009b. Project Schedule. Accessed November 4, 2009 

2 at http://www.powerpathway.com/schedule.html. 

3 Mitrovica, J.X., N. Gomez, and P.U. Clark. 2009. “The Sea-Level Fingerprint of West Antarctic 

4 Collapse.” Science 323:753. 

5 Morse, W.W. and K.W. Able. 1995. “Distribution and Life History of Windowpane, 

6 Scophthalmus aquosus, off the Northeastern United States.” Fishery Bulletin 93:675-693. 

7 Murdy, E.O., R.S. Birdsong, and J.A. Musick. 1997. Fishes of the Chesapeake Bay. 

8 Smithsonian Institution Press, Washington, D.C. 

9 Najjar, R., L. Patterson, and S. Graham. 2009. “Climate Simulations of Major Estuarine 

10 Watersheds in the Mid-Atlantic Region of the US.” Climatic Change 95:139-168. 

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

12 National Marine Fisheries Service (NMFS). 2004. Essential Fish Habitat Consultation 

13 Guidance Version 1.1. Office of Habitat Conservation Silver Spring, Maryland. 

14 National Marine Fisheries Service (NMFS). 2008a. Summary of Essential Fish Habitat (EFH) 

15 Designations: Chesapeake Bay , Mainstem, Maryland / Virginia. Accessed June 27, 2008 at 

16 http://www.nero.noaa.gov/hcd/md1.html. Accession No. ML100710559. 

17 National Marine Fisheries Service (NMFS). 2008b. Summary of Essential Fish Habitat (EFH) 

18 Designations: Patuxent River, Maryland. Accessed June 27, 2008 at 

19 http://www.nero.noaa.gov/hcd/md5.html. Accession No. ML100710562. 

20 National Marine Fisheries Service (NMFS). 2009a. Essential Fish Habitat Designations for 

21 New England Skate Complex. Accessed January 13, 2009 at 

22 http://www.nero.noaa.gov/hcd/skateefhmaps.htm. Accession No. ML100710568. 

23 National Marine Fisheries Service (NMFS). 2009b. Essential Fish Habitat (EFH) for Black sea 

24 bass. Accessed January 13, 2009 at http://www.nero.noaa.gov/hcd/blackseabass.htm. 

25 Accession No. ML100710532. 

26 National Marine Fisheries Service (NMFS). 2009c. Essential Fish Habitat (EFH) for Bluefish. 

27 Accessed January 13, 2009 at http://www.nero.noaa.gov/hcd/bluefish.htm. Accession No. 

28 ML100710536. 

29 National Marine Fisheries Service (NMFS). 2009d. Essential Fish Habitat (EFH) for Butterfish. 

30 Accessed January 13, 2009 at http://www.nero.noaa.gov/hcd/butterfish.htm. Accession No. 

31 ML100710581. 

32 National Marine Fisheries Service (NMFS). 2009e. Essential Fish Habitat (EFH) for Red Drum. 

33 Accessed January 13, 2009 at http://www.nero.noaa.gov/hcd/reddrum.htm. Accession No. 

34 ML100710590. 

Appendix F

April 2010 F-117 Draft NUREG-1936
1 National Marine Fisheries Service (NMFS). 2009f. Essential Fish Habitat (EFH) for Summer 

2 Flounder. Accessed January 13, 2009 at http://www.nero.noaa.gov/hcd/summerflounder.htm. 

3 Accession No. ML100710597. 

4 National Oceanic and Atmospheric Administration (NOAA). 2005. 41st SAW Assessment 

5 Summary Report. Reference Document 05-10, Woods Hole, Massachusetts. 

6 New England Fishery Management Council (NEFMC). 1998. Final Amendment #11 to the 

7 Northeast Multispecies Fishery Management Plan, Amendment #9 to the Atlantic Sea Scallop 

8 Fishery Management Plan Amendment #1 to the Monkfish Fishery Management Plan, 

9 Amendment #1 to the Atlantic Salmon Fishery Management Plan, Components of the Proposed 

10 Atlantic Herring Fishery Management Plan for Essential Fish Habitat Incorporating the 

11 Environmental Assessment, Volume I. New England Fishery Management Council in 

12 consultation with National Marine Fisheries Service. Accessed November 11, 2008 at 

13 http://www.nefmc.org/habitat/index.html. 

14 Nichols, J. 2008. Summer Flounder Size Range. Personal Communication to Harriet Nash 

15 December 24, 2008. Accession No. ML093070050. 

16 Norcross, B.L. and D.M. Wyanski. 1994. “Interannual Variation in the Recruitment Pattern and 

17 Abundance of Age-0 Summer Flounder, Paralichthys dentatus, in Virginia estuaries.” Fishery 

18 Bulletin 92:591-598. 

19 Nygard, J. 2005. 2005 Review of the Atlantic States Marine Fisheries Commission Fishery 

20 Management Plan for Bluefish (Pomatomus saltatrix). Atlantic States Marine Fisheries 

21 Commission, Raleigh, North Carolina. 

22 Olson, M.M. 1987. “Entrainment Studies, Zooplankton Entrainment.” Chapter 7 in Ecological 

23 Studies in the Middle Reach of Chesapeake Bay, Calvert Cliffs, ed. K. L. Heck Jr., Springer24 Verlag, New York. 

25 Overholtz, W. 2006. Butterfish. Status of Fishery Resources off the Northeastern US. NEFSC 

26 - Resource Evaluation and Assessment Division. Accessed November 11, 2008 at 

27 http://www.nefsc.noaa.gov/sos/spsyn/op/butter/archives/24_Butterfish_2006.pdf. 

28 Packer, D.B., C.A. Zetlin, and J.J. Vitaliano. 2003a. Essential Fish Habitat Source Document: 

29 Clearnose Skate, Raja eglanteria, Life History and Habitat Characteristics. NOAA Technical 

30 Memorandum NMFS-NE-174. Woods Hole, Massachusetts. Accession No. ML072080214. 

31 Packer, D.B., C.A. Zetlin, and J.J. Vitaliano. 2003b. Essential Fish Habitat Source Document: 

32 Little Skate, Leucoraja erinacea, Life History and Habitat Characteristics. NOAA Technical 

33 Memorandum NMFS-NE-175. Woods Hole, Massachusetts. Accession No. ML072080217. 

34 Packer, D.B., C.A. Zetlin, and J.J. Vitaliano. 2003c. Essential Fish Habitat Source Document: 

35 Winter Skate, Leucoraja ocellata, Life History and Habitat Characteristics. NOAA Technical 

36 Memorandum NMFS-NE-179. Woods Hole, Massachusetts. Accession No. ML072070390. 

Appendix F

Draft NUREG-1936 F-118 April 2010
1 Pepco Holdings, Inc. (PHI). 2009. Pepco Holdings, Inc. & Maryland Broadband Cooperative 

2 Plan Single Chesapeake Bay Utility Crossing. News Release March 24, 2009. Available at 

3 http://www.delmarva.com/welcome/news/releases/archives/2009/article.aspx?cid=1138. 

4 Popper, A.N., T.J. Carlson, A.D. Hawkins, B.L. Southall, and R.L. Gentry. 2006. Interim Criteria 

5 for Injury of Fish Exposed to Pile Driving Operations: A White Paper. Accessed October 10, 

6 2008 at www.wsdot.wa.gov/NR/rdonlyres/84A6313A-9297-42C9-BFA6-

7 750A691E1DB3/0/BA_PileDrivingInterimCriteria.pdf. 

8 Ringger, T.G. 2000. “Investigations of Impingement of Aquatic Organisms at the Calvert Cliffs 

9 Nuclear Power Plant, 1975-1995.” Environmental Science & Policy 3 (Supplement 1): 261-273. 

10 Rivers and Harbors Appropriation Act of 1899. 33 U.S.C. 403 as amended. 

11 Rooker, J.R., S.A. Jolt, G.J. Holt, and L.A. Fuiman. 1999. “Spatial and Temporal Variability in 

12 Growth, Mortality, and Recruitment Potential of Postsettlement Red Drum (Sciaenops ocellatus) 

13 in a Subtropical Estuary.” Fishery Bulletin 97(3):581-590. 

14 Sackett, D.K., K.W. Able, and T.M. Grothues. 2007. “Dynamics of Summer Flounder 

15 (Paralichthys dentatus) Seasonal Migrations Based on Ultrasonic Telemetry.” Estuarine,

16 Coastal and Shelf Science 74:119-130. 

17 Scharf, F.S. and K. K. Schlicht. 2000. “Feeding Habits of Red Drum (Sciaenops ocellatus) in 

18 Galveston Bay, Texas Seasonal Diet Variation and Predator-Prey Size Relationships.” 

19 Estuaries 23:128-139. 

20 Sellner, K.G. and M.E. Kachur. 1987. “Entrainment Studies, Phytoplankton Entrainment.” 

21 Chapter 7 in Ecological Studies in the Middle Reach of Chesapeake Bay, Calvert Cliffs, ed. K. L. 

22 Heck Jr. Springer-Verlag, New York. 

23 Shepherd, G.R. and D.B. Packer. 2006. Essential Fish Habitat Source Document: Bluefish,

24 Pomatomus saltatrix, Life History and Habitat Characteristics, Second Edition. NOAA Technical 

25 Memorandum NMFS-NE-198. Woods Hole, Massachusetts. 

26 Sosebee, K. 2006. Skates. Status of Fishery Resources off the Northeastern US. NEFSC - 

27 Resource Evaluation and Assessment Division. Accessed November 11, 2008 at 

28 http://www.nefsc.noaa.gov/sos/spsyn/op/skate/archives/27_Skates_2006.pdf. 

29 Teng, H. L.E. Buja, and G.A. Meehl. 2006. “Twenty-first-century climate change commitment 

30 from a multi-model ensemble.” Geophysical Research Letters 33:L07706, 

31 doi:10.1029/2005GL024766. 

32 Terceiro, M. 2006. Summer Flounder Assessment and Biological Reference Point Update for 

33 2006. National Oceanic and Atmospheric Administration, Woods Hole, Massachusetts. 

Appendix F

April 2010 F-119 Draft NUREG-1936
1 UniStar Nuclear Energy (UniStar). 2008a. Letter from George Vanderheyden (UniStar) to NRC 

2 dated June 12, 2008, “Subject: UniStar Nuclear Energy, NRC Docket No. 52-016, Submittal of 

3 Response to Requests for Additional Information for the Calvert Cliffs Nuclear Power Plant, Unit 

4 3 and Request for Withholding of Documents.” NRC’s Request for Additional Information dated 

5 May 13, 2008. Accession No. ML100040300. 

6 UniStar Nuclear Development, LLC (UniStar). 2008b. Letter from Greg Gibson (UniStar) to 

7 U.S. Nuclear Regulatory Commission dated September 29, 2008 in response to NRC letters 

8 dated May 13, 2008, June 12, 2008, and August 29, 2008, “Subject: UniStar Nuclear Energy, 

9 NRC Docket No. 52-016, Submittal of Response Requests for Additional Information for the 

10 Calvert Cliffs Nuclear Power Plant, Unit 3 – Supplemental Aquatic RAIs.” Accession No. 

11 ML082760508. 

12 UniStar Nuclear Development, LLC (UniStar). 2008c. Letter from Greg Gibson (UniStar) to 

13 U.S. Nuclear Regulatory Commission dated October 31, 2008 in response to NRC letter dated 

14 October 14, 2008, “Subject: UniStar Nuclear Energy, NRC Docket No. 52-016, Calvert Cliffs 

15 Nuclear Power Plant, Unit 3, Submittal of Response to Requests for Additional Information, 

16 Environmental Impact Statement (EIS) Issues.” Accession No. ML083110676. 

17 UniStar Nuclear Development, LLC (UniStar). 2008d. Letter from Dimitri Lutchenkov (UniStar) 

18 to U.S. Army Corps of Engineers dated November 11, 2008 in response to Corps letter dated 

19 October 28, 2008, “Subject: Joint Federal/State Application of Calvert Cliffs 3 Nuclear Project, 

20 LLC and UniStar Nuclear Operating Services, LLC, Calvert Cliffs Nuclear Power Plant Site, 

21 Lusby, Calvert County, Maryland, USACE Tracking No. NAB-2007-08123-M05.” Accession No. 

22 ML091530687. 

23 UniStar Nuclear Development, LLC (UniStar). 2009a. Calvert Cliffs Nuclear Power Plant Unit 3 

24 Combined License Application, Part 3, Environmental Report. Revision 6. UniStar, Baltimore, 

25 Maryland. Accession No. ML092880921. 

26 UniStar Nuclear Development, LLC (UniStar). 2009b. Letter from Greg Gibson (UniStar) to 

27 U.S. Nuclear Regulatory Commission dated March 5, 2009. “Subject: UniStar Nuclear Energy, 

28 NRC Docket No. 52-016, Calvert Cliffs Nuclear Power Plant, Unit 3, Environmental RAIs No. 

29 1001 through 1011.” In response to NRC’s Request for Additional Information dated 

30 February 3, 2009. Accession No. ML090710146. 

31 UniStar Nuclear Development, LLC (UniStar). 2009c. Letter from Greg Gibson (UniStar) to 

32 U.S. Nuclear Regulatory Commission dated July 24, 2009. “Subject: UniStar Nuclear Energy, 

33 NRC Docket No. 52-016, Calvert Cliffs Nuclear Power Plant, Unit 3, Follow-up Responses to 

34 Environmental Report RAI NO.1 003-2, Aquatic Ecology and RAI NO.1 008-4, Ecological 

35 Impacts (Fish Return System).” In response to NRC’s Request for Additional Information dated 

36 February 3, 2009. Accession No. ML092150721. 

Appendix F

Draft NUREG-1936 F-120 April 2010
1 UniStar Nuclear Development, LLC (UniStar). 2009d. Letter from Greg Gibson (UniStar) to 

2 U.S. Nuclear Regulatory Commission dated July 29, 2009. “Subject: UniStar Nuclear Energy, 

3 NRC Docket No. 52-016, Calvert Cliffs Nuclear Power Plant, Unit 3, Follow-up Response to 

4 Requests for Additional Information Nos. 1001-14 and 1008-6.” In response to NRC’s Request 

5 for Additional Information dated February 3, 2009. Accession No. ML092120061. 

6 U.S. Army Corps of Engineers (USACE). 2008. Public Notice in Reply to Application Number 

7 CENAB-OP-RMS NAB-2007-01823-M05 (Calvert Cliff’s 3 Nuclear Project, LLC/Unistar Nuclear 

8 Operating Services, LLC). September 3, 2008. Accession No. ML082550288. 

9 U.S. Army Corps of Engineers (USACE). 2009. Public Notice. Application Number CENAB10 OP-RMS(NAB-2008-01241-M05 (2008-61276) (Dominion Cove Point LNG/Pier Reinforcement 

11 Project). PN-09-20. May 19, 2009. 

12 U.S. Nuclear Regulatory Commission (NRC). 2000. Calvert Cliffs Nuclear Power Plant, Units 1 

13 and 2 – Renewal of Operating License. Accessed at http://www.nrc.gov/reading-rm/doc14 collections/commission/secys/2000/secy2000-0010/2000-0010scy.html. 

15 U.S. Nuclear Regulatory Commission (NRC). 2005. Event Notification Report for July 18, 

16 2005. Calvert Cliffs Nuclear Power Plant Impingement Incidents Event Number: 41845. 

17 Available at http://www.nrc.gov/reading-rm/doc-collections/event18 status/event/2005/20050718en.html. 

19 

20 U.S. Nuclear Regulatory Commission (NRC). 2006a. Event Notification Report for July 12, 

21 2006. Calvert Cliffs Nuclear Power Plant Impingement Incidents Event Numbers: 42700. 

22 Available at http://www.nrc.gov/reading-rm/doc-collections/event23 status/event/2006/20060712en.html. 

24 

25 U.S. Nuclear Regulatory Commission (NRC). 2006b. Event Notification Report for August 16, 

26 2006. Calvert Cliffs Nuclear Power Plant Impingement Incidents Event Number: 42776. 

27 Available at http://www.nrc.gov/reading-rm/doc-collections/event28 status/event/2006/20060816en.html. 

29 U.S. Nuclear Regulatory Commission (NRC). 2009. Letter from D. Pickett (NRC) to J. Spina 

30 (Calvert Cliffs Nuclear Power Plant, Inc.), Subject: Calvert Cliffs, Units 1 & 2, Amendment 

31 Regarding Measurement Uncertainty Recapture Power Uprate,” July 22, 2009. Accession No. 

32 ML091820366. 

33 Wicks, C.,D. Jasinski, and B. Longstaff. 2007. Breath of Life: Dissolved Oxygen in 

34 Chesapeake Bay. Newsletter prepared for Chesapeake EcoCheck, Assessing and Forecasting 

35 Ecosystem Status. Available at 

36 http://www.chesapeakebay.net/dissolvedoxygen.aspx?menuitem=14654. 

37 Wood, R.J., D.F. Boesch, and V.S. Kennedy. 2002. “Future consequences of climate change 

38 for the Chesapeake Bay Ecosystem and its Fisheries.” American Fisheries Society Symposium

39 32:171-184. 

Appendix F

April 2010 F-121 Draft NUREG-1936
1 Wu, S-Y., R. Najjar, and J. Siewert. 2009. “Potential Impacts of Sea-level Rise on the Mid- and 

2 Upper-Atlantic Region of the United States.” Climatic Change 95:121–138. 

3 

Appendix F

Draft NUREG-1936 F-122 April 2010
Appendix G 

Supporting Documentation on Radiological Dose 

Assessment 

April 2010 G-1 Draft NUREG-1936 

Appendix G 

Supporting Documentation on Radiological Dose 

Assessment 

1 The U.S. Nuclear Regulatory Commission (NRC) staff performed an independent dose 

2 assessment of the radiological impacts resulting from normal operation of the new and existing 

3 nuclear units at and near the Calvert Cliffs Nuclear Power Plant (CCNPP). The results of this 

4 assessment are presented in this appendix and are compared to the results from UniStar found 

5 in Section 5.9 of this EIS, Radiological Impacts of Normal Operations. The appendix is divided 

6 into four sections: (1) dose estimates to the public from liquid effluents, (2) dose estimates to 

7 the public from gaseous effluents, (3) cumulative dose estimates, and (4) dose estimates to the 

8 biota from liquid and gaseous effluents. 

9 G.1 Dose Estimates to the Public from Liquid Effluents 

10 The staff used the dose assessment approach specified in Regulatory Guide 1.109 (NRC 1977) 

11 and the LADTAP II computer code (Strenge et al. 1986) to estimate doses to the maximally 

12 exposed individual (MEI) and population from the liquid effluent pathway of the proposed Unit 3. 

13 The staff used the annual radioactive effluent release reports for the years 2000 to 2006 to 

14 estimate doses to the MEI and population from liquid effluent releases from the existing CCNPP 

15 units (Constellation 2001, 2002, 2003, 2004, 2005, 2006, 2007). 

16 G.1.1 Scope 

17 Doses from the proposed Unit 3 to the MEI were calculated and compared to regulatory criteria 

18 for the following: 

19 • Total Body – Dose was the total for all pathways (i.e., drinking water, fish and shellfish 

20 consumption, shoreline usage, swimming exposure, boating) with the highest value for 

21 either the adult, teen, child, or infant compared to the 0.03 mSv/yr (3 mrem/yr) per reactor 

22 dose design objective in Title 10 of the Code of Federal Regulations (CFR), Part 50, 

23 Appendix I. 

24 • Organ – Dose was the total for each organ for all pathways (i.e., drinking water, fish and 

25 shellfish consumption, shoreline usage, swimming exposure, boating) with the highest value 

26 for either the adult, teen, child, or infant compared to the 0.1 mSv/yr (10 mrem/yr) per 

27 reactor dose design objective specified in 10 CFR Part 50, Appendix I. 
Appendix G 

Draft NUREG-1936 G-2 April 2010 

1 The staff reviewed the exposure pathways and the input parameters and values used by 

2 UniStar (2009) for appropriateness, including references made to the AREVA NP, Inc. (AREVA) 

3 U.S. EPR design certification document (AREVA 2007). Default values from Regulatory Guide 

4 1.109 (NRC 1977) were used when site-specific input parameters were not available from 

5 UniStar. The staff concluded that the assumed exposure pathways were conservative in that 

6 the Chesapeake Bay is not a source for irrigation or drinking water (except for ship borne 

7 desalination facilities). 

8 G.1.2 Resources Used 

9 To calculate doses to the public from liquid effluents, the staff used a personal computer version of 

10 the LADTAP II code entitled NRCDOSE, Version 2.3.10 (Chesapeake Nuclear Services, Inc. 2008) 

11 obtained through the Oak Ridge Radiation Safety Information Computational Center (RSICC). 

12 G.1.3 Input Parameters 

13 Table G-1 provides a listing of the major parameters used in calculating dose to the public from 

14 liquid effluent releases during normal operation. 

15 G.1.4 Comparison of Results 

16 Table G-2 presents a comparison of UniStar’s results for a single new unit with those 

17 determined by the staff. Doses calculated for the MEI and population were similar to those 

18 developed by UniStar. 

19 For calculating the population dose from liquid effluents, the population distribution used by 

20 UniStar was for year 2080, 10 years beyond the anticipated operating license. However, 

21 Environmental Standard Review Plan (ESRP) Section 5.4.1 (NRC 2000) instructs the NRC staff to 

22 use the “...projected population for 5 years from the time of the licensing action under 

23 consideration.” Assuming the combined license (COL) licensing action occurs in year 2010 and 

24 adding 5 years yields year 2015, so the NRC staff considered using the population for 2015 in its 

25 analysis. Using the population projections from Environmental Report (ER) Table 2.5-10 (UniStar 

26 2009) (summarized in Table G-3) yields a population estimate for the year 2015 of 3,676,123. 

27 This is significantly smaller than the 2080 projected population (8,124,000), so the doses 

28 calculated by UniStar are conservatively high. For comparability, the NRC staff also used 2080 

29 population. Doses for the year 2015 would be a factor of 2.2 less than those reported below. 

30 The staff concurs with the conclusion documented in the ER that the peak MEI and population 

31 doses from the existing unit liquid effluent pathway during the period 2002 to 2006 occurred in 

32 year 2002. The NRC staff reviewed the annual radioactive effluent release reports for the years 

33 2002 to 2006 (Constellation 2003, 2004, 2005, 2006, 2007) to find the peak occurred in year 

34 2002. The staff’s review of the 2002 annual report (Constellation 2003) yielded results 

35 equivalent to those reported in Tables 4.5-2 and 5.4-14 of UniStar’s ER (UniStar 2009). 
Appendix G 

April 2010 G-3 Draft NUREG-1936 

1 Table G-1. Parameters Used in Calculating Dose to the Public from Liquid Effluent Releases 

Parameter Staff Value Comments 

New unit liquid effluent source 

term (Ci/yr)(a)

H-3 

Na-24 

Cr-51 

Mn-54 

Fe-55 

Fe-59 

Co-58 

Co-60 

Zn-65 

W-187 

Np-239 

Sr-89 

Sr-91 

Y-91m 

Y-93 

Zr-95 

Nb-95 

Mo-99 

Tc-99m 

Ru-103 

Ru-106 

Ag-110m 

Te-129m 

Te-129 

Te-131m 

Te-131 

I-131 

Te-132 

I-132 

I-133 

Cs-134 

I-135 

Cs-136 

Cs-137 

Ba-140 

La-140 

Ce-141 

Ce-143 

Ce-144 

Pr-144 

1.66 × 103 

6.10 × 10−3 

1.00 × 10−3 

5.40 × 10−4 

4.10 × 10−4

1.00 × 10−4 

1.50 × 10−3 

1.80 × 10−4 

1.70 × 10−4 

4.60 × 10−4 

5.80 × 10−4 

5.00 × 10−5 

8.00 × 10−5 

5.00 × 10−5 

3.60 × 10−4 

1.30 × 10−4 

1.00 × 10−4 

1.80 × 10−3 

1.70 × 10−3 

2.50 × 10−3 

3.10 × 10−2 

4.40 × 10−4 

6.00 × 10−5 

4.00 × 10−5 

3.10 × 10−4 

6.00 × 10−5 

3.40 × 10−2 

4.80 × 10−4 

1.20 × 10−3 

3.50 × 10−2 

2.60 × 10−3 

1.50 × 10−2 

3.10 × 10−4 

3.50 × 10−3 

4.20 × 10−3 

7.60 × 10−3 

5.00 × 10−5 

6.10 × 10−4 

1.30 × 10−3 

1.30 × 10−3 

Values from AREVA U.S. EPR Design 

Control Document Table 11.2-4 for a 

single unit (AREVA 2007). These 

values are the same as those reported 

in ER Table 3.5-7 (UniStar 2009). 
Appendix G 

Draft NUREG-1936 G-4 April 2010 

1 

Table G-1. (contd) 

Parameter Staff Value Comments 

Discharge flow rate (ft3/s) 100 Site-specific value from Table 5.4-1 of 

the ER (UniStar 2009). 

Source term multiplier 1 Single-unit source term. 

Site type Saltwater Discharge is to the saltwater 

Chesapeake Bay. 

Reconcentration model No impoundment Site-specific value from Table 5.4-1 of 

the ER (UniStar 2009). 

Impoundment total volume (ft3

) 0 Set to zero for “no impoundment” 

model (Strenge et al. 1986). 

Shore width factor 1.0 Suggested value for tidal basin (NRC 

1977; Strenge et al. 1986; UniStar 

2009). 

Dilution factors for aquatic food 

and boating, shoreline and 

swimming, and drinking water 

365 Site-specific value from Table 5.4-1 of 

the ER (UniStar 2009). 

Transit time (hr) 0 Site-specific value from Table 5.4-1 of 

the ER (UniStar 2009). 

Consumption and usage factors 

for adults, teens, children, and 

infants 

Shoreline and Boating 

usage (hr/yr) 

 200 (adult) 

 200 (teen) 

 200 (child) 

 200 (infant) 

Swimming usage (hr/yr) 

 100 (adult) 

 100 (teen) 

 100 (child) 

 100 (infant) 

Drinking water usage 

(L/yr) 

 730 (adult) 

 510 (teen) 

 510 (child) 

 330 (infant) 

Fish consumption (kg/yr) 

 21 (adult) 

 16 (teen) 

 6.9 (child) 

 0 (infant)

Site-specific values from Table 5.4-2 

of the ER (UniStar 2009) and LADTAP 

II code default values (NRC 1977; 

Strenge et al. 1986). 

MEI drinking water assumes water is 

desalinated by shipborne water 

treatment facilities. 

Total 50-mi population 8,124,000 Site-specific value from Table 11.2-9 

of the FSAR (AREVA 2007). 

Total 50-mi sport fishing harvest 

(kg/yr) 

1,290,000 Site-specific value from Table 5.4-1 of 

the ER (UniStar 2009). 
Appendix G 

April 2010 G-5 Draft NUREG-1936 

Table G-1. (contd) 

Parameter Staff Value Comments 

Total 50-mi sport invertebrate 

harvest (kg/yr) 

1,580,000 Site-specific value from Table 5.4-1 of 

the ER (UniStar 2009). 

Total 50-mi commercial fishing 

harvest (kg/yr) 

152,200,000 Site-specific value from Table 5.4-1 of 

the ER (UniStar 2009). 

Total 50-mi commercial 

invertebrate harvest (kg/yr) 

26,400,000 Site-specific value from Table 5.4-1 of 

the ER (UniStar 2009). 

Total 50-mi shoreline usage 

(person-hr/yr) 

37,843,909 Site-specific value from Table 5.4-1 of 

the ER (UniStar 2009). 

Total 50-mi swimming usage 

(person-hr/yr) 

30,133,372 Site-specific value from Table 5.4-1 of 

the ER (UniStar 2009). 

Total 50-mi boating usage 

(person-hr/yr) 

44,285,377 Site-specific value from Table 5.4-1 of 

the ER (UniStar 2009). 

(a) Only radionuclides included in Regulatory Guide 1.109 are considered (NRC 1977). 

1 Table G-2. Comparison of Doses to the Public from Liquid Effluent Releases for a New Unit

Type of Dose(a) UniStar ER (2009)(a) Staff Calculation 

Percent 

Difference 

Total Body (mrem/yr) 0.0140 (adult) 0.0140 (adult) 0.0 

Organ Dose (mrem/yr) 0.0902 (adult GI-LLI) 0.0902 (adult GI-LLI) 0.0 

Thyroid (mrem/yr) 0.0787 (child) 0.0787 (child) 0.0 

Population dose from liquid 

pathway (person-rem/yr) 

0.186 0.186 0.0 

(a) Results from UniStar ER Tables 5.4-7, 5.4-8 and 5.4-9 (UniStar 2009). 

2 
Draft NUREG-1936 G-6 April 2010 

Appendix G Table G-3. Population Projections from 2000 to 2080 within 50 mi of the Calvert Cliffs Site 1 

Population Projections within Radii/Distances mi 

Year 0 to 10 mi (a) 10 to 20 mi 20 to 30 mi 30 to 50 mi 30 to 40 mi 40 to 50 mi 0 to 50 mi (d)

Annual Average Percent Change for the 10-Year Period 

2000(b) 48,755 112,841 162,006 2,886,668 618,907 2,267,761 3,210,270 NA 

2010(c) 57,937 139,384 189,097 3,116,981 683,019 2,433,962 3,503,399 0.91% 

2015(c) 63,441 155,687 204,844 3,252,151 719,341 2,532,810 3,676,123 NA 

2020(c) 69,504 174,040 222,222 3,395,683 757,969 2,637,714 3,861,449 1.02% 

2030(c) 83,129 216,740 263,498 3,729,663 845,378 2,884,285 4,293,030 1.12% 2040(c) 99,840 271,210 314,001 4,122,037 947,388 3,174,649 4,807,088 1.20% 2050(c) 120,508 340,666 376,926 4,586,827 1,062,906 3,523,921 5,424,927 1.29% 

2060(c) 145,458 428,351 454,445 5,134,257 1,200,670 3,933,587 6,162,511 1.36% 

2080(e) 215,332 683,900 672,100 6,553,000 1,550,000 5,003,000 8,124,000 1.39% 

(a) Population estimates and projections include transient and residential population in the 0 to 10 mi range. (b) Residential population in 2000, U.S. Census Bureau, Decennial Census. (c) The populations for years 2010 through 2060 have been projected by calculating a growth rate using state population projections (by 

county) as the base. 

(d) Transient population is only included in the 0 to 10 mi distribution. (e) Population used in GASPAR II Population runs (UniStar 2009). 
Appendix G 

April 2010 G-7 Draft NUREG-1936 

1 G.2 Dose Estimates to the Public from Gaseous Effluents 

2 The staff used the dose assessment approach specified in Regulatory Guide 1.109 (NRC 1977) 

3 and the GASPAR II computer code (Strenge et al. 1987) to estimate doses to the MEI and to 

4 the population within a 50-mi radius of the proposed Unit 3 site from the gaseous effluent 

5 pathway for both the proposed and existing units. 

6 G.2.1 Scope 

7 The staff and UniStar calculated the maximum gamma air dose, beta air dose, total body dose, 

8 and skin dose from noble gases at the exclusion area boundary location 0.86 mi south of the 

9 proposed Unit 3 site. Dose to the MEI was calculated at 0.88 mi SE of the site for the following 

10 exposure pathways: plume immersion, direct shine from deposited radionuclides, inhalation, 

11 ingestion of local farm or garden vegetables, and ingestion of locally produced beef. The milk 

12 ingestion pathway is not considered because there are no known milk cows within 5 mi of the 

13 Unit 3 site (UniStar 2009). 

14 The staff reviewed the input parameters and values used by UniStar (2009) for appropriateness, 

15 including references made to the AREVA U.S. EPR design control document (2007). Default 

16 values from Regulatory Guide 1.109 (NRC 1977) were used when input parameters were not 

17 available. The staff concluded that the assumed exposure pathways and input parameters and 

18 values used by UniStar were appropriate. These pathways and parameters were used by the 

19 staff in its independent calculations using GASPAR II. 

20 Joint frequency distribution data of wind speed and wind direction by atmospheric stability class 

21 for the Unit 3 site provided in Table 2.7-42 of the ER (UniStar 2009) were used as input to the 

22 XOQDOQ code (Sagendorf et al. 1982) to calculate long-term average χ/Q and D/Q values for 

23 routine releases. The staff’s independent results compare favorably to those reported in ER 

24 Tables 2.7-101 to 2.7-104 (UniStar 2009). 

25 Population doses were calculated for all types of releases (e.g., noble gases, iodines and 

26 particulates, and H-3 and C-14) using the GASPAR II code for the following exposure pathways: 

27 plume immersion, direct shine from deposited radionuclides, ingestion of vegetables, and 

28 ingestion of milk and meat. 

29 G.2.2 Resources Used 

30 To calculate doses to the public from gaseous effluents, the staff used a personal computer 

31 version of the XOQDOQ and GASPAR II codes entitled NRCDOSE Version 2.3.10 

32 (Chesapeake Nuclear Services, Inc. 2008) obtained through the Oak Ridge RSICC. 
Appendix G 

Draft NUREG-1936 G-8 April 2010 

1 G.2.3 Input Parameters 

2 Table G-4 provides a listing of the major parameters used in calculating dose to the public from 

3 gaseous effluent releases during normal operation. 

4 Table G-4. Parameters Used in Calculating Dose to Public from Gaseous Effluent Releases

Parameter Staff Value Comments 

New unit gaseous effluent 

source term (Ci/yr)(a)

Ar-41 

Kr-85m 

Kr-85 

Kr-87 

Kr-88 

Xe-131m 

Xe-133m 

Xe-133 

Xe-135m 

Xe-135 

Xe-138 

I-131 

I-133 

H-3 

C-14 

Cr-51 

Mn-54 

Co-57 

Co-58 

Co-60 

Fe-59 

Sr-89 

Sr-90 

Zr-95 

Nb-95 

Ru-103 

Ru-106 

Sb-125 

Cs-134 

Cs-136 

Cs-137 

Ba-140 

Ce-141 

3.4 × 101 

1.5 × 102 

3.4 × 104 

5.3 × 101 

1.8 × 102 

3.5 × 103 

1.8 × 102 

8.6 × 103 

1.4 × 101 

1.2 × 103 

1.2 × 101 

8.8 × 10−3 

3.2 × 10−2 

1.8 × 102 

7.3 × 100 

9.7 × 10−5 

5.7 × 10−5

8.2 × 10−6 

4.8 × 10−4 

1.1 × 10−4 

2.8 × 10−5 

1.6 × 10−4 

6.3 × 10−5 

1.0 × 10−5 

4.2 × 10−5 

1.7 × 10−5 

7.8 × 10−7 

6.1 × 10−7 

4.8 × 10−5 

3.3 × 10−5 

9.0 × 10−5 

4.2 × 10−6 

1.3 × 10−5

Values from AREVA U.S. EPR 

Design Control Document 

Table 11.3--3 (AREVA 2007). Except 

for rounding differences, these values 

are the same as those reported in ER 

Table 3.5-8 (UniStar 2009). 
Appendix G 

April 2010 G-9 Draft NUREG-1936 

1 

Table G-4. (contd) 

Parameter Staff Value Comments 

Existing Units 1 and 2 gaseous 

effluent source term (Ci/yr)(a)

H-3 

Ar-41 

Co-58 

Co-60 

Kr-85m 

Kr-85 

Sr-89 

Sr-90 

Xe-131m 

Xe-133m 

Xe-133 

Xe-135 

I-133 

I-131 

4.79 × 10+0 

2.72 × 10−3 

8.99 × 10−6 

7.19 × 10−6 

8.60 × 10−2 

1.88 × 10+2 

9.08 × 10−9 

ND 

1.51 × 10+1 

6.49 × 10+0 

2.58 × 10+2 

2.67 × 10+1 

2.32 × 10−2 

3.28 × 10−2 

Values from 2006 annual radioactive 

effluent release report Table 4.5-7 

(UniStar 2009) and Table 1C 

(Constellation 2007). 

Population distribution Table 2.5-10 of the ER 

(UniStar 2009) 

Population distribution used by 

UniStar and the NRC staff was for 

year 2080. Note that ESRP 

Section 5.4.1 requires use of 

“projected population for 5 years from 

the time of the licensing action under 

consideration.” Assuming the ESP 

licensing action occurs in year 2010 

and adding 5 years yields year 2015. 

See discussion of population dose in 

Section G.2.5. 

Wind speed and direction 

distribution 

Table 2.7-42 of the ER 

(UniStar 2009) 

Site-specific data provided by UniStar 

for 5-year period from 2000 to 2005. 

Atmospheric dispersion factors 

(s/m3

) 

Tables 2.7-99 to 2.7-110 

of the ER (UniStar 2009) 

Site-specific data provided by UniStar 

for 5-year period from 2000 to 2005. 

Ground deposition factors (m-2) Tables 2.7-111 to 2.7-114 

of the ER (UniStar 2009) 

Site-specific data provided by UniStar 

for 5-year period from 2000 to 2005. 

Milk production rate within a 

50-mi radius of the Calvert Cliffs 

site (kg/yr) 

2.34 × 10+8 Site-specific data provided by UniStar 

(2009). 

Vegetable/fruit production rate 

within a 50-mi radius of the 

Calvert Cliffs site (kg/yr) 

5.62 × 10+11 Site-specific data provided by UniStar 

(2009). 
Appendix G 

Draft NUREG-1936 G-10 April 2010 

Table G-4. (contd) 

Parameter Staff Value Comments 

Meat production rate within a 

50-mi radius of the Calvert Cliffs 

site (kg/yr) 

3.58 × 10+7 Site-specific data provided by UniStar 

(2009). 

Pathway receptor locations 

(direction, distance, and 

atmospheric dispersion factors) - 

nearest site boundary, vegetable 

garden, residence, meat animal 

Table 5.4-6 and Tables 

2.7-105 to 2.7-107 of the 

ER (UniStar 2009) 

Site-specific data provided by UniStar 

(2009). 

Consumption factors for milk, 

meat, leafy vegetables, and 

vegetables 

Milk (L/yr) 

 310 (adult) 

 400 (teen) 

 330 (child) 

 330 (infant) 

Meat (kg/yr) 

 110 (adult) 

 65 (teen) 

 41 (child) 

 0 (infant) 

Leafy vegetables (kg/yr) 

 64 (adult) 

 42 (teen) 

 26 (child) 

 0 (infant) 

Vegetables (kg/yr) 

 520 (adult) 

 630 (teen) 

 520 (child) 

 0 (infant) 

Table 5.4-5 of the ER (UniStar 2009) 

and Regulatory Guide 1.109 (NRC 

1977). 

Fraction of year leafy vegetables 

are grown 

0.58 Site-specific value from Table 5.4-4 of 

the ER (UniStar 2009). 

Fraction of year that milk cows 

are on pasture 

0.58 Site-specific value from Table 5.4-4 of 

the ER (UniStar 2009). 

Fraction of MEI vegetable intake 

from own garden 

0.76 Default value of GASPAR II code 

(Strenge et al. 1987). 

Fraction of milk-cow intake that 

is from pasture while on pasture 

1 Default value of GASPAR II code 

(Strenge et al. 1987). 
Appendix G 

April 2010 G-11 Draft NUREG-1936 

Table G-4. (contd) 

Parameter Staff Value Comments 

Average absolute humidity over 

the growing season (g/m3

) 

8.4 Site-specific value from Table 5.4-4 of 

the ER (UniStar 2009). 

Average temperature over the 

growing season (̊F) 

66.8 Site-specific value from Table 5.4-4 of 

the ER (UniStar 2009). 

Fraction of year beef cattle are 

on pasture 

0.58 Site-specific value from Table 5.4-4 of 

the ER (UniStar 2009). 

Fraction of year beef cattle 

intake that is from pasture while 

on pasture 

1 Default value of GASPAR II code 

(Strenge et al. 1987). 

(a) To convert Ci/yr to Bq/yr, multiply the value by 3.7 × 1010. 

1 G.2.4 Comparison of Doses to the Public from Gaseous Effluent Releases 

2 Table G-5 compares results documented in the ER (UniStar 2009) for doses from noble gases 

3 at the exclusion area boundary with the results calculated by the NRC staff. The doses 

4 provided by UniStar and those calculated by the NRC were similar. 

5 Table G-6 presents doses to the MEI calculated by UniStar and the staff. Doses to the MEI 

6 were calculated at the nearest residence, nearest garden, and nearest beef cattle. The doses 

7 estimated by UniStar and those calculated by the NRC staff were similar. 

8 Table G-5. Comparison of Doses to the Public from Noble Gas Releases for a New Unit 

Type of Dose 

UniStar ER 

(2008) (a)

Staff 

Calculation 

Percent 

Difference 

Gamma air dose at exclusion area boundary 

– noble gases only (mrad/yr) 

0.34 0.35 2.9 

Beta air dose at exclusion area boundary – 

noble gases only (mrad/yr) 

2.8 2.9 3.6 

Total body dose at exclusion area boundary – 

noble gases only (mrem/yr) 

0.215 0.22 2.3 

Skin dose at exclusion area boundary – noble 

gases only (mrem/yr) 

2.05 2.1 2.4 

(a) Results from UniStar ER Table 5.4-12 (UniStar 2009). 
Appendix G 

Draft NUREG-1936 G-12 April 2010 

1 Table G-6. Comparison of Doses to the MEI from Gaseous Effluent Releases for a New Unit 

Location Pathway 

Total Body Dose 

(mrem/yr) 

Bone Dose 

(mrem/yr) 

Skin Dose 

(mrem/yr) 

Nearest residence, 

0.88 mi southeast 

Plume 0.214 0.214 2.05 

Nearest residence, 

0.88 mi Southeast 

Ground 0.00149 0.00149 0.00174 

Nearest residence, 

0.88 mi southeast 

Inhalation 

Adult 

Teen 

Child 

Infant 

0.00413 

0.00436 

0.00385 

0.00222 

7.36 × 10–5 

8.98 × 10–5

1.10 × 10–4

5.76 × 10–5

0.00430 

0.00434 

0.00383 

0.00220 

Nearest garden, 1.33 mi 

south southeast 

Vegetable 

Adult 

Teen 

Child 

0.0234 

0.0371 

0.0863 

0.107 

0.176 

0.422 

0.0229 

0.0362 

0.0853 

Nearest meat animal, 

0.88 mi southeast 

Meat 

Adult 

Teen 

Child 

0.0174 

0.0144 

0.0267 

0.0818 

0.0691 

0.130 

0.0172 

0.0144 

0.0267 

2 G.2.5 Comparison of Results – Population Doses 

3 Table G-7 compares the UniStar population dose estimates taken from Table 5.4-13 of the ER 

4 (UniStar 2009) with the NRC staff estimates for the new unit. The staff’s independent 

5 calculation for population dose yields results that are comparable to the UniStar ER estimates 

6 for the proposed Unit 3. Both UniStar and the NRC staff used the population estimate for the 

7 year 2080 which is a factor of 2.2 times higher than the population estimated for the year 2015 

8 (5 years past the expected licensing action). 

9 Table G-7. Comparison of Population Total Body Doses from Gaseous Effluent Releases for 

10 Proposed Unit 3

Pathway 

UniStar ER (2008) 

(person-rem/yr)(a) Staff Estimate Population (person-rem/yr) Percent Difference 

Noble gases 3.63 3.65 0.55 

Iodines and particulates NR(b) 0.0307 - 

Tritium and C-14 NR(b) 1.23 - 

Total 5.52 4.91 -11 

(a) Results from UniStar ER Table 5.4-13 (UniStar 2009). 

(b) Values not reported in ER (UniStar 2009). 
Appendix G 

April 2010 G-13 Draft NUREG-1936 

1 G.3 Cumulative Dose Estimates 

2 Table G-8 compares UniStar’s results for cumulative dose estimates to the MEI with those 

3 calculated by the NRC staff. Cumulative dose estimates include doses from all pathways 

4 (i.e., direct radiation, liquid effluents, and gaseous effluents) for both the proposed Unit 3 and 

5 the existing Units 1 and 2 at the Calvert Cliffs site. These cumulative dose estimates were 

6 estimated for comparison to the dose standards of 40 CFR Part 190. Cumulative dose 

7 estimates calculated by UniStar (2009) and the NRC staff were similar but not identical. 

8 Differences in the cumulative dose were due to UniStar’s selection of the highest dose between 

9 2000 and 2005 for Units 1 and 2. Whereas the staff selected 2006 as a year indicative of the 

10 current trend in MEI doses from plant activity. UniStar’s selection is bounding. 

11 Table G-8. Comparison of Cumulative Doses to the Maximally Exposed Individual

Dose 

UniStar ER 

(2009)(a)(b)

Staff 

Estimate(c)

Percent 

Difference 

40 CFR Part 190 

Dose Standards 

Whole body (mrem/yr) 0.36 0.35 -2.8 25 

Thyroid dose (mrem/yr) 0.62 0.64 3.2 75 

Dose to other organ – (mrem/yr)(d) 1.2 .87 -27 25 

(a) Doses from direct radiation were determined to be negligible (UniStar 2009). 

(b) Sum of dose from liquid and gaseous effluent releases for the two existing units and the proposed unit are from 

Table 5.4-15 of the ER (UniStar 2009). 

(c) The staff calculation included the sum of doses from liquid and gaseous effluent releases from the two existing 

units and the new proposed unit. Doses from liquid effluent for existing units were taken from the 2006 annual 

radiological effluent report (Constellation 2007). Doses from gaseous effluent for existing units were calculated. 

(d) UniStar combined the critical organ for liquids (adult GI-LLI) and gaseous effluents (child – bone) to 

conservatively represent the maximum dose (UniStar 2009). Staff combined the maximum organ from all 

pathways as a conservative estimate of maximum organ dose. 

12 G.4 Dose Estimates to the Biota from Liquid and Gaseous 

13 Effluents 

14 To estimate doses to the biota from the liquid and gaseous effluent pathways, the staff used the 

15 LADTAP II code (Strenge et al. 1986), the GASPAR II code (Strenge et al. 1987), and input 

16 parameters supplied by UniStar (2009) in its ER. 

17 G.4.1 Scope 

18 The staff estimated the doses to biota other than humans using surrogate species; using the 

19 characteristics of surrogate species to represent a range of species is an accepted 

20 methodology. Fish, invertebrates, and algae are used as surrogate aquatic biota species. 

21 Muskrats, raccoons, herons, and ducks are used as surrogate terrestrial biota species. The 
Appendix G 

Draft NUREG-1936 G-14 April 2010 

1 staff recognizes the LADTAP II computer program as an appropriate method for calculating 

2 dose to the aquatic biota and for calculating the liquid-pathway contribution to terrestrial biota. 

3 The LADTAP II code calculates an internal dose component and an external dose component 

4 and sums them for a total body dose. The staff reviewed the input parameters used by UniStar 

5 for appropriateness. Default values from Regulatory Guide 1.109 (NRC 1977) were used when 

6 site-specific input parameters were not available. The staff concluded that all of the LADTAP II 

7 input parameters used by UniStar were appropriate. These parameters were used by the staff 

8 in its independent calculations using LADTAP II. 

9 The LADTAP II code calculates biota dose only from the liquid effluent pathway. Terrestrial 

10 biota could also be exposed via the gaseous effluent pathway. The gaseous pathway doses 

11 would be the same as doses for the MEI calculated using the GASPAR II code. UniStar (2009) 

12 used the MEI doses at the exclusion area boundary (0.88 mi from the plant) to estimate these 

13 doses. However, because animals may live within the site boundary, closer than maximally 

14 exposed humans, the staff used a location 0.25 mi from the release point for estimating onsite 

15 biota exposures. The ratio of radionuclide concentrations in air at the biota location to the 

16 concentrations at the MEI location is used to adjust (or scale) the dose. Dose from exposure to 

17 atmospheric plumes is directly proportional to air concentration. To account for the greater 

18 proximity of the main body mass of animals to the ground compared to humans, the biota 

19 calculation assumed a ground deposition factor twice that used in the human MEI calculation. 

20 The gaseous pathway doses are summed and combined with the liquid pathway doses for a 

21 total dose for the representative biota species. 

22 G.4.2 Resources Used 

23 To calculate doses to the biota, the staff used a personal computer version of the LADTAP II 

24 and GASPAR II computer codes entitled NRCDOSE Version 2.3.10 (Chesapeake Nuclear 

25 Services, Inc. 2008). NRCDOSE was obtained through the Oak Ridge RSICC. 

26 G.4.3 Input Parameters 

27 The NRC staff used the input parameters for LADTAP II and GASPAR II specified in 

28 Sections G.2.3 and G.2.4 to calculate biota dose. 

29 G.4.4 Comparison of Results 

30 Table G-9 compares UniStar’s biota dose estimates from liquid and gaseous effluents taken 

31 from Table 5.4-19 of the ER (UniStar 2009) with the NRC staff’s estimates. Dose estimates 

32 were similar until staff added ingestion of vegetables and calculated the doses from gaseous 

33 releases at a location closer to the gaseous release point. Even though percent differences are 

34 large for gaseous doses, all of the estimated doses are well below NCRP and IAEA guidelines 

35 (as discussed in Section 5.9.5 of this EIS). 
Appendix G 

April 2010 G-15 Draft NUREG-1936 

1 Table G-9. Comparison of Dose Estimates to Biota from Liquid and Gaseous Effluents, Unit 3 

Biota Pathway 

UniStar ER (2009) 

(mrad/yr) 

Staff Calculation 

(mrad/yr) 

Percent 

Difference 

Fish Liquid 0.326 0.327 0 

Gaseous(a) NA NA - 

Muskrat Liquid 1.28 0.975 -24 

Gaseous 0.22 32.9 14800 

Raccoon Liquid 0.0471 0.046 -2.3 

Gaseous 0.22 32.9 14800 

Heron Liquid 0.17 0.17 0 

Gaseous 0.22 32.9 14800 

Duck Liquid 1.31 1.02 -22 

Gaseous 0.22 32.9 14800 

Algae Liquid 5.13 5.97 +16 

Gaseous(a) NA NA NA 

Invertebrate Liquid 2.62 2.67 +1.9 

Gaseous(a) NA NA NA 

(a) Fish, invertebrate species, and algae would not be exposed to gaseous effluents. 

2 G.5 References 

3 10 CFR Part 50. Code of Federal Regulations, Title 10, Energy, Part 50, “Domestic Licensing of 

4 Production and Utilization Facilities.” 

5 40 CFR Part 190. Code of Federal Regulations, Title 40, Protection of Environment, Part 190, 

6 “Environmental Radiation Protection Standards for Nuclear Power Operations.” 

7 AREVA NP Inc. (AREVA). 2007. AREVA NP Environmental Report, Standard Design 

8 Certification. ANP-10290, Revision 0, November 2007. Accession No. ML073530589. 

9 Constellation Energy Group, LLC (Constellation). 2001. Annual Radiological Environmental 

10 Operating Report for the Calvert Cliffs Nuclear Power Plant Units 1 and 2 and the Independent 

11 Spent Fuel Storage Installation, January 1- December 31, 2000. Accession No. ML011340212. 

12 Constellation Energy Group, LLC (Constellation). 2002. Annual Radiological Environmental 

13 Operating Report for the Calvert Cliffs Nuclear Power Plant Units 1 and 2 and the Independent 

14 Spent Fuel Storage Installation, January 1- December 31, 2001. Accession No. ML021350439 

15 and ML022320346. 
Appendix G 

Draft NUREG-1936 G-16 April 2010 

1 Constellation Energy Group LLC (Constellation). 2003. Annual Radiological Environmental 

2 Operating Report for the Calvert Cliffs Nuclear Power Plant Units 1 and 2 and the Independent 

3 Spent Fuel Storage Installation, January 1- December 31, 2002. Accession No. ML031400478. 

4 Constellation Energy Group LLC (Constellation). 2004. Annual Radiological Environmental 

5 Operating Report for the Calvert Cliffs Nuclear Power Plant Units 1 and 2 and the Independent 

6 Spent Fuel Storage Installation, January 1- December 31, 2003. Accession No. ML041380033. 

7 Constellation Energy Group LLC (Constellation). 2005. Annual Radiological Environmental 

8 Operating Report for the Calvert Cliffs Nuclear Power Plant Units 1 and 2 and the Independent 

9 Spent Fuel Storage Installation, January 1- December 31, 2004. Accession No. ML051370609. 

10 Constellation Energy Group LLC (Constellation). 2006. Annual Radiological Environmental 

11 Operating Report for the Calvert Cliffs Nuclear Power Plant Units 1 and 2 and the Independent 

12 Spent Fuel Storage Installation, January 1- December 31, 2005. Accession No. ML061440213. 

13 Constellation Energy Group LLC (Constellation). 2007. Annual Radiological Environmental 

14 Operating Report for the Calvert Cliffs Nuclear Power Plant Units 1 and 2 and the Independent 

15 Spent Fuel Storage Installation, January 1- December 31, 2006. Accession No. ML071590393. 

16 Chesapeake Nuclear Services, Inc. 2008. NRCDOSE for Windows. Radiation Safety 

17 Information Computational Center, Oak Ridge, Tennessee. 

18 Sagendorf, J.F., J.T. Goll, and W.F. Sandusky. 1982. XOQDOQ: Computer Program for the 

19 Meteorological Evaluation of Routine Effluent Releases at Nuclear Power Stations. 

20 NUREG/CR-2919, Pacific Northwest National Laboratory, Richland, Washington. 

21 Strenge, D.L., R.A. Peloquin, and G. Whelan. 1986. LADTAP II – Technical Reference and 

22 User Guide. NUREG/CR-4013, Pacific Northwest Laboratory, Richland, Washington. 

23 Strenge, D.L., T.J. Bander, and J.K. Soldat. 1987. GASPAR II – Technical Reference and User 

24 Guide. NUREG/CR-4653, Pacific Northwest Laboratory, Richland, Washington. 

25 UniStar Nuclear Development, LLC (UniStar). 2009. Calvert Cliffs Nuclear Power Plant Unit 3 

26 Combined License Application, Part 3, Environmental Report. Revision 6, Baltimore, Maryland. 

27 Accession No. ML092880921. 

28 U.S. Nuclear Regulatory Commission (NRC). 1977. Calculation of Annual Doses to Man from 

29 Routine Releases of Reactor Effluents for the Purpose of Evaluating Compliance with 

30 10 CFR Part 50, Appendix I. Regulatory Guide 1.109, Office of Nuclear Reactor Regulation, 

31 Washington, D.C. 
Appendix G 

April 2010 G-17 Draft NUREG-1936 

1 U.S. Nuclear Regulatory Commission (NRC). 2000. Environmental Standard Review Plan— 

2 Standard Review Plans for Environmental Reviews for Nuclear Power Plants. NUREG-1555, 

3 Washington, D.C. Includes 2007 updates. 

Appendix H 

 

Authorizations, Permits, and Certifications 

April 2010 H-1 Draft NUREG-1936 

Appendix H 

Authorizations, Permits, and Certifications 

1 This appendix contains a list of the environmental-related authorizations, permits, and 

2 certifications potentially required by Federal, State, regional, local, and affected Native 

3 American tribal agencies related to the combined license for the Calvert Cliffs Nuclear Power 

4 Plant, Unit 3. The table is adapted from Table 1.3-1 of the Environmental Report submitted to 

5 the U.S. Nuclear Regulatory Commission by UniStar. 
Draft NUREG-1936 H-2 April 2010

Appendix H Table H-1. Authorizations/Permits Required for Combined License 1 

Agency Authority Requirement Activity Covered

Permit Issued or 

Authorization 

Obtained/Status

U.S. Nuclear Regulatory Commission (NRC) 

10 Code of Federal Regulations (10 CFR) Part 40 

Source Material License 

Possession, use and transfer of source material. 

Submitted March 2008 

NRC 10 CFR Part 52, Subpart C Combined License Construction and Operation of a 

nuclear power plant. 

Submitted Part 1 July 2007, Submitted March 2008 

NRC 10 CFR Part 70 Special Nuclear 

Material License 

Possession, delivery, receipt, use, transfer of fuel. 

Submitted March 2008 

NRC 10 CFR Part 30 By-product Material 

License 

Production, transfer, receipt acquisition, ownership, possession of nuclear byproduct materials 

Submitted March 2008 

NRC Clean Air Act Section 176 

(42 U.S.C. 7506); 40 CFR Part 93 Subpart B 

Air Conformity Analysis 

Conformity with State Implementation Plan for criteria air pollutants in non-attainment zones 

Prior to issuance of the combined license 

Federal Aviation Administration 

49 U.S.C. 44718; 14 CFR 77.13 

Construction Notice Construction of structures 

(>200 feet) affecting air navigation 

Issued August 2009 

USACE Federal Water Pollution 

Control Act, Section 404; 33 CFR 322-323; Rivers and Harbors Act 33 U.S.C. 403 Section 10; 33 U.S.C. 1344 

Individual Permit Excavation, dredging, and/or 

disposal of dredged material in navigable waters; filling of waters of U.S. 

Submitted May 2008 

2 
April 2010 H-3 Draft NUREG-1936

Appendix H

Table H-1. (contd)

Agency Authority Requirement Activity Covered

Permit Issued or 

Authorization 

Obtained/Status

Maryland Department of the Environment (MDE) 

Coastal Zone Management Act, 16 U.S.C. 1451 et seq., 15 CFR 930.57 

CZMA Consistency Certification and Approval 

Activities affecting the state’s coastal zone resources. 

Incorporated as part of USACE/MDE Joint Permit Application submitted May 2008 

U.S. Fish and Wildlife Service (FWS) 

Endangered Species Act (ESA) Section 7, 16 U.S.C. 1536 

Consultation regarding potential to adversely impact protected species 

Identification of protected species and critical habitat onsite and in the vicinity of site, assessment of construction and operation impacts. 

Began Informal consultation January 2009 

National Marine Fisheries Service (NMFS) 

ESA Section 7, 16 U.S.C. 703 et seq.; 50 CFR 402 

Consultation regarding potential to adversely impact protected species 

Identification of protected species and critical habitat onsite and in the vicinity of site, assessment of construction and operation impacts. 

Incorporated as part of USACE/MDE Joint Permit Application submitted May 2008 

NMFS Magnuson-Stevens 

Fishery Conservation Management Act Section 305(b); 16 U.S.C. 1801 et seq 

Consultation regarding potential impacts to essential fish habitat (EFH) 

Identification of EFH in the site vicinity, assessment of project operations impacts 

Incorporated as part of USACE/MDE Joint Permit Application submitted May 2008 

FWS Bald and Golden Eagle 

Protection Act, 16 U.S.C. 668(a); Migratory Bird Permits, 50 CFR 21 

Eagle Scientific Collecting Permit 

Eagle management activities Issued March 26, 

2009 
Draft NUREG-1936 H-4 April 2010

Appendix H Table H-1. (contd)

Agency Authority Requirement Activity Covered

Permit Issued or 

Authorization 

Obtained/Status

State Historic Preservation Office (SHPO) / MD Historic Trust 

National Historic Preservation Act (NHPA) 16 U.S.C. 470 et seq; 36 CFR 800 

Cultural Resources Review and Consultation 

Identification, description and evaluation of cultural resources on and in the site vicinity with the potential to be impacted by construction and operation. 

Phase I and II completed 2007 and 2008, respectively 

Maryland Public Service Commission (PSC) 

Annotate Code of MD 7-207 and 7-208; Code of Maryland Regulations 20.79 

Certification of Public Convenience and Necessity (CPCN) 

Site preparation for construction and operation of electric generating station 

Issued June 26, 2009 

PSC Annotate Code of MD 7-

207 and 7-208; Code of Maryland Regulations 20.79 

CPCN Construction or modification of 

transmission lines (Lines to be modified) 

Issued June 26, 2009 

MDE Federal Water Pollution 

Control Act 33 U.S.C. 1341 et seq, Code of Maryland Regulations 26.08.02.10 

Section 401 Water Quality Certification 

Compliance with state water quality standards 

Incorporated as part of USACE/MDE Joint Permit Application submitted May 2008 

U.S. Environmental Protection Agency (EPA) 

Federal Water Pollution Control Act Section 316(a), Code of Maryland Regulations 26.08.03.03 

Water quality impact assessment 

Demonstrate thermal discharges to water comply with thermal discharge criteria, and are protective of aquatic species 

With NPDES permit application to be submitted December 2013 

EPA/MDE Federal Water Pollution 

Control Act Section 316(b), Code of Maryland Regulations 26.08.03.05 

Best Technology Available demonstration 

Demonstrate cooling water intake structure represents Best Technology Available in minimizing potential for entrainment/impingement of aquatic species. 

With NPDES permit application to be submitted December 2013 
April 2010 H-5 Draft NUREG-1936

Appendix H

Table H-1. (contd)

Agency Authority Requirement Activity Covered

Permit Issued or 

Authorization 

Obtained/Status

MDE Federal Water Pollution 

Control Act Section 402; 33 U.S.C. 1342; Code of Maryland Regulations 26.08.04 

National Pollution Discharge Elimination System (NPDES) permit 

Discharge of industrial wastewater and stormwater during operation 

December 2013 

Maryland Department of Natural Resources 

Code of Maryland Regulations 08.03.08.03 

Maryland listed threatened species 

Removal of bald eagle nest within Limit of Disturbance 

Issued September 2008 

MDE Code of Maryland 

Regulations 26.08.04.09 

General NPDES permit for stormwater associated with construction activity 

Discharge of stormwater during construction 

Issued February 2008 

PSC/ MDE Code of Maryland 

Regulations 26.24 and 20.79.03.02.B(4)(g) 

Maryland Tidal Wetlands License 

Construction work in tidal wetlands 

Submitted May 2008 under Joint Permit Application and included in CPCN application 

PSC/ MDE Code of Maryland 

Regulations 26.23 and 20.79.03.02.B(4)(g) 

Maryland Non-Tidal Wetlands Permit 

Construction work in non-tidal wetlands 

Submitted May 2008 under Joint Permit Application 

MDE Code of Maryland 

Regulations 26.17.04 

Waterway and 100-year floodplain permits 

Any activity that changes the course, current, or cross-section of a non-tidal stream or body of water, including the 100-year floodplain 

Submitted May 2008 under Joint Permit Application 
Draft NUREG-1936 H-6 April 2010

Appendix H Table H-1. (contd)

Agency Authority Requirement Activity Covered

Permit Issued or 

Authorization 

Obtained/Status

MDE Code of Maryland 

Regulations 26.17.01 

Erosion and Sediment Control Plan 

Land clearing, grading, or other earth disturbance (construction) 

November 2009 

MDE Code of Maryland 

Regulations 26.17.02 

Stormwater Management Plan 

Land development activity (construction and operation) 

November 2009 

Chesapeake Bay Critical Area (CBCA) Commission 

Code of Maryland Regulations 27.02 

CBCA conformance Construction and operation of an 

electric generating facility in the CBCA 

Issued August 2008, Revised plan approval issued August 2009 

PSC Code of Maryland 

Regulations 26.17.06; 20.79.03.02.B(3)(e) 

Water appropriation permit 

Withdrawal of groundwater for construction and withdrawal of surface water during operation 

Issued June 26, 2009 

MDE Code of Maryland 

Regulations 26.03.12 

Major Water Facilities Permit 

Construction of potable water supply system 

January 2011 

MDE Code of Maryland 

Regulations 26.03.12 

Major Sewerage System Permit 

Construction of sanitary waste treatment system for operation 

January 2011 

MDE Code of Maryland 

Regulations 26.04.06 

Sewage Sludge Utilization Permit 

Disposal of sludge from sewage treatment plant 

January 2011 

EPA / MDE 40 CFR 262.12, Code of 

Maryland Regulations 26.13.03 

Hazardous Waste Generator Registration 

Generation and storage of hazardous waste for 

≤90 days 

January 2010 
April 2010 H-7 Draft NUREG-1936

Appendix H

Table H-1. (contd)

Agency Authority Requirement Activity Covered

Permit Issued or 

Authorization 

Obtained/Status

MDE Code of Maryland 

Regulations 26.12.01.01 

State Radioactive Materials License 

Possession, use, acquisition, ownership, transfer of radioactive materials not regulated by NRC 

January 2015 

MDE Code of Maryland 

Regulations 26.10.01.07 

Oil Operations Permit 

Storage of oil in above ground storage tanks 

≥10,000 gal 

and/or >1,000 gal of used oil 

January 2015 

PSC Code of Maryland 

Regulations 26.11.02 

State Air Permit to Construct – Construction Phase 

Construction of constructionphase air pollutant emission sources 

Issued June 26, 2009 

PSC 40 CFR 52.21; Code of 

Maryland Regulations 26.11.01 and 26.11.02 

Prevention of Significant Deterioration (PSD) – Construction Phase 

Construction and operation of construction-phase major stationary sources of attainment pollutants 

Issued June 26, 2009 

PSC Code of Maryland 

Regulations 26.11.01, 26.11.02, 26.11.17 

New Source Review (NSR) – Construction Phase 

Construction of constructionphase major stationary sources of nonattainment pollutants 

Issued June 26, 2009 

PSC Code of Maryland 

Regulations 26.11.02; 20.79.03.02.B(2)(c) 

State Air Permit to Construct – Operational Phase 

Construction of operationalphase air pollutant emission sources 

Issued June 26, 2009 

PSC 40 CFR 52.21; Code of 

Maryland Regulations 26.11.01, 26.11.02 and 20.79.03.02.B(2)(c) 

PSD- Operational Phase 

Construction of major stationary sources of attainment pollutants for operational phase facilities 

Issued June 26, 2009 
Draft NUREG-1936 H-8 April 2010

Appendix H Table H-1. (contd)

Agency Authority Requirement Activity Covered

Permit Issued or 

Authorization 

Obtained/Status

PSC Code of Maryland 

Regulations 26.11.01, 26.11.02, 26.11.17, and 20.79.03.02.B(2)(c) 

NSR – Operational Phase 

Construction of major stationary sources of attainment pollutants for operational phase facilities 

Issued June 26, 2009 

MDE Code of Maryland 

Regulations 26.11.03; 20.79.03.02.B(2)(c) 

Clean Air Act Title V Operating Permit State Operating Permit 

Operation of existing facility with major stationary sources of air emissions 

May 2010 

Maryland State Highway Administration 

Annotated Code of MD 8-625 and Code of Maryland Regulations 11.04.05 

Highway Access Permit 

Construction of new or modified entrances on state highways 

Based on agency guidance 

Calvert County Department of Planning and Zoning 

Calvert County Code, Ordinances and Resolutions Chapter 18, Building Code of Calvert County 

County Grading Permit 

Clearing and grading of land November 2009 

Calvert County Department of Planning and Zoning 

Calvert County Code, Ordinances and Resolutions Chapter 18, Building Code of Calvert County 

County Building Permit, and Related Site Development Plan 

Construction of buildings and other structures. 

September 2010 
April 2010 H-9 Draft NUREG-1936

Appendix H

Table H-1. (contd)

Agency Authority Requirement Activity Covered

Permit Issued or 

Authorization 

Obtained/Status

Calvert County Department of Planning and Zoning; Inspections and Permits 

Calvert County Zoning, Ordinance, Article 4 

County Use and Occupancy Permit 

Use and occupancy of buildings Certificate of 

Occupancy issued as defined by Building Permit 

Federal Energy Regulatory Commission 

Section 205 of the Federal Power Act 

Market Based Rate Authorization and related energy regulatory matters (e.g., Exempt Wholesale Generator filing) 

Authority to sell power at market-based rates 

Based on agency guidance 

Calvert County Department of Planning and Zoning 

Calvert County Code, Ordinances and Resolutions Chapter 18, Building Code of Calvert County 

County Permit for Structure Demolition or Move 

Demolish certain structures and move certain structures at Camp Canoy 

Expected Spring 2010 

EPA 40 CFR 82.162 Ozone-Depleting 

Substance (ODS) Compliance Certification 

Recovery and recycling of ODS 2010 
Draft NUREG-1936 H-10 April 2010

Appendix H Table H-1. (contd)

Agency Authority Requirement Activity Covered

Permit Issued or 

Authorization 

Obtained/Status

U.S. Department of Energy 

Nuclear Waste Policy Act of 1982 

Contract for Disposal of Spent Nuclear Fuel and/or High-Level Radioactive Waste 

Disposal of spent nuclear fuel and/or high-level radioactive waste 

November 2008 

U.S. Department of Transportation 

49 CFR 107, Subpart G Certificate of 

Registration 

Transportation of hazardous materials 

April 2011 

Tennessee Department of Environment and ConservationDivision of Radiological Health 

TN Department of Environment and Conservation Rule 1200-2-10.32 

Tennessee Radioactive License for Delivery 

Transportation of radioactive waste into the State of Tennessee (below regulatory limits materials) 

November 2015 

State of Utah Department of Environmental Quality – Division of Radiological Control 

Utah Radiation Control Rules R313-26 

General Site Access Permit 

Transportation of radioactive waste into the State of Utah 

November 2015 

1 
Appendix I 

Severe Accident Mitigation Alternatives 

April 2010 I-1 Draft NUREG-1936 

Appendix I 

Severe Accident Mitigation Alternatives 

1 I.1 Introduction 

2 UniStar has submitted an application to construct an AREVA NP Inc. (AREVA) U.S. EPR at the 

3 Calvert Cliffs site. Current policy developed after the Limerick decision (Limerick 1989) requires 

4 that the U.S. Nuclear Regulatory Commission (NRC) staff consider alternatives to mitigate the 

5 consequences of severe accidents in a site-specific environmental impact statement (EIS). The 

6 severe accident mitigation alternative (SAMA) review presented here considers both severe 

7 accident mitigation design alternatives (SAMDAs) and procedural alternatives. 

8 In Title 10 of the Code of Federal Regulations (CFR), 10 CFR 52.79(a)(38), the NRC requires 

9 that an applicant for a combined license (COL) include “... a description and analysis of design 

10 features for the prevention and mitigation of severe accidents...” in the Final Safety Analysis 

11 Report (FSAR). The UniStar COL application provides this information in the FSAR (UniStar 

12 2009a). The Environmental Report (ER) (UniStar 2009a) also includes information regarding 

13 the SAMA analysis. 

14 In 10 CFR 52.47(a)(23), the NRC requires that applicants for design certification include “... a 

15 description and analysis of design features for the prevention and mitigation of severe 

16 accidents...” in the application for design certification. In 10 CFR 52.47(a)(27) the NRC requires 

17 a description of a “...plant-specific probabilistic risk assessment (PRA) and its results,” and in 

18 10 CFR 52.47(b)(2) the NRC requires an ER that contains the information required by 10 CFR 

19 51.55. AREVA has submitted all of this information in documents that are part of the application 

20 for certification of the U.S. EPR design. 

21 While the NRC staff has not completed its generic SAMDA review of the U.S. EPR for design 

22 certification, the staff has conducted a review of the UniStar SAMDA analysis specific to 

23 operation of a U.S. EPR at the Calvert Cliffs site (UniStar 2009b). The staff reviewed the input 

24 parameters and values used by UniStar (2009b) for appropriateness, including references made 

25 to the U.S. EPR design certification document (AREVA 2007a, b). The UniStar analysis is 

26 based on: 

27 1. the PRA included as Section 19.1 of the U.S. EPR FSAR (AREVA 2007a) and the SAMDA 

28 analysis in the U.S. EPR ER (AREVA 2007b), and 

29 2. results of the analysis of probability-weighted risks of the U.S. EPR design at the Calvert 

30 Cliffs site described in Section 5.11.2 of this EIS. 
Appendix I 

Draft NUREG-1936 I-2 April 2010 

1 An analysis for a U.S. EPR at a generic site is presented first; then the analysis is extended to 

2 include consideration of Calvert Cliffs site-specific information. These analyses have been 

3 updated by the NRC staff based on Revision 1 to the U.S. EPR ER (AREVA 2009). The 

4 SAMDA analysis for the proposed U.S. EPR design certification will be finally resolved through 

5 the design certification rulemaking process. 

6 I.2 U.S. EPR SAMDA Review – Generic Site 

7 This section addresses the generic analysis of SAMDAs conducted by AREVA, the applicant for 

8 the design certification of the U.S. EPR design. The SAMA review in Section I.3 extends the 

9 generic SAMDA analysis to include Calvert Cliffs site-specific factors including meteorology, 

10 population, and land use. Section I.3 also addresses SAMAs that were not included in the 

11 generic analysis because they do not involve reactor system design. 

12 I.2.1 U.S. EPR PRA Results 

13 AREVA, the applicant for certification of the U.S. EPR design, conducted Level 1 and Level 2 

14 PRAs to estimate the core damage frequencies (CDF) that might result from a large number of 

15 initiating events and accident sequences. Table I-1 lists these CDF estimates and estimates of 

16 the large release frequencies (LRF) of iodine, cesium, or tellurium. Releases associated with 

17 containment bypass, containment isolation failure, or containment failure at or before reactor 

18 vessel failure are considered to be large. Table I-1 also lists NRC staff goals related to CDFs 

19 and LRFs. 

20 Table I-1. Comparison of U.S. EPR PRA Results with the Design Goals 

NRC Design Goal(a) U.S. EPR PRA Results(b)

Core 

Damage 

Frequency 

(yr-1) 

Large 

Release 

Frequency

(yr-1) 

Core 

Damage 

Frequency 

(yr-1) 

Large 

Release 

Frequency 

(yr-1) 

Internal At Power Events 1.0 × 10-4 1.0 × 10-6 2.8 × 10-7 2.2 × 10-8

Internal Flooding Events 1.0 × 10-4 1.0 × 10-6 6.1 × 10-8 1.1 × 10-9

Internal Fire Events 1.0 × 10-4 1.0 × 10-6 1.8 × 10-7 3.6 × 10-9

Low Power and Shutdown Events 1.0 × 10-4 1.0 × 10-6 5.8 × 10-8 2.4 × 10-9

(a) SECY-90-016 (NRC 1990) 

(b) From Chapter 19 of the U.S. EPR FSAR (AREVA 2007a) 
Appendix I 

April 2010 I-3 Draft NUREG-1936 

1 Although the U.S. EPR PRAs did not provide quantitative estimates of CDFs and LRFs for 

2 seismic and other external initiating events such as hurricanes and tornadoes, they are 

3 discussed in the FSAR. The Section 19.1.5.1 of the FSAR (AREVA 2007a) presents the results 

4 of a seismic margins analysis in which PRA methods are used to identify potential 

5 vulnerabilities in the design and so corrective measures can be taken to reduce risk. Similarly, 

6 FSAR Section 19.1.5.4 addresses risks associated with high winds, tornado missiles, external 

7 flooding, and external fires. Risks associated with these events are considered to be 

8 insignificant by AREVA. 

9 I.2.2 Potential Design Improvements 

10 In the ER submitted as part of the design certification application (AREVA 2009), AREVA 

11 identified 167 candidate alternatives based on a review of industry documents, including 

12 previous SAMDA reviews and NRC evaluations of those reviews, and consideration of plant13 specific enhancements. The candidate alternatives were then screened to identify candidates 

14 for detailed evaluation. The categories used in screening were 

15 • not applicable 

16 • already implemented 

17 • combined 

18 • excessive implementation cost 

19 • very low benefit 

20 • not required for design certification 

21 • consider for further evaluation. 

22 The development of the U.S. EPR design has benefitted from insights gained in numerous 

23 PRAs. The low CDFs and LRFs in Table I-1 are attributable to the implementation of design 

24 improvements already incorporated into the U.S. EPR design. The following are examples of 

25 the 67 candidate alternatives already included in the design: 

26 • increase direct current battery capacity 

27 • improve direct current bus load shedding 

28 • provide an additional diesel generator 

29 • install self-actuating containment isolation valves 

30 • replace steam generators with new designs 

31 • install relief valves in the component cooling water system 

32 • create a reactor coolant depressurization system 
Appendix I 

Draft NUREG-1936 I-4 April 2010 

1 • add a motor-driven feedwater pump 

2 • improve seismic ruggedness of plant components. 

3 The screening process eliminated 21 candidate alternatives as being inapplicable for the U.S. 

4 EPR design; 4 candidate alternatives were combined with similar alternatives; and 51 candidate 

5 alternatives were procedural or administrative rather than design alternatives. Of the remaining 

6 24 candidate alternatives, 1 was categorized as very low benefit because it would not 

7 significantly reduce risk, and 23 were categorized as having excessive implementation costs. 

8 No candidate alternatives were identified for further evaluation. 

9 I.2.3 Cost-Benefit Comparison 

10 AREVA used the cost-benefit methodology found in NUREG/BR-0184, Regulatory Analysis 

11 Technical Evaluation Handbook (NRC 1997), to calculate the maximum attainable benefit 

12 associated with completely eliminating all risk for the U.S. EPR. 

13 This methodology involves determining the net value for a SAMDA according to the following 

14 formula: 

15 Net Value = (APE + AOC + AOE + AOSC) - COE 

16 where 

17 APE = present value of averted public exposure ($) 

18 AOC = present value of averted offsite property damage costs ($) 

19 AOE = present value of averted occupational exposure costs ($) 

20 AOSC = present value of averted onsite costs ($); this includes cleanup, decontamination, 

21 and long-term replacement power costs 

22 COE = cost of enhancement ($) 

23 If the net value of a SAMDA is negative, the cost of implementing the SAMDA is larger than the 

24 benefit associated with the SAMDA and it is not considered to be cost beneficial. 

25 To assess the risk reduction potential for SAMDAs, AREVA (AREVA 2009) assumed that each 

26 design alternative would work perfectly to completely eliminate all severe accident risk from the 

27 internal events. This assumption is conservative as it maximizes the benefit of each design 

28 alternative. AREVA estimated the public exposure benefits for the design alternative on the 

29 basis of the reduction of risk expressed in terms of whole body person-rem per year received by 

30 the total population within a 50-mi radius of the generic site hosting a U.S. EPR. 
Appendix I 

April 2010 I-5 Draft NUREG-1936 

1 Table I-2 summarizes AREVA’s estimates of each of the associated cost elements. The 

2 provided results are based on the approach, parameters, and data listed in NUREG/BR-0184. 

Baseline risks used in the analysis were 1.98 ×10-1 3 person-rem/yr population dose risk and 

4 $182 per year for cost risk for internal events during full-power operation (AREVA 2007b). 

5 Table I-2. Summary of Estimated Maximum Averted Costs for a Generic Site 

Averted Cost Estimate ($)(a)

Quantitative Attributes 7% discount 3% discount 

Health Public (APE) 5094 10,072 

Occupational (AOE) 264 847 

Offsite(b) Property (AOC) 2603 5147 

Onsite NA(c) NA(c)

Cleanup and Decontamination Onsite (AOSC)(d) 8215 26,682 

Replacement Power (AOSC)(d) 36,888 180,452 

Total(e) 53,063 164,179 

Total with seismic risk 70,574 218,358 

(a) From the design certification ER (AREVA 2009). 

(b) Includes offsite cleanup and decontamination costs. 

(c) Not Analyzed. 

(d) AOSC includes onsite cleanup and decontamination costs and the cost of replacement power. 

(e) Based on internal event, internal flooding, and internal fire risks. 

6 The monetary present value estimate for each risk attribute does not represent the expected 

7 reduction in risk resulting from a single accident; rather, it is the present value of a stream of 

8 potential losses extending over the projected lifetime of the facility (in this case projected to be 

9 60 years). Therefore, the averted cost estimates reflect the expected annual loss resulting from 

10 a single accident, the possibility that such an accident could occur at any time over the licensed 

11 life, and the effect of discounting these potential future losses to present value. 

12 As indicated above, AREVA estimated the total present dollar value equivalent associated with 

13 complete elimination of severe accidents at a single U.S. EPR unit site to range between about 

14 $53,100 and about $164,200. The estimated cost of replacement power has the largest effect 

15 on the averted cost. To account for the seismic risks, AREVA increased these estimates by a 

16 factor 1.33. The resulting best estimate of maximum averted costs is about $70,600 with an 

17 upper bound estimate of about $218,400. For any SAMDA to be cost beneficial, the 

18 enhancement cost must be less than $218,400. Based on a cost estimate of $70,600, AREVA 

19 concluded that none of the SAMDA candidates are cost beneficial. Based on screening 

20 estimates, AREVA (2009) estimated that the minimum implementation cost for a SAMDA would 

21 be about $150,000. AREVA also noted that the costs estimates for public health impacts (APE) 

22 and offsite costs (AOC) could double without affecting the SAMDA analysis. 
Appendix I 

Draft NUREG-1936 I-6 April 2010 

1 I.2.4 Staff Evaluation 

2 In 10 CFR 52.47(a)(27), the NRC requires that an applicant for design certification perform a 

3 plant- or site-specific PRA. The aim of this PRA is to seek improvements in the reliability of core 

4 and containment heat removal systems that are significant and practical. The set of potential 

5 design improvements considered for the U.S. EPR include those from industry guidance, 

6 previous SAMDA review, and review of the U.S. EPR design. The U.S. EPR design already 

7 incorporates many design enhancements related to severe accident mitigation. Such design 

8 improvements have resulted in a CDF that are two orders of magnitude lower than the CDFs for 

9 the existing Calvert Cliffs Units 1 and 2. 

10 AREVA’s averted cost estimates are based on point-estimate values, without consideration of 

11 uncertainties in CDF or offsite consequences. Even though this approach is consistent with that 

12 used in previous design alternative evaluations, further consideration of these factors could lead 

13 to significantly higher risk reduction values, given the extremely small CDF and risk estimates in 

14 the baseline PRA. Uncertainties either in CDF or in offsite radiation exposures resulting from a 

15 core damage event are fairly large because key safety features of the U.S. EPR design are 

16 unique, and their reliability has been evaluated through analysis and testing programs rather 

17 than through operating experience. 

18 Further, in evaluating the costs of SAMDA candidates, AREVA did not explicitly assess the 

19 capital costs associated with the various alternatives. Instead, AREVA used estimated costs of 

20 back fitting of similar SAMDAs provided by industry in license renewal applications. This 

21 approach has the potential to overestimate the actual costs of SAMDAs because the cost of 

22 implementing a modification to a reactor that has been built is always greater than implementing 

23 the modification in a design that is still evolving. 

24 I.3 Calvert Cliffs Site-Specific SAMA Review 

25 The discussion above evaluates SAMDAs for the U.S. EPR at a generic site. The discussion 

26 that follows updates that evaluation to include consideration of Calvert Cliffs site-specific factors 

27 including meteorological conditions, population distribution, and land use. It is based on the 

28 UniStar SAMDA analysis presented in the ER (UniStar 2009b) revised to account for changes in 

29 the U.S. EPR ER (AREVA 2009). The last part of this discussion deals with procedural and 

30 training SAMAs. 

31 I.3.1 Risk Estimates 

32 UniStar estimated severe accident risks for a U.S. EPR at the Calvert Cliffs site in Section 7.2 of 

33 its ER (UniStar 2009b). The NRC staff evaluated the information for the U.S. EPR design 

34 supplied by AREVA and UniStar (AREVA 2007a, b; UniStar 2009a) and Calvert Cliffs site-
Appendix I 

April 2010 I-7 Draft NUREG-1936 

1 specific data (meteorology, demographics, and land use) provided by UniStar (UniStar 2008, 

2 2009b). The results of these analyses are found in Table 5-16 in Chapter 5 of this EIS (Vol. 1). 

Table 5-16, gives a CDF of 5.3×10-7 yr-1, and population dose and cost risks of 4.1×10-1 3 personrem yr-1 and $369 yr-1 4 , respectively. These risks are based on internally initiated events, internal 

5 flooding events, and internal fire events that occur while the reactor is at power. The U.S. EPR 

6 FSAR (AREVA 2007a) states that the total CDF for events occurring while the reactor is at 

7 low power or shutdown is estimated to be about an order of magnitude less than the total at 

8 power CDF. 

9 I.3.2 Cost-Benefit Comparison 

10 In Section 7.3.2 of the ER (UniStar 2009b), UniStar estimates the averted costs associated with 

11 eliminating all severe accident risks associated for a U.S. EPR at the Calvert Cliffs site. The 

12 UniStar analysis is an update of the AREVA SAMDA analysis (AREVA 2007b) to include site13 specific information. UniStar substituted population dose and offsite cost risks based on 2050 

14 population projections for the Calvert Cliffs site for the population dose and offsite property costs 

15 in the AREVA analysis. Table I-3 shows both the AREVA generic averted cost estimates and 

16 the UniStar estimates, updated by the NRC staff to reflect the changes in the U.S. EPR ER 

17 (AREVA 2009). 

18 Table I-3. Summary of Estimated Averted Costs for the Calvert Cliffs Site 

Averted Cost Value Estimate ($) 

AREVA Generic(a) Calvert Cliffs Site(b)

Quantitative Attributes 7% discount 3% discount 7% discount 3% discount 

Public (APE) 5094 10,072 11,537 22,812 Health 

Occupational (AOE) 264 847 264 847 

Offsite(c) (AOC) 2603 5,147 5192 10,266 Property Onsite NA(d) NA(d) NA(d) NA(d)

Cleanup and 

Decontamination

Onsite (AOSC)(e) 8215 26,682 8215 26,682 

Replacement Power (AOSC)(e) 36,888 180,452 36,888 180,452 

Total 53,063 164,179 65,095 241,059 

Total with seismic risk 70,574 218,358 82,587 320,608 

(a) From design certification ER (AREVA 2009). 

(b) UniStar estimates (UniStar 2009b) updated to reflect AREVA (2009). 

(c) Includes cleanup and decontamination costs. 

(d) Not Analyzed. 

(e) AOSC includes onsite cleanup and decontamination cost and the cost of replacement power. 
Appendix I 

Draft NUREG-1936 I-8 April 2010 

1 In assessing the risk reduction potential of design improvements for the U.S. EPR, the NRC 

2 staff evaluated the AREVA risk reduction estimates for the various design alternatives and 

3 assessed the potential impact of uncertainties on the results. The analyses in Table I-2 and 

4 Table I-3 present the value of reducing the severe accident risk to zero. These values are used 

5 in screening potential SAMDAs. Using the results in Table I-2, AREVA concluded that no 

6 candidate alternative from an initial list of 167 alternatives would be cost beneficial. The Calvert 

7 Cliffs site-specific values, although higher than those estimated for a generic site, are below the 

8 minimum estimated cost for a design change. Moreover, no SAMDA can reduce the risk to 

9 zero. Therefore, the staff concludes that it is highly unlikely that any SAMDA would be cost 

10 beneficial at the Calvert Cliffs site. 

11 I.3.3 Procedural and Training SAMAs 

12 The original list of 167 U.S. EPR SAMDAs included 51 candidate alternatives that were 

13 procedural or training in nature. These items were eliminated from consideration because they 

14 did not involve design changes. Examples of items screened out for this reason include 

15 • develop procedures for replenishing diesel fuel oil 

16 • emphasize steps in recovery of offsite power after a station blackout in training 

17 • institute simulator training for severe accident sequences 

18 • delay containment spray actuation after a large loss of coolant accident 

19 • implement procedures to stagger high-pressure safety injection pump use after a loss of 

20 service water 

21 • provide operator training on manually actuating the extra borating system. 

22 These candidate alternatives fall within the scope of the SAMA review that the NRC staff 

23 conducts as part of its environmental review of applications. However, such SAMAs generally 

24 involve operational and training procedures that have not been developed and that are typically 

25 not developed until construction has been completed and the plant is approaching operation. 

26 The staff reviewed the candidate alternatives that were previously screened out because they 

27 did not involve design changes. Because the maximum attainable benefit is so low, a SAMA 

28 based on procedures or training for a U.S. EPR at the Calvert Cliffs site would have to reduce 

29 the CDF or risk to near zero to become cost beneficial. Based on its evaluation, the staff 

30 concludes that it is unlikely that any of the SAMAs based on procedures or training would 

31 reduce the CDF or risk that much. Therefore, the staff further concludes it is unlikely that these 

32 SAMAs would be cost effective. 

33 UniStar (2009b) has stated that “... the plant administrative processes, procedures, and training 

34 program will be developed to address appropriate maintenance and use of the U.S. EPR design 
Appendix I 

April 2010 I-9 Draft NUREG-1936 

1 features which have been credited with the reduction of risk associated with postulated severe 

2 accidents.” Based on this statement, the staff expects that UniStar will consider risk insights 

3 and mitigation measures in the development of procedures and training; however, this 

4 expectation is not crucial to the staff’s conclusions because the staff already concluded 

5 procedural and training SAMAs would be unlikely to be cost effective. 

6 I.3.4 Conclusions 

7 Based on its evaluation of the U.S. EPR PRA (AREVA 2007a) and SAMDA analysis (AREVA 

8 2009), the Calvert Cliffs site-specific severe accident and SAMDA analyses (UniStar 2008, 

9 2009b) and its own independent review, the staff concludes that that there are no U.S. EPR 

10 SAMDAs that would be cost beneficial at the Calvert Cliffs site. The staff expects that UniStar 

11 will consider risk insights and mitigation measures in the development of procedures and 

12 training; however, this expectation is not crucial to the staff’s conclusions because the staff 

13 concludes procedural and training SAMAs would be unlikely to be cost effective. 

14 I.4 References 

15 10 CFR Part 51. Code of Federal Regulations, Title 10, Energy, Part 51, "Environmental 

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

17 10 CFR Part 52. Code of Federal Regulations, Title 10, Energy, Part 52, “Licenses, 

18 Certifications, and Approvals for Nuclear Power Plants.” 

19 AREVA NP Inc. (AREVA) 2007a. U.S. EPR Final Safety Analysis Report. Revision 0, 

20 December 2007. Accession No. ML073531265. 

21 AREVA NP Inc. (AREVA). 2007b. AREVA NP Environmental Report, Standard Design 

22 Certification. ANP-10290, Revision 0, November 2007. Accession No. ML073530589. 

23 AREVA NP Inc. (AREVA). 2009. AREVA NP Environmental Report, Standard Design 

24 Certification. ANP-10290, Revision 1, Accession No. ML092650775. 

25 Limerick Ecology Action vs. NRC. 1989. "Federal Reporter, Second Series, Vol 869, P 719 

26 [3rd Circuit]." 

27 UniStar Nuclear Development, LLC (UniStar). 2008. Letter from George Vanderheyden 

28 (UniStar, President and CEO) to NRC dated June 12, 2008, “Subject: UniStar Nuclear Energy, 

29 NRC Docket No. 52-016, Submittal of Response to Requests for Additional Information for the 

30 Calvert Cliffs Nuclear Power Plant, Unit 3 and Request for Withholding of Documents.” NRC’s 

31 Request for Additional Information dated May 13, 2008. Accession No. ML100040300. 
Appendix I 

Draft NUREG-1936 I-10 April 2010 

1 UniStar Nuclear Development, LLC (UniStar). 2009a. Calvert Cliffs Nuclear Power Plant Unit 3 

2 Combined License Application, Part 2, Final Safety Analysis Report. Revision 6. UniStar, 

3 Baltimore, Maryland. Accession No. ML092880897. 

4 UniStar Nuclear Development, LLC (UniStar). 2009b. Calvert Cliffs Nuclear Power Plant Unit 3 

5 Combined License Application, Part 3, Environmental Report. Revision 6. UniStar, Baltimore, 

6 Maryland. Accession No. ML092880921. 

7 U.S. Nuclear Regulatory Commission (NRC). 1990. “Evolutionary LWR Certification Issues and 

8 Their Relationships to Current Regulatory Requirements.” SECY-90-016, January 1990. 

9 U.S. Nuclear Regulatory Commission (NRC). 1997. Regulatory Analysis Technical Evaluation 

10 Handbook. NUREG/BR-0184, NRC, Washington, D.C. 
Appendix J 

UniStar’s Least Environmentally Damaging 

Practicable Alternative (LEDPA) and Onsite 

Alternatives Analysis 

April 2010 J-1 Draft NUREG-1936

Appendix J 

UniStar Least Environmentally Damaging Practicable 

Alternative (LEDPA) and Onsite Alternatives Analysis 

1 UniStar provided an alternative site analysis (UniStar 2009) that describes the offsite 

2 alternatives relative to wetland and stream impacts and a statement on the least 

3 environmentally damaging practicable alternatives (LEDPA). UniStar also provided an onsite 

4 alternative analysis that describes the onsite alternative layouts relative to wetland and stream 

5 impacts. These alternative site analyses are shown in the balance of this appendix. 
Appendix J 

Draft NUREG-1936 J-2 April 2010

1 

NU C LEAR ENERGY 

Appendix F-US Army Corps of Engineers (USACE) Information 

This appendix contains: 1) Project Purpose, 2) the Least Environmentally Damaging Practicable Alternative (LEOPA) 

Analysis. 

Section F1 - Purpose 

The basic purpose for the project is to generate electricity for additional base load capacity. 

The overall purpose of the project is to construct a nuclear power plant facility to provide for additional baseload electrical 

generating capacity to meet the growing demand in the State of Maryland. 

Section F2 - LEDPA Analysis 

Table 9.3-12 of ER Chapter 9 of the Calvert Cliffs Unit 3 COLA presents the impacts of the EPR project at four sites; the 

proposed site and three alternative sites. The relevant information from the subject table needed for a 404(b)1 analysis 

and subsequent LEOPA determination by the USACE has been provided in the COLA ER Tables 9.3-12, 9.3-13, and 9.3-

14 below. 

Review of the tables identifies that relative to impacts to Waters of the U.S. on the site itself, EASTALCO would be the 

LEOPA site. However, further evaluation of associated off-site impacts required for water line and transmission line rightof-way (ROW) construction associated with the Alternative Sites, supports Calvert Cliffs Unit 3 as the LEOPA site. 

A LEDPA analysis, by regulation, should help identify a site with the least impact to Waters of the U.S. and with no 

s;gnificant adverse impacts to other environmental resources as the Least Environmentally Oamaging Practicable 

Alternative Accordingly, based upon a comprehensive evaluation , including 41 other environmental impact criteria used 

to evaluate the four sites, Calvert Cliffs Unit 3 Alternative Site Evaluation Report (ASER) and supporting materials clearly 

demonstrate that the Calvert Cliffs Unit 3 site has the smallest overall impact to environmental resources and therefore is 

the environmentally preferred location for construction of the EPR within the defined Region of Interest, Maryland. 

The dredging for barge access is unique to Calvert Cliffs due to its location and existing nuclear facilities. The proposed 

tidal wetland impact is approximately 5.7 acres (4.5 acres due to the barge slip restoration and the balance of 1.2 acres is 

associated with the intake structure, discharge pipe, and fish return). The barge facility restoration work to access the pier 

and improve navigation would have eventually been necessary to service the existing facil ities at Units 1 and 2. The tidal 

work does not impact the overall LEOPA conclusion, as Calvert Cliffs was selected based on a comprehensive evaluation 

as described below. 

The Alternative Sites Bainbridge and EASTALCO share a similar navigable riverine environment where in-water Cooling 

Water Intake Structure (CWIS) components are proposed. Similar methods of in-water work and identical impacts below 

Ordinary High Water (OHW) or Mean High Water shoreline (MHW) were assumed. Certain assumptions were used in the 

calculations of impacts associated with in-water work, estimated at 0.23 acre (1 00'x1 00'). These assumptions are based 

on understanding of the physical environment, based on screening level data and experience of the UniStar Nuclear 

Energy team with similar projects. Primary factors included the following: an assumption that 0.23 acre would 

accommodate the cooling water intake system components and any necessary turbidity curtain array or coffer dam; work 

within the 0.23 acre disturbance footprint could accommodate dredging, blasting, drilling, or any other typical construction 

methods; the use of horizontal directional drilling (HOO) could be employed to avoid open cut or surface lay pipeline 

impacts; the pump house and support structures can be sited outside of any regulatory resource area. 

The Thiokol Alternative Site is located along the Patuxent River. Because of the soft muddy substrate documented to be 

in the river at the location of the cooling water intake and discharge locations and a shallow shelf along the southern 

shoreline that must be spanned to reach suitable water depths, the following assumptions were included in the calculation 

of impacts presented here: 1) HOO will not be an effective technology, 2) dredging must be employed for the pipe trench 

and CWIS component locations, 3) the CWIS would need to be located 1000' or greater offshore. Under this scenario, 

work would be proposed to impact approximately 2.25 acres of waters below MHW, and require approximately 8,000 

cubic yards of (in-place) sediment. 
 Appendix J 

April 2010 J-3 Draft NUREG-1936

1 

UnlStar 

N IJ CL EA R E NER GY 

Table 9.3-12 Comparison of Wetland and Waterway Impacts from Alternative Sites Evaluation 

I Proposed Site Alternative Sites I Calvert Cliffs 

310 Bainbridge EASTALCO Thiokol17 

I Property Acreage 2057.2 1068.6 1742.1 620.0 I Wetlands - Total Propertyl (ac) 173.2 4.6 22.0 49.8 

Wetlands - SiteZ (ac) 6.6 0.0 0.0 34.5 

Streams - Total (LF) 21805 8654 32944 7055 

Streams - Site4 (LF) 3604 1557 1311 3435 

Wetlands Affected - SiteO (ac) 6.6 0.0 0.0 34.5 

Streams Affected - SiteO (LF) 3604 1557 1311 3435 

Section 10 Waters: Tidal (a c) 5.7' NA NA 2.25!l 

Navigable Riverine (ac) N/A NA 

Off-Site WetlandslVVaterways Wetland Stream Wetland Stream Wetland Stream Wetlands Streams 

Affected -ROWs and s s s s s s 

Interconnects (ac/LFf 

CWIS (in-water 

0.23 0 0.23 0 0.23 0 0.23 0 

components)( ac) 11 

CW Pump House (ac.)lZ NA NA 0 0 0 0 0 0 

Water Line ROW NA NA 1.3 0 3.2 865 0.4 0 

I 

Transmission Line ROW (ac) 14 0 0 5.2 3517 0.2 1820 26.6 4051 

RR Spur/Improvements (ac) NA NA NA NA NA NA NA NA 

I 

Access Roadways (ac) NA NA NA NA NA NA NA NA 

Other Off-Site Uses (ac)15 NA NA NA NA NA NA NA NA 

l"TotaJ Property" includes the entirety of the alternate site facility contiguous land holdings (black outline). 

2' Site" includes the 420 parcel on the Total Property selected for EPR development (red outline). 

3Describes the total length of all streams on the Total Property in linear feel. Includes both mapped perennial and intermittent waterways and obvious drainage ways observed during site 

inspections or interpreted from desktop mapping. 

"Describes streams within the 420 EPR Site. calculated in the same manner as streams for "Total Property". 

5 An assumption has been made that any wetlands within the 420 acre Site would be affected . 

6An assumption has been made that any streams within the 420 acre Site would be affected by construction. 

7 The actual, not estimated, proposed impacts to Sec. 10 regulated tidal waterways below ordinary high water (OHW) or mean high water shoreline (MHW) is approximately 5.7 acres. 

-----_ .. _------- - - --
Appendix J 

Draft NUREG-1936 J-4 April 2010

1 

Nur: LEA n ENERGY 

8 The Thiokol site cooling water intake and discharge structures are located within the Patuxent River. Directional drilling would not be possible based on soft mud substrate, and suitable water 

depths are located 1000' feet into the river channel seaward of OHW or MHW. Accordingly, dredging of a 1000' x 45' pipe trench (4' deep) in addition to 0.5 acres for aquatic structures is 

proposed, totaling approximately 2.25 acres. Dredging volume (in place) is estimated to be approximately 8,000 cubic yards. 

9 For both the Bainbridge and EASTALCO Alternative Sites, 0.23 acre (100'x100') of wetland disturbance below OHW is assumed. This estimation of impact is based upon prior experience in 

similar environments, and assumes use of directional drilling to approach intake sites, and the ability to contain the Intake and discharge structures within a coffer dam or turbidity curtain array 

with area 0.23 acres. 

lOAn assumption has been made that any wetlands or streams within the ROWs or interconnects would be affected by construction. Impacts associated with ROW construction and some inwater construction activities are temporary in nature. 

11An assumption has been made to allow a 1 00'x1 00' area of impact for in-water cooling water intake system (CWIS) components. No alternate sites are proposed to use shoreline intake 

structures; all intake/discharge structures are proposed to be sited at a depth of -20' MLW or greater. Horizontal directional drilling (HOD) is proposed to access off shore locations. 

l 2A cooling water pump house would be located alongshore to the selected cooling water source, and would occupy 0.5 acre total area. 

llFor the purposes of this evaluation, it has been assumed that any water line ROW would require a 120' width for construction to allow installation of 2-60" pipes. 

14For new transmission line construction or reconductoring of existing circuits to accommodate the EPR, a 300' wide cleared ROW is assumed to be required. The Transmission Corridor for the 

Thiokol site is different from the one in the March 2009 Requests for Additional Information Responses (UN#09-140) 

lSOther off-site uses include any required parking, laydown. staging requiring land alteration. 

l8ER Section 4.1 .1.1 (Rev. 5) states the CCNPP3 and supporting facilities will be located on 2,070 acres; ER Section 4.3.1.3 (Rev. 5) states the construction of CCNPP3 will permanently fill 

approximately 8,350 LF of stream and 11 .72 acres of delineated wetland areas. This table provides data primarily for the approximate 420-acre EPR Site (see Footnote 2) for consistent 

comparison with the alternative sites and, therefore, some data in this table will be different from quantities of affected acreage stated in the ER Rev. 5. 

17 ER Section 9.3.2.4.5 (UN#09-319) states that the Thiokol site has approximately 49.2 ac of non-tidal wetlands and 14,411 LF of stream within the 619 ac Thiokol site. This table provides data 

primarily for an approximate 420-acre EPR site within the overall property boundary. Therefore the data on affected wetlands and streams in this table will differ from the data presented in ER 

Section 9.3.2.4.5 (UN#09-319). 

Sources: USFWS, 2008. National Wetlands Inventory. U.S. Fish and Wildlife Service, CONUS_weCpoly, Classification of Wetlands and Deepwater Habitats of the United States, Washington, 

DC, FWS/OBS-79/31, National Wetlands Metadata. website: http://www.fws .gov/wetiandslData/DataDownloadState.html. accessed: June 17, 2009. MDNR, 2002. Wetlands of Special State Concern Data, Geospatial Data from the Maryland Department of Nalural Resources, Metadata, website: 

httD:lfdnrweb.dnr.state.md.us/ais/data/data.asD, accessed June 27, 2009. 
 Appendix J 

April 2010 J-5 Draft NUREG-1936

1 

G:l)Star r.lUCLEAR ENERGY 

Number of 

discrete 

wetlands or 

systems 

Calvert Cliffs I 5 

3 

Bainbridge I 5 

EASTALCO I 10 

Table 9.3-13 Summary of Wetlands on Alternate Sites 

Wetland types (NWI classification) I Description 

1. Freshwater Forested/Shrub 

Wetland 

2. Freshwater Pond 

3. Freshwater Pond 

4. Freshwater Forested/Shrub 

Wetland 

5. Freshwater Pond 

1. Freshwater Forested/Shrub 

Wetland 

2. Freshwater Pond 

3. Riverine 

4. Riverine 

5. Freshwater Forested/Shrub 

1. Freshwater Emergent Wetland 

2. Freshwater Emergent Wetland 

3. Freshwater Forested/Shrub 

Wetland 

4. Freshwater Forested/Shrub 

Wetland 

5. Freshwater Forested/Shrub 

Wetland 

6. Freshwater Emergent Wetland 

7. Riverine 

8. Freshwater Emergent Wetland 

9. Freshwater Emergent Wetland 

10. Freshwater Forested/Shrub 

Wetland 

1.4.7 ac of PF01 

2. 0.5 ac of PUB2 

3. 

0.02 ac of PUB 

4.0.5 ac of PFO 

5. 0.9 ac of PUB 

1.3.7 ac 

2.0.9 ac 

3.1.3 ac 

4.3.2 ac 

5.0.7 ac 

1. 0.2 ac 

2.0.4 ac 

3.0.1ac 

4.0.3 ac 

5.0.9 ac 

6.0.03 ac 

7.1 .3 ac 

8.0.2 ac 

9.0.3 ac 

10.0.7 ac 
Appendix J 

Draft NUREG-1936 J-6 April 2010

1 

NUC LEA. R ENERGY 

Thiokol 

Number of 

discrete 

wetlands or 

systems 

14 

Table 9.3-13 Summary of Wetlands on Alternate Sites 

Wetland types (NWI classification) I Description 

1. Freshwater Forested/Shrub 

Wetland 

2. Freshwater Forested/Shrub 

Wetland 

3. Freshwater Forested/Shrub 

Wetland 

4. Freshwater Forested/Shrub 

Wetland 

5. Freshwater Forested/Shrub 

Wetland 

6. Freshwater Forested/Shrub 

Wetland 

7. Freshwater Forested/Shrub 

Wetland 

8. Freshwater Pond 

9. Freshwater Emergent Wetland 

10. Freshwater Forested/Shrub 

Wetland 

11 . Freshwater Emergent Wetland 

12. Estuarine. and Marine Wetland 

13. Estuarine and Marine 

Deepwater 

14. Freshwater Emergent Wetland 

1 . 2.5 ac of PFO 

2. 31 .9 ac of PFO 

3. 0.08 ac 

4. 0.3 ac 

5. 4.3 ac 

6. 0.1 ac 

7. 0.1 ac 

8. 0.5 ac 9. 1.9 ac 

10. 5.2 ac 11. 1.1 ac 

12. 6.3 ac 

13. 6.8 ac 

14. 0.3 ac 

PFO is a palustrine forested wetland 

2PUB is a palustrine unconsolidated bottom wetland 

Sources: USFWS, 2008. National Wetlands Inventory, U.S. F sh i and Wildlife Service, CONUS_wetJloly, Classification of Wetlands and Deepwater Habitats of the United 

States, Washington, DC, FWS/OBS-79/31 , National Wetlands Metadata, website: http://www.fws.govlwetlands/DatalDataDownloadState.html. accessed: June 17, 2009. 

MDNR, 2002. Wetlands of Special State Concern Data, Geospatial Data from the Maryland Department of Natural Resources, Metadata, website: 

http://dnrweb.dnr.state.md.uslgis/dataldata.asp, accessed June 27, 2009. 
 Appendix J 

April 2010 J-7 Draft NUREG-1936

1 

u':'lStar 

NUCLEAR ENERGY 

Table 9.3-14 S fWatl Alt, te Sitl 

Number of/names of streams Stream type Description 

Calvert Cliffs 3 A. Johns Creek A. Perennial A. 4661 LF 

B. Tributary to the Bay B. Perennial B. 2093 LF 

C. Tributary of Johns Creek C. Perennial C. 7400 LF 

D. Goldstein Branch D. Perennial D. 2051 LF 

E. Tributary of Perrin Branch E. Intermittent E. 4517 LF 

F. Tributary of Perrin Branch F. Perennial F. 1083 LF 

Bainbridge A. Tributary of Susquehanna River A. Perennial A. 2638 LF 

B. Happy Valley Branch B. Perennial B. 6016 LF 

C. Tributary of Susquehanna River C. Perennial C. 1279 

D. Tributary of Susquehanna River D. Perennial D. 312 LF 

E. Tributary of Susquehanna River E. Perennial E. 308 LF 

F. Octoraro Creek F. Perennial F. 1433 LF 

G. Tributary to Octoraro Creek G. Perennial G. 185 LF 

EASTALCO A. Tributary of Tuscarora Creek A. Perennial A.2693 LF 

B. Tuscarora Creek B. Perennial B. 12319 LF 

C. Tributary of Tuscarora Creek C. Intermittent C. 6001 LF 

D. Tributary of Tuscarora Creek D. Perennial D. 3399 LF 

E. Tributary of Tuscarora Creek E. Intermittent E. 4634 LF 

F. Horsehead Run F. Intermittent F. 3898lF 

G. Tributary of Tuscarora Creek G. Intermittent G. 120 IF 

H. Tuscarora Creek H. Perennial H. 745 IF 

I. Tributary of Tuscarora Creek I. Perennial I. 395 LF 

J. Tributary of Tuscarora Creek J. Perennial J. 327 LF 

K. Tributary of Tuscarora Creek K. Perennial K. 378 LF 

L. Tributary of Tuscarora Creek L. Perennial L. 403 LF 

M. Tributary of Tuscarora Creek 

M. Perennial 

M. 317 LF 

Thiokol A. Tributary of Burnt Mill Creek A. Perennial A. 5430 LF 

B. Rich Neck Creek B. Perennial B. 2250 IF 

C. Tributary of Bumt Mill Creek C. Perennial C. 312 LF 

D. Horse Landing Creek D. Perennial D. 486 LF 

E. Tributary of Persimmon Creek E. Perennial E. 332 LF 

F. Persimmon Creek F. Perennial F. 324 LF 

G. Tributary of Killpeck Creek G. Perennial G. 300 LF 

H. Killpeck Creek H. Perennial H. 300 LF 

I. Tributary of Patuxent Creek I. Perennial I. 445 LF 

J. Tributary of Patuxent Creek J. Perennial J. 354 LF 

K. Tributary of Patuxent Creek K. Perennial K. 308 LF 

L. Tributary of Patuxent Creek L. Intermittent L. 201 IF M. Tributary of Patuxent Creek 

M. Perennial 

M. 310 LF 

L. Swanson Creek L. Perennial L. 379 LF 

Sources. 

USFWS, 2008. National Wetlands Inventory, U.S. Fish and Wildlife Service, CONUS_wet_poly, Classification of Wetlands and Deepwater Habitats of the United States, Washington, DC, 

FWS/OBS·79/31 , National Wetlands Metadata, website: http://www.fws.gov/wetiands/Data/DataDownloadState.html. accessed June 17, 2009. 

MDNR, 2002. Wetlands of Special State Concern Data, Geospatial Data from the Maryland Department of Natural Resources, Metadata, website: 

http://dnrweb.dnr.state.md.us/gis/data/data.asp, accessed June 27, 2009. 
Appendix J 

Draft NUREG-1936 J-8 April 2010

1 J.1 Onsite Alternatives Analysis 

2 Clean Water Act Section 404(b)(1) Guidelines for Specification of Disposal Sites for Dredged or 

3 Fill Material ("Guidelines"), stipulate that no discharge of dredged or fill material into a waters of 

4 the United States (including jurisdictional wetlands) shall be permitted if there is a practicable 

5 alternative which would have less adverse impact on the aquatic environment, so long as the 

6 alternative does not have other significant adverse environmental consequences. Even if an 

7 applicant’s preferred alternative is determined to be the least environmentally damaging 

8 practicable alternative, the Corps must still determine whether the LEDPA is in the public 

9 interest. The Corps Public Interest Review (PIR), described at 33 CFR 320.4, directs the Corps 

10 to consider a number of factors in a balancing process. A permit will be not be issued for an 

11 alternative that is not the LEDPA, nor will a permit be issued for an activity that is determined to 

12 be contrary to the public interest. In considering both the LEDPA and the PIR the Corps must 

13 consider compliance with other applicable substantive laws such as the Endangered Species 

14 Act (ESA) and the National Historic Preservation Act (NHPA) as well as consult with other 

15 Federal Agencies. The Corps also must follow procedural laws such as National Environmental 

16 Policy Act (NEPA), and other applicable laws described in 33 CFR 320.3. 

17 Section 230.10(a) of the Guidelines requires that “no discharge of dredged or fill material shall 

18 be permitted if there is a practicable alternative to the proposed discharge which would have 

19 less adverse impact on the aquatic ecosystem, so long as the alternative does not have other 

20 significant adverse environmental consequences.” Section 230.10(a)(2) of the Guidelines 

21 states that “an alternative is practicable if it is available and capable of being done after taking 

22 into consideration cost, existing technology, and logistics in light of overall project purposes. If it 

23 is otherwise a practicable alternative, an area not presently owned by the applicant that could 

24 reasonably be obtained, utilized, expanded, or managed in order to fulfill the basic purpose of 

25 the proposed activity may be considered.” Thus, this analysis is necessary to determine which 

26 alternative is the LEDPA that meets the project purpose and need. 

27 Where the activity associated with a discharge is proposed for a special aquatic site (as defined 

28 in 40 CFR Part 230, Subpart E), and does not require access or proximity to or siting within 

29 these types of areas to fulfill its basic project purpose (i.e., the project is not “water dependent”), 

30 practicable alternatives that avoid special aquatic sites are presumed to be available, unless 

31 clearly demonstrated otherwise (40 CFR 230.10(a)(3)). 

32 As part of the Corps permit review process, the Corps requested a detailed analysis on the 

33 steps taken to minimize UniStar’s proposed onsite impacts and to quantify potential permanent 

34 and temporary impacts to all waters of the United States, including jurisdictional wetlands, for 

35 each onsite project alternative. The onsite analysis does not preclude the necessity to evaluate 

36 the alternative site analysis. 
 Appendix J 

April 2010 J-9 Draft NUREG-1936

1 UniStar described the site layout study to select an appropriate location on the CCNPP campus 

2 for Unit 3 (UniStar 2008). The UniStar layout study, including design options to minimize 

3 impacts, evaluated north, south, and west parcel configurations. The criteria and considerations 

4 included environmental; security; land use and zoning; construction feasibility; 

5 switchyard/transmission lines; impact to existing facilities or structures; and process studies. 

6 UniStar also studied aesthetics; wetlands and streams; threatened and endangered species; 

7 and areas of historic and archeological resources. According to UniStar’s delineation, the 

8 Calvert Cliffs campus has approximately 133 acres of wetlands and 94,200 linear feet of 

9 streams (UniStar 2008). Table J-1 describes the UniStar delineated potential wetland and 

10 stream impact areas for the four studied locations. UniStar determined that its selected south 

11 parcel would be the most ecologically sound location of proposed Unit 3. 

12 Table J-1. Wetland and Stream Impact Areas of Onsite Alternatives

Onsite Alternative 

Approximate 

Wetland Impact 

Approximate Stream 

Impact 

Option A layout Northern 29.27 ac 9753 linear ft 

Option B layout Northern 29.27 ac 9753 linear ft 

Option C layout Northern 29.67 ac 11,474 linear ft 

UniStar’s selected layout Southern 11.7 ac 8350 linear ft 

13 At the request of the Corps, UniStar minimized potential project impacts to waters of the United 

14 States, including wetlands. Site layout for this project was based on an extensive site layout 

15 study to determine a layout that would most practicably avoid and minimize impacts to Corps 

16 jurisdictional waters and wetlands (UniStar 2008). Efforts were made to avoid, to the extent 

17 possible, the long- and short-term adverse impacts associated with the destruction or 

18 modification of wetlands and streams and to avoid direct or indirect support of new construction 

19 in wetlands and streams wherever there was a practicable alternative. The proposed impacts 

20 were further reduced through relocation of or reconfiguration of facility components. Project 

21 siting was limited by design constraints, which allowed integration with the existing Units 1 and 2 

22 and exclusion zones. UniStar prepared a summary of the stages of avoidance and/or 

23 minimization of potential onsite wetland and stream impacts within the selected southern layout 

24 that reduced wetland impacts from the initially proposed 18.6 ac reduced to 11.7 ac by 

25 relocating a construction road and the batch plant; reducing impact from stormwater drainage 

26 basins; optimizing the switchyard; and refining the wetland delineation (UniStar 2008). Decision 

27 options available to the Corps (which embraces all of the applicant's alternatives) are issue the 

28 permit; issue with modifications or conditions; or deny the permit. 
Appendix J 

Draft NUREG-1936 J-10 April 2010

1 J.2 References 

2 33 CFR Part 320. Code of Federal Regulations. Title 33, Navigation and Navigable Waters, 

3 Part 320, “General Regulatory Policies.” 

4 40 CFR Part 230. Code of Federal Regulations, Title 40, Protection of Environment, Part 230, 

5 “Section 404(b)(1) Guidelines for Specification of Disposal Sites for Dredged or Fill Material.” 

6 Clean Water Act. 33 U.S.C. 1251, et seq. (also referred to as the Federal Water Pollution 

7 Control Act [FWPCA]). 

8 Endangered Species Act of 1973. 16 U.S.C. 1531 et seq. 

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

10 National Historic Preservation Act of 1966 (NHPA). 16 U.S.C. 470, et seq. 

11 UniStar Nuclear Development, LLC (UniStar). 2008. Letter from Dimitri Lutchenkov (UniStar) to 

12 Mr. William Seib (Corp) dated November 11, 2008. “Subject: Joint Federal/State Application of 

13 Calvert Cliffs 3 Nuclear Project, LLC and UniStar Nuclear Operating Services, LLC, Calvert 

14 Cliffs Nuclear Power Plant Site, Lusby, Calvert County, Maryland, USACE Tracking No. NAB15 2007-08123-M05”. Accession No. ML091530687. 

16 UniStar Nuclear Energy (UniStar). 2009. Letter from G. Gibson (UniStar) to NRC dated 

17 October 15, 2009. “Subject: UniStar Nuclear Energy, NRC Docket No. 52-016, Calvert Cliffs 

18 Nuclear Power Plant, Unit 3, Supplemental Response to Environmental Report, RAI No. 1019, 

19 U.S. Army Corps of Engineers (USACE), Question No. 1 and No. 5.” Accession No. 

20 ML092920352. 
Appendix K 

UniStar’s Phase I Mitigation Plan Summary for 

Wetlands and Stream Impacts 

April 2010 K-1 Draft NUREG-1936

Appendix K 

UniStar’s Phase I Mitigation Plan Summary for 

Wetlands and Stream Impacts 

1 SUMMARY OF PHASE I COMPENSATORY MITIGATION PLAN FOR NONTIDAL WETLAND 

2 AND STREAM IMPACTS ASSOCIATED WITH CALVERT CLIFFS UNIT 3 

3 The proposed compensatory “in kind” mitigation for the scheduled impacts to wetlands and 

4 surface waters of the proposed Unit 3 project at the Calvert Cliffs site is intended to meet the 

5 mitigation requirements of the USACE Baltimore District, and includes the creation and 

6 enhancement of wetlands and streams to conditions more suitable for use by wildlife species 

7 native to the region. Appropriate and practicable steps to minimize adverse impacts were 

8 conducted through analysis of multiple site development plan concepts. The mitigation areas 

9 were chosen following a mitigation site selection process. Four general mitigation strategies 

10 were initially identified: (1) onsite and in kind; (2) onsite and not in kind; (3) offsite and in kind; 

11 and (4) offsite and not in kind. The mitigation strategy chosen for the proposed Unit 3 project at 

12 the Calvert Cliffs site provides for onsite and in-kind mitigation, as this strategy, or mitigation 

13 action, would replace nontidal wetland acreage and functional losses more effectively than the 

14 other three strategies. The project was designed to adhere to the Code of Maryland 

15 Regulations (COMAR), 26.23.04.03 (COMAR 2007). 

16 This work includes the enhancement of one manmade, abandoned sediment basin within the 

17 Lake Davies Disposal Area; the enhancement of portions of Johns Creek; the creation of 

18 forested and herbaceous wetland habitat within the largest manmade abandoned, sediment 

19 basin on the Lake Davies disposal area; creation of forested wetland habitat within the Camp 

20 Conoy area; stream restoration; and stream enhancement. The wetland mitigation proposes to 

21 create an approximate 0.9-ac area of open water pond habitat; 1.3 ac of freshwater marsh; 7.2 

22 ac of bottomland hardwood forest; eradication of invasive vegetation and enhancement of 

23 approximately 2.4 ac of bottomland hardwood forest; enhancement of wetlands abutting Johns 

24 Creek by eradication of invasive vegetation and enhancement of approximately 15.7 ac of 

25 bottomland hardwood forest; and creation of approximately 4.6 ac of forested wetland habitat. 

26 The stream mitigation proposes to restore stream functions along approximately 6283 linear feet 

27 of stream portions by employing treatments such as instream habitat structures (cover logs, 

28 lateral/longitudinal diversity and root wads); bank stabilization (vegetative and bioengineering 

29 solutions); and riparian wetland enhancements (hydraulic and vegetative). The stream 
Appendix K 

Draft NUREG-1936 K-2 April 2010

1 mitigation also proposes to enhance a total of approximately 4146 linear feet of specific stream 

2 portions by improving aquatic habitat, constructing bank stabilization and planting native riparian 

3 vegetation. These projects will be monitored for a 5-year period and shall be protected in 

4 perpetuity through establishment of a legally binding protection mechanism. 

5 WETLAND MITIGATION 

6 Compensatory mitigation for unavoidable impacts to approximately 11.72 ac of jurisdictional, 

7 nontidal forested wetlands, emergent (herbaceous) wetlands, and surface waters (including 

8 Camp Conoy Fishing Pond) (USACE and/or MDE jurisdictional) and 8350 linear feet of stream 

9 will be required to satisfy Clean Water Act s. 404 standards and obtain regulatory authorization 

10 for Unit 3 construction. After field reconnaissance and site walk-through of the Calvert Cliffs site 

11 property in 2007 and 2008, including the Unit 3 project area, specific locations were identified as 

12 having ecological lift potential for wetland enhancement, or as being suitable for the creation of 

13 wetland communities from upland landscape. 

14 Among the group of wetlands that will not be impacted by development of the Unit 3 facility, 

15 specific sites were selected that would benefit from mitigation providing for an increase in 

16 wetland values and functions. The wetland mitigation actions will include creation and 

17 enhancement within the Lake Davies Disposal Area (former sediment settling basins), the 

18 portion of Johns Creek to the south of the sediment basins, and an upland grassed field at the 

19 Camp Conoy area (wetland creation site). Phragmites (Phragmites australis) is found 

20 throughout the entire site, especially within the wetland sites proposed for mitigation. By 

21 eradicating Phragmites, the wetlands infested with this invasive nuisance species will have uplift 

22 for wildlife habitat and other important wetland functions. Increased diversification of native 

23 plant species will also be provided by planting these mitigation sites with native bottomland 

24 hardwood tree species and/or shrubs. Finally, by removing the Phragmites from the degraded 

25 wetlands, a more normal hydrologic regime will be established. 

26 The wetland mitigation component of the compensatory mitigation plan includes the following 

27 proposed activities: 

28 • The creation of forested wetland habitat within the Camp Conoy area that lies within the 

29 CBCA (Mitigation Site WC-1); 

30 • The creation of palustrine forested and emergent wetland habitat within the middle 

31 manmade, abandoned, sediment basin of the Lake Davies Disposal Area (Mitigation Site 

32 WC-2); 

33 • The enhancement of a smaller manmade, abandoned, sediment basin within the Lake 

34 Davies Disposal Area (Mitigation Site WE-1); 

35 • The enhancement of a portion of Johns Creek and a linear drainageway extension occurring 

36 to the south of the Lake Davies Disposal Area (Mitigation Site WE-2); 
 Appendix K 

April 2010 K-3 Draft NUREG-1936

1 • The eradication of Phragmites through herbicide application and establishment of a native 

2 vegetation community (Mitigation Sites WC-2, WE-1, and WE-2); 

3 • The use of soil material from impacted onsite wetland areas that do not contain phragmites 

4 as a supplemental growth medium within wetland creation sites (Mitigation Sites WC-1 and 

5 WC-2). 

6 Following the onsite wetland creation and wetland enhancement activities for the proposed 

7 Unit 3 project, a 5-year annual monitoring program will be implemented in accordance with the 

8 requirements of the Mitigation and Monitoring Guidelines (USACE) and the protocols in the 

9 Maryland Compensatory Mitigation Guidance (IMTF). Furthermore, the monitoring program will 

10 be conducted pursuant to the Maryland Department of the Environment, Water Management 

11 Administration (MDEWMA) mitigation monitoring guidelines and protocols. 

12 Mitigation credit ratios for activities designed to replace impacted forested wetlands functions 

13 and values are 2:1 for creation and 3:1 for enhancement. The use of a 3:1 mitigation credit ratio 

14 for enhancement is based on controlling Phragmites coupled with the planting of native 

15 bottomland hardwood species. The credit ratio for the mitigation activity to replace impacted 

16 emergent wetlands functions and values is 1:1 for creation. 

17 STREAM MITIGATION 

18 The proposed Unit 3 site contains five proposed stream restoration reaches and five proposed 

19 stream enhancement reaches (perennial and intermittent) onsite. The stream reaches 

20 proposed for mitigation activities are primarily contained within the Woodland Branch and Johns 

21 Creek watershed, and secondarily in the Camp Conoy area that lies within the CBCA. 

22 The stream mitigation component of the compensatory mitigation plan includes the following 

23 proposed activities: 

24 • The restoration of stream channel corridor within the onsite portion of upper and lower 

25 Woodland Branch; 

26 • The enhancement of stream channel within the middle reach of Woodland Branch and two 

27 unnamed tributaries; 

28 • The restoration of stream channel within an unnamed tributary to and a portion of the 

29 mainstem of Johns Creek; 

30 • The enhancement of stream channel within an additional unnamed tributary to Johns Creek; 

31 and 

32 • The restoration and enhancement of stream channel within unnamed tributaries of the 

33 Camp Conoy area. 
Appendix K 

Draft NUREG-1936 K-4 April 2010

1 The proposed stream restoration and stream enhancement measures are intended to 

2 compensate for the unavoidable, direct loss of physical, biological and/or riparian function of 

3 impacted streams. Stream restoration will take advantage of opportunities to reconnect 

4 channels to their historic flow paths and restore active connection to wooded floodplains. Areas 

5 where degraded channels are abandoned will be designed to function as pockets of seasonal 

6 wetlands, ephemeral ponds, and oxbow lakes in the riparian zone. Stream enhancement 

7 activities, intended to improve existing stream physical and ecological functions within the 

8 channel’s current flow path include bank grading operations and floodplain creation at lower 

9 elevations, bank treatments, and native plantings. 

10 The stream restoration and enhancement mitigation opportunities, combined with the proposed 

11 stormwater management plan, will offset losses to watershed functions by increasing the ability 

12 to provide floodwater storage, naturally recharge local aquifers, improve water quality, and 

13 maintain stream and riparian functions that support corresponding ecology. 

14 The amount of stream mitigation proposed is based on a mitigation ratio of 1:1 for stream 

15 restoration and 2:1 for stream enhancement impacts. 

16 K.1 Reference 

17 Clean Water Act. 33 USC 1251, et seq. (also referred to as the Federal Water Pollution Control 

18 Act [FWPCA]). 

19 COMAR 26.23.04.03. 2007. “Mitigation Standards.” Code of Maryland Regulations. 
Appendix L 

Carbon Dioxide Footprint Estimates for a 

1000-MW(e) Reference Reactor

April 2010 L-1 Draft NUREG-1936

Appendix L 

Carbon Dioxide Footprint Estimates for a 

1000-MW(e) Reference Reactor 

1 The review team has estimated the carbon dioxide (CO2) footprint of various activities 

2 associated with nuclear power plants. These activities include building, operating, and 

3 decommissioning the plant. The estimates include direct emissions from the nuclear facility and 

4 indirect emissions from workforce transportation and the uranium fuel cycle. 

5 Construction equipment estimates listed in Table L-1 are based on hours of equipment use 

6 estimated for a single nuclear power plant at a site requiring a moderate amount of terrain 

7 modification. Equipment usage for a multiple unit facility would be larger, but it is likely that it 

8 would not be a factor of 2 larger. A reasonable set of emissions factors used to convert the 

9 hours of equipment use to CO2 emissions are based on carbon monoxide (CO) emissions 

10 (UniStar 2007) scaled to CO2 using a scaling factor of 165 tons of CO2 per ton of CO. This 

11 scaling factor is based on emissions factors in Table 3.3-1 of AP-42 (EPA 1995). Equipment 

12 emissions estimates for decommissioning are one-half of those for construction. 

13 Table L-1. Construction Equipment CO2 Emissions (metric tons equivalent) 

Equipment Construction Total(a) Decommissioning Total(b) 

Earthwork and Dewatering 1.1 × 104 5.4 × 103

Batch Plant Operations 3.3 × 103 1.6 × 103

Concrete 4.0 × 103

 2.0 × 103

Lifting and Rigging 5.4 × 103

 2.7 × 103

Shop Fabrication 9.2 × 102

 4.6 × 102

Warehouse Operations 1.4 × 103

 6.8 × 102

Equipment Maintenance 9.6 × 103

 4.8 × 103

TOTAL(c) 3.5 × 104

 1.8 × 104

(a) Based on hours of equipment usage over 7-yr period. 

(b) Based on equipment usage over 10-yr period. 

(c) Total not equal to the sum due to rounding. 

14 Workforce estimates are typical workforce numbers for new plant construction and operation 

15 based on estimates in various COL applications, and decommissioning workforce emissions 

16 estimates are based on decommissioning workforce estimates in NUREG-0586 S1, Generic 

17 Environmental Impact Statement on Decommissioning of Nuclear Facilities, Supplement 1 

18 Regarding the Decommissioning of Nuclear Power Reactors (NRC 2002). A typical 
Appendix L 

Draft NUREG-1936 L-2 April 2010

1 construction workforce averages about 2500 for a 7-year period with a peak workforce of 

2 about 4000. A typical operations workforce for the 40-year life of the plant is assumed to be 

3 about 400, and the decommissioning workforce during a decontamination and dismantling 

4 period of 10 years is assumed to be 200 to 400. In all cases, the daily commute is assumed to 

5 involve a 100-mi roundtrip with 2 individuals per vehicle. Considering shifts, holidays, and 

6 vacations,1250 roundtrips per day are assumed each day of the year during construction, 200 

7 roundtrips per day are assumed each day during operations, and 150 roundtrips per day are 

8 assumed 250 days per year for the decontamination and dismantling portion of 

9 decommissioning. If the SAFSTOR decommissioning option is included in decommissioning, 20 

10 roundtrips each day of the year are assumed for the caretaker workforce. 

11 Table L-2 lists the review team’s estimates of the CO2 equivalent emissions associated with 

12 workforce transport. The table lists the assumptions used to estimate total miles traveled by 

13 each workforce and the factors used to convert total miles to metric tons CO2 equivalent. CO2

14 equivalent accounts for other greenhouse gases, such as methane and nitrous oxide that are 

15 emitted by internal combustion engines. The workers are assumed to travel in gasoline16 powered passenger vehicles (cars, trucks, vans, and SUVs) that get an average of 19.7 mi per 

17 gallon of gas (FHWA 2006). Conversion from gallons of gasoline burned to CO2 equivalent is 

18 based on U.S. Environmental Protection Agency emissions factors (EPA 2007a, 2007b). 

19 Table L-2. Workforce CO2 Footprint Estimates 

 Construction 

Workforce 

Operational 

Workforce 

Decommissioning 

Workforce 

SAFSTOR 

Workforce 

Roundtrips per day 1250 200 150 20 

Miles per roundtrip 100 100 100 100 

Days per year 365 365 250 365 

Years 7 40 10 40 

Miles traveled 3.2 × 108

 2.9 × 108 3.8 × 107 2.92 × 107

Miles per gallon(a) 19.7 19.7 19.7 19.7 

Gallons fuel burned 1.6 × 107

 1.5 × 107 1. 9 × 106 1.58 × 106

Metric tons CO2 per 

gallon(b) 8.81 × 10-3 8.81 × 10-3 8.81 × 10-3 8.81 × 10-3

Metric tons CO2 1.4 × 105

 1.3 × 105 1.7 × 104 1.3 × 104

CO2 equivalent factor(c) 0.971 0.971 0.971 0.971 

Metric tons CO2 equivalent 1.5 × 105

 1.3 × 105 1.7 × 104 1.3 × 104

(a) FHWA 2006 

(b) EPA 2007b 

(c) EPA 2007a

20 Published estimates of uranium fuel cycle CO2 emissions required to support a nuclear power 

21 plant range from about 1 percent to about 5 percent of the CO2 emissions from a comparably 
 Appendix L 

April 2010 L-3 Draft NUREG-1936

1 sized coal-fired plant (Sovacool 2008). A coal-fired power plant emits about 1 metric ton of CO2

2 for each megawatt hour generated (Miller and Van Atten 2004). Therefore, for consistency with 

3 Table S-3 of Title 10 of the Code of Federal Regulations (CFR) Part 51.51, the NRC staff 

4 estimated the uranium fuel cycle CO2 emissions as 0.05 metric tons of CO2 per MWh generated 

5 and assumed an 80 percent capacity factor. Finally, the review team estimated the CO2

6 emissions directly related to plant operations from the typical usage of various diesel generators 

7 on site using EPA emissions factors (EPA 1995). The review team assumed an average of 600 

8 hours of emergency diesel generator operation per year (total for 4 generators) and 200 hours 

9 of station blackout diesel generator operation (total for 2 generators). 

10 Given the various sources of CO2 emissions discussed above, the review team estimates the 

11 total life CO2 footprint for a reference 1000-MW(e) nuclear power plant to be about 18 million 

12 metric tons. The components of the footprint are summarized in Table L-3. The uranium fuel 

13 cycle component of the footprint dominates all other components. It is directly related to power 

14 generated. As a result, it is reasonable to use reactor power to scale the footprint to larger 

15 reactors. 

16 Table L-3. Reference Reactor Lifetime Carbon Dioxide Footprint 

Source Activity Duration (yr) Total Emissions (metric tons) 

Construction Equipment 7 3.5 × 104

Construction Workforce 7 1.5 × 105

Plant Operations 40 1.9 × 105

Operations Workforce 40 1.3 × 105

Uranium Fuel Cycle 40 1.7 × 107

Decommissioning Equipment 10 1.8 × 104

Decommissioning Workforce 10 1.7 × 104

SAFSTOR Workforce 40 1.3 × 104

TOTAL 1.8 × 107

17 In closing, the review team considers the footprint estimated in Table L-3 to be appropriately 

18 conservative. The CO2 emissions estimates for the dominant component (uranium fuel cycle) 

19 are based on 30-year-old enrichment technology, assuming that the energy required for 

20 enrichment is provided by coal-fired generation. Different assumptions related to the source of 

21 energy used for enrichment or the enrichment technology that would be just as reasonable 

22 could lead to a significantly reduced footprint. 

23 Emissions estimates presented in the body of this environmental impact statement (EIS) have 

24 been scaled to values that are appropriate for the proposed project. The uranium fuel cycle 

25 emissions have been scaled by reactor power using the scaling factor determined in Chapter 6 

26 of this EIS and by the number of reactors to be built. Plant operations emissions have been 

27 adjusted to represent the number of large CO2 emissions sources (e.g., diesel generators, 
Appendix L 

Draft NUREG-1936 L-4 April 2010

1 boilers) associated with the project. The workforce emissions estimates have been scaled to 

2 account for differences in workforce numbers and commuting distance. Finally, equipment 

3 emissions estimates have been scaled by estimated equipment usage. As shown in Table L-3, 

4 only the scaling of the uranium fuel cycle emissions estimates makes a significant difference in 

5 the total carbon footprint of the project. 

6 L.1 References 

7 10 CFR Part 51. Code of Federal Regulations, Title 10, Energy, Part 51, “Environmental 

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

9 Federal Highway Administration (FHWA). 2006. Highway Statistics 2005 (Table VM-1). 

10 Washington, D.C. 

11 Miller, P.J. and C. Van Atten. 2004. North American Power Plant Air Emissions. Commission 

12 for Environmental Cooperation of North America, Montreal. 

13 Sovacool, B.K. 2008. “Valuing the greenhouse gas emissions from nuclear power: A critical 

14 survey.” Energy Policy 36:2940-2953. 

15 UniStar Nuclear Energy, LLC (UniStar). 2007. Technical Report in Support of Application of 

16 UniStar Nuclear Operating Services, LLC for Certificate of Public Convenience and Necessity 

17 Before the Maryland Public Service Commission for Authorization to Construct Unit 3 at Calvert 

18 Cliffs Nuclear Power Plant and Associated Transmission Lines. Prepared for the Public Service 

19 Commission of Maryland, dated November 2007. Accession No. ML090680065. 

20 U.S. Environmental Protection Agency (EPA). 1995. Compilation of Air Pollutant Emission 

21 Factors Volume 1: Stationary and Point and Area Sources. AP-42, 5th Ed. Research Triangle 

22 Park, North Carolina. 

23 U.S. Environmental Protection Agency (EPA). 2007a. Inventory of U.S. Greenhouse Gas 

24 Emissions and Sinks: 1990-2005. EPA-430-R-07-002. Washington, D.C. 

25 U.S. Environmental Protection Agency (EPA). 2007b. “Conversion Factors to Energy Units 

26 (Heat Equivalents) Heat Contents and Carbon Content Coefficients of Various Fuel Types.” In

27 Inventory of U.S. Greenhouse Gas Emissions and Sinks: Fast Facts 1990-2005. EPA-430-R28 07-002. Washington, D.C. 

29 U.S. Nuclear Regulatory Commission (NRC). 2002. Generic Environmental Impact Statement 

30 on Decommissioning of Nuclear Facilities, Supplement 1 Regarding the Decommissioning of 

31 Nuclear Power Reactors. NUREG-0586 S1, Vol. 1, Washington, D.C. 
Appendix M 

Supplemental Terrestrial Ecology Information 

April 2010 M-1 Draft NUREG-1936 

Appendix M 

Supplemental Terrestrial Ecology Information 

1 This appendix supplements information provided in the draft environmental impact statement 

2 (EIS) related to the Puritan tiger beetle (Cicindela puritana) and the northeastern beach tiger 

3 beetle (C. dorsalis dorsalis). 

4 M.1 Tiger Beetle Species Descriptions 

5 Management of listed tiger beetles on the Calvert Cliffs site began in 1993 when Baltimore Gas 

6 and Electric Company, the prior operator of Calvert Cliffs Units 1 and 2, entered a conservation 

7 agreement with the Nature Conservancy that designated a Tiger Beetle Habitat Protection Area 

8 (NRC 2000). Tiger beetle populations have been monitored within Calvert County annually 

9 since 1997 and on the Calvert Cliffs site, with the exception of 2001 and 2005 (Knisley 2009). 

10 Annual pedestrian surveys are conducted along Chesapeake Bay from late June to mid-July 

11 when adult beetle populations are at their peak seasonally. All adults were counted at the 

12 water’s edge where the beach is narrow, while wider beach sections were canvassed using a 

13 circuitous route. Waypoints are recorded to divide the beach into sections about 328 ft in 

14 length, and habitat attributes are noted. The remainder of this section describes the life history 

15 and habitat use of the two tiger beetle species that occur on and in the vicinity of the Calvert 

16 Cliffs site. 

17 M.1.1 Puritan Tiger Beetle (Cicindela puritana) 

18 Tiger beetles are typically the dominant invertebrate predators in the open, sandy dunes and 

19 beaches that they inhabit (FWS 1993). The Puritan tiger beetle (Cicindela puritana), measuring 

20 11.5 to 12.4 mm, occurred historically on beaches in Connecticut, New Hampshire, 

21 Massachusetts, and along the shore of the Chesapeake Bay in Maryland (55 FR 32088). 

22 Recently, the Puritan tiger beetle’s distribution has been drastically limited, with only three 

23 known locations: the Chesapeake Bay shoreline in Calvert County, around the mouth of the 

24 Sassafras River in eastern Maryland, and along the Connecticut River in Connecticut and 

25 Massachusetts (Figure M-1) (FWS 1993). The largest of these populations, found in Calvert 

26 County, has declined in numbers since the early 1990s (Knisley 2006). There also appear to be 

27 wide fluctuations in the numbers of adults observed at these sites from year to year. 

28 In 1990, the Puritan tiger beetle was Federally listed as threatened due to its limited distribution, 

29 coupled with threats from habitat loss and degradation and vulnerability to natural and human 

30 threats (55 FR 32088). A more recent status review of this species recommended the 
Appendix M 

Draft NUREG-1936 M-2 April 2010 

1 

2 Figure M-1. Distribution of the Puritan Tiger Beetle in the Chesapeake Bay Region (FWS 1993) 
Appendix M 

April 2010 M-3 Draft NUREG-1936 

1 Puritan tiger beetle be reclassified to endangered (FWS 2007). It is also a State of Maryland 

2 endangered species (MDNR 2007). 

3 The life cycle of Cicindela puritana takes up to 2 years to complete during which they transition 

4 through three larval instar stages. The adults emerge in June, and their numbers peak in late 

5 June through early July (FWS 1993; 55 FR 32088). Mating activities typically occur in the late 

6 afternoon. The females then move up to the adjacent cliff face to deposit their eggs (55 FR 

7 32088). The larvae hatch in late July or August and remain as first instars for 2 to 4 weeks then 

8 overwinter as second instars (FWS 1993). The following spring they molt into third instars and 

9 spend the summer and following winter in that stage (FWS 1993). 

10 Puritan tiger beetle larvae in the Chesapeake Bay populations construct and inhabit deep 

11 burrows in sparsely or non-vegetated sandy clay bluffs adjacent to the beaches where adults 

12 are found (FWS 1993; 55 FR 32088). The larvae tend to be most active during cool weather, 

13 especially in the fall as evidenced by observed open burrows (FWS 1993). The larvae are 

14 carnivorous and feed on small invertebrates that pass within reach of their burrows. They 

15 attach themselves to the lip of their burrows with hooks on their abdomen (FWS 1993). Adults 

16 exhibit some flexibility in beach habitat preference from wide sandy beaches to narrow beaches 

17 below clay banks (FWS 1993). Thus, important habitat is where the larvae inhabit the sparsely 

18 vegetated sandy bluffs adjacent to beaches. 

19 Adults are active day and night and are prey for other predators, including robber flies and 

20 spiders, and larvae are parasitized by an ant-like wasp (Methoca sp.) (FWS 1993). The larvae 

21 are also susceptible to erosion and destruction of their burrows from winter storms. However, 

22 the largest threat to the survival of these beetles is from loss and destruction of habitat required 

23 for larval survival from shoreline stabilization and development (FWS 1993). Natural erosion of 

24 cliffs by wave action and rainfall creates newly exposed habitat, suitable for oviposition and 

25 larval development, which is being destroyed by cliff stabilization structures such as the 

26 construction of bulkheads (55 FR 32088). Development often requires bank stabilization, and, 

27 as banks are stabilized, plant cover becomes established, reducing or eliminating suitable 

28 habitat and occupation by this beetle species (FWS 1993). 

29 Most Puritan tiger beetles that occur along the Chesapeake Bay occur within Calvert County 

30 (see Figure M-1). On the Calvert Cliffs site, this habitat is found on the southern portion of the 

31 Calvert Cliffs site only. Calvert County populations have fluctuated from more than 9000 in 

32 1988 and 1998 to less than 6000 in the past 3 years (Knisley 2006). Adult counts at the 

33 shoreline of the Calvert Cliffs site since 1997 have also fluctuated from a high of 616 in 1998 to 

34 a low of 49 in 1999, and the count was at 122 in 2008 (Knisley 2009). Adult beetles were 

35 observed where beach habitat was suitable, with most observations occurring south of the 

36 barge dock (Figure M-2). 
Appendix M 

Draft NUREG-1936 M-4 April 2010 

1 

2 Figure M-2. Proposed Facilities and Puritan Tiger Beetle Survey Results from 2006 (Adapted 

3 from USACE 2008; Knisley 2009) 
Appendix M 

April 2010 M-5 Draft NUREG-1936 

1 M.1.2 Northeastern Beach Tiger Beetle (Cicindela dorsalis dorsalis) 

2 Like the Puritan tiger beetle, the northeastern beach tiger beetle (Cicindela dorsalis dorsalis) is 

3 an important invertebrate predator. Its presence is an indication of a healthy beach community. 

4 Slightly larger than the Puritan tiger beetle at 13 to 15 mm (55 FR 32088), the northeastern 

5 beach tiger beetle inhabits dynamic beach environments closer to the water’s edge (FWS 

6 1994). 

7 C. dorsalis dorsalis has historically occurred from Cape Cod, Massachusetts, south to central 

8 New Jersey, and along the shores of the Chesapeake Bay in Virginia and Maryland (FWS 

9 1994). The species has been extirpated from Rhode Island; Connecticut; Long Island, New 

10 York; and New Jersey. Distribution is limited to two sites in coastal Massachusetts and 

11 throughout the Chesapeake shoreline (FWS 1994). Chesapeake Bay populations now 

12 constitute a significant portion of the known population of northeastern beach tiger beetles. The 

13 northeastern beach tiger beetle is a Federally threatened species, endangered in the State of 

14 Maryland (55 FR 32088; MDNR 2007), and a 5-year review of the status by the U.S. Fish and 

15 Wildlife Service (FWS) is pending for the northeastern beach tiger beetle (73 FR 3991). 

16 Northeastern beach tiger beetles emerge as adults in early June through mid-August, peaking in 

17 July (55 FR 32088). Adults are diurnally active on wider beach sections near the water’s edge 

18 on warm, sunny days where they mate and lay their eggs from late June through August (FWS 

19 1994). They preferably inhabit beaches at least 20-ft wide and move into new areas of 

20 deposition (Fenster et al. 2006). The adults feed mainly on small amphipods, arthropods, and 

21 flies and have also been observed scavenging dead amphipods, crabs, and fish (FWS 1994). 

22 The larval stages typically last through two winters with the first instar stage beginning in late 

23 July and August, and, by September, most of the larvae are second instars and remain active 

24 through November (FWS 1994; 55 FR 32088). Third instars from the previous summer’s cohort 

25 are also active during the fall, and both cohorts then hibernate over the winter on the beach until 

26 around mid March (FWS 1994). The third instar larvae then emerge as adults, while the newer 

27 cohort remains over the summer and following winter as third instars. However, if they hatch 

28 early and have an abundance of food, some can emerge as adults after only one winter (FWS 

29 1994). 

30 Northeastern beach tiger beetle larvae construct and inhabit burrows from which they ambush 

31 prey. Unlike Puritan tiger beetles, northeastern beach tiger beetles are found much lower on 

32 the beach in the upper intertidal to high-drift zones where prey is abundant (FWS 1994). 

33 Although burrows may be inundated at high tide, larvae have adapted by closing the burrow 

34 until water levels drop (FWS 1994). Unlike most other species of tiger beetles, the larvae of 

35 C. dorsalis dorsalis have been observed crawling on the beach, presumably relocating their 
Appendix M 

Draft NUREG-1936 M-6 April 2010 

1 burrows to more favorable areas in response to changing conditions (FWS 1994). The larvae 

2 are susceptible to desiccation due to their lack of a hard cuticle and are inactive during hot, dry 

3 periods (FWS 1994). 

4 Adults are preyed upon by birds, wolf spiders, and asilid flies (Fenster et al. 2006). The larvae 

5 are parasitized by an ant-like wasp (Methocha sp.) (FWS 1994), and they are also susceptible 

6 to erosion, flooding, and food availability. Larva-to-adult survival may be as low as 5 percent. 

7 Causes for decline of this species have been attributed to beach habitat destruction and direct 

8 mortality from recreational use, alteration by stabilization structures, and natural phenomena 

9 (FWS 1994). The larvae are particularly vulnerable to compaction or destruction of their 

10 burrows by human use and vehicular traffic on the beaches where they develop (55 FR 32088). 

11 Annual population levels of this species fluctuate widely, and local extinction and repopulation 

12 likely are survival mechanisms as adults are able to disperse widely. Marked individuals have 

13 been recovered 5 to 12 mi away, and some adults have been observed more than 50 mi from 

14 known populations. Lack of undisturbed beaches and proximate populations are hampering 

15 recruitment despite the wide dispersal abilities of the adults (FWS 1994). Northeastern beach 

16 tiger beetles prefer large, wide, exposed beaches with fine sand particles subject to natural 

17 erosion with little disturbance by humans (Fenster et al. 2006; 55 FR 32088). 

18 Historically in Calvert County, northeastern beach tiger beetles have been confined to the 

19 northernmost 300-ft section of beach on the Calvert Cliffs site that borders Flag Ponds Nature 

20 Park. No known population of the northeastern beach tiger beetle is established within the 

21 Calvert Cliffs site, although individuals have been observed on the Calvert Cliffs site. In 2004, 

22 four adult northeastern beach tiger beetles were observed on the beach approximately 5000 ft 

23 northwest of the existing Calvert Cliffs water intake structure, but none were observed from 

24 2006 to 2008 despite annual surveys (Knisley 2006, 2009). This location is the nearest known 

25 occurrence of this species to the proposed construction activity. No suitable breeding habitat, 

26 larvae, or burrows have been observed on the Calvert Cliffs site, and it is believed that this 

27 species does not have an established population on the site (Knisley 2006). 

28 M.2 References 

29 55 FR 32088. August 7, 1990. “Endangered and Threatened Wildlife and Plants; 

30 Determination of Threatened Status for the Puritan Tiger Beetle and the Northeastern Beach 

31 Tiger Beetle.” Federal Register. U.S. Department of Interior. 

32 73 FR 3991. January 23, 2008. “Endangered and Threatened Wildlife and Plants; Initiation of 

33 5-year Reviews of 10 Listed Species.” Federal Register. U.S. Department of Interior. 
Appendix M 

April 2010 M-7 Draft NUREG-1936 

1 Fenster, M S., C.B. Knisley, and C.T. Reed. 2006. “Habitat Preference and the Effects of 

2 Beach Nourishment on the Federally Threatened Northeastern Beach Tiger Beetle, Cidindela 

3 dorsalis dorsalis: Western Shore, Chesapeake Bay, Virginia.” Journal of Coastal Research

4 22(5):1133-1144. 

5 Knisley, C.B. 2006. Current Status of Two Federally Threatened Tiger Beetles at Calvert Cliffs 

6 Nuclear power Plant, 2006. Letter Report to Carla Logan, Constellation Generation Group, 

7 Baltimore, Maryland. Accession No. ML090690159. 

8 Knisley, C.B. 2009. Email from C.B. Knisley (Randolph-Macon College), to C.A. Duberstein 

9 (Pacific Northwest National Laboratory) dated January 13, 2009, “Subject: RE: Calvert Cliffs 

10 tiger beetles.” Accession No. ML100050568. 

11 Maryland Department of Natural Resources (MDNR). 2007. Rare, Threatened, and 

12 Endangered Animals of Maryland. Wildlife and Heritage Program, Annapolis, Maryland. 

13 U.S. Army Corps of Engineers (USACE). 2008. Public Notice in Reply to Application Number 

14 CENAB-OP-RMS(NAB-2007-08123-MO5 (Calvert Cliffs 3 Nuclear Project, LLC/UniStar Nuclear 

15 Operation Services, LLC). Accession No. ML082550288. 

16 U.S. Fish and Wildlife Service (FWS). 1993. Puritan Tiger Beetle (Cicindela puritana G. Horn), 

17 Recovery Plan. U.S. Fish and Wildlife Service Northeast Region, Hadley, Massachusetts. 

18 Accession No. ML100490629. 

19 U.S. Fish and Wildlife Service (FWS). 1994. Northeastern Beach Tiger Beetle (Cincindela 

20 dorsalis dorsalis Say), Recovery Plan. U.S. Fish and Wildlife Service, Hadley, Massachusetts. 

21 Accession No. ML071970332. 

22 U.S. Fish and Wildlife Service (FWS). 2007. Puritan Tiger Beetle (Cicindela puritana), 

23 Draft 5-Year Review: Summary and Evaluation. U.S. Fish and Wildlife Service, Annapolis, 

24 Massachusetts. 

25 U.S. Nuclear Regulatory Commission (NRC). 2000. Calvert Cliffs Nuclear Power Plant, Units 1 

26 19 and 2 – Renewal of Operating License. Available at http://www.nrc.gov/reading-rm/doc20 

27 collections/commission/secys/2000/secy2000-0010/2000-0010scy.html. 

BIBLIOGRAPHIC DATA SHEET

(See instructions on the reverse)

NRC FORM 335

(9-2004)

NRCMD 3.7

U.S. NUCLEAR REGULATORY COMMISSION 1. REPORT NUMBER

(Assigned by NRC, Add Vol., Supp., Rev.,

 and Addendum Numbers, if any.)

NUREG-1936 Volume 2

3. DATE REPORT PUBLISHED

MONTH

April

YEAR

2010

4. FIN OR GRANT NUMBER

2. TITLE AND SUBTITLE

Environmental Impact Statement for the Combined License (COL) for Calvert Cliffs Nuclear

Power Plant Unit 3 

Draft Report for Comment

5. AUTHOR(S)

See Appendix A

6. TYPE OF REPORT

Technical

7. PERIOD COVERED (Inclusive Dates)

8. PERFORMING ORGANIZATION - NAME AND ADDRESS (If NRC, provide Division, Office or Region, U.S. Nuclear Regulatory Commission, and mailing address; if contractor,

Division of Site and Environmental Reviews

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, 

provide name and mailing address.)

and mailing address.)

10. SUPPLEMENTARY NOTES

Docket 52-016

11. ABSTRACT (200 words or less)

This EIS has been prepared in response to to an application submitted to the U.S. Nuclear Regulatory Commission (NRC) by

Calvert Cliffs 3 Nuclear Project, LLC and UniStar Nuclear Operating Services, LLC (collectively referred to as UniStar) for a

combined license (COL). UniStar also submitted a joint Federal/State Application for the Alteration of Any Floodplain, Waterway,

Tidal or Nontidal Wetland in Maryland to the U.S. Army Corps of Engineers (Corps). The Corps is a cooperating agency on this

EIS. This EIS includes the analysis by the NRC and Corps staff that considers and weighs the environmental impacts of

constructing and operating a new nuclear unit at the Calvert Cliffs site and at alternative sites and mitigation measures available

for reducing or avoiding adverse impacts.

After considering the environmental aspects of the proposed NRC action, the NRC's staff preliminary recommendation to the

Commission is that the COL be issued as requested. This recommendation is based on (1) the application, including the

Environmental Report, submitted by UniStar and responses to requests for additional information; (2) consultation with Federal,

State, Tribal and local agencies; (3) the staff's independent review; (4) the staff's consideration of comments related to the

environmental review that were received during the public scoping process; and (5) the assessments summarized in the EIS,

including the potential mitigation measures identified in the ER and this EIS. The Corps' permit decision will be made following

the issuance of the final EIS.

12. KEY WORDS/DESCRIPTORS (List words or phrases that will assist researchers in locating the report.)

Combined license, COL, COLA

Calvert Cliffs Unit 3

draft environmental impact statement, DEIS, EIS

envrionmental review 

National Environmental Policy Act, NEPA

UniStar

14. SECURITY CLASSIFICATION

13. AVAILABILITY STATEMENT

unlimited

(This Page)

unclassified

(This Report)

unclassified

15. NUMBER OF PAGES

16. PRICE

NRC FORM 335 (9-2004) PRINTED ON RECYCLED PAPER

Office of New Reactors

U.S. Nuclear Regulatory Commission

Washington, D.C. 20555-0001

Same as above


UNITED STATES 

NUCLEAR REGULATORY COMMISSION

WASHINGTON, DC 20555-0001

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

OFFICIAL BUSINESS